PRIVACY POLICY

Ultimo aggiornamento: Mercoledì 20 Marzo 2019

(CollaborUP or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information and data.This Privacy Policy explains our policy for dealing with personal information and data that we collect through the following channels (here and after, the Collection Channels):

  • our online properties (here and after, each a “Website“), including:
    • the CollaborUP Platform (including the CollaborUP Influencer mobile application); and
    • our websites, including, but not limited to, https://www.collaborup.com and any of our related websites, social media pages, internal websites and other mobile or tablet applications;
  • any other means through which an individual provides personal information to CollaborUP, including either physically or electronically; and
  • any other means through which we lawfully collect personal information about you.

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting CollaborUP’s privacy officer in Italy via email: privacy@collaborup.com or mail: Via Montenapoleone 18, 20121 Milano

PERSONAL INFORMATION IS IMPORTANT TO US

  1. We are committed to safeguarding personal privacy. We recognize that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.
  2. Throughout this Privacy Policy, we refer to your ‘personal information’, which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
  3. CollaborUP has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles and have regard to the European Union’s General Data Protection Regulation (GDPR), and the privacy laws various states in the United States.
  4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
  5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

ON WHAT BASIS DO WE PROCESS YOUR DATA

  1. CollaborUP will only collect, monitor, use, disclose, or process any personal information about you with your consent (which we endeavour to obtain at the same time as collecting your personal information) or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties. We will generally deal with your personal information for the primary purposes set out in this Privacy Policy.
  2. For individuals in the European Union, CollaborUP processes your personal data on the legal basis of consent, which you grant when you subscribe to our Collection Channels or where otherwise requested.  CollaborUP also processes your personal data in order to perform its obligations under its agreement with you under the CollaborUP Platform Terms of Use, and, where necessary, for the purposes of our legitimate interests as set out in this Privacy Policy, such as maintaining a record of rights assigned or licensed to us. To the extent that your personal data must be provided to us, it is a contractual and not a statutory requirement. You are not obliged to provide us with your personal data. However, if you fail to provide us with such personal data, you withdraw your consent or request restriction over or otherwise object to our processing of your personal data, we may not be able to provides you access to, or all functionality of, the CollaborUP Platform or with other products or services.
  3. CollaborUP also reserves the right to use, disclose or otherwise process any personal information to satisfy any law, regulation or legal request, or in relation to CollaborUP’ other legitimate interests such as and where that personal information is relevant to legal action relating to CollaborUP.

ANONYMITY AND PSEUDONYMITY

  1. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we may seek the personal information identified in this Privacy Policy. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.

KINDS OF PERSONAL INFORMATION THAT CollaborUP COLLECTS AND HOLDS

  1. Personal information that may be requested includes, but is not limited to:
    1. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
    2. your Apple AppStore and/or Google Play Store ID and your unique device identifier (UDID);
    3. your social media handles and login details including usernames and passwords;
    4. location information;
    5. more detailed contact preferences;
    6. sensitive information about you;
    7. photographs of you;
    8. your occupation and information regarding your professional history and professional interests;
    9. information regarding your education and qualifications;
    10. information regarding your personal interests and interesting and relevant information about you;
    11. financial details including your bank account details and PayPal details;
    12. your online behavior and interests based on your online browsing activity;
    13. information about your preferences, interests, and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
    14. information about your experience with our products or services or third party products or services listed on a Website;
    15. your credit card details (where you purchase any products or services from us);
    16. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to CollaborUP and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
    17. any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this privacy policy).
  2. When you use a Website, we may also collect personal information about you in the following general categories:
    1. usage and preference information: we collect information about how you interact with a Website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
    2. device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
    3. other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.

SENSITIVE INFORMATION

  1. We do not seek to collect sensitive information (or “special categories” of information under the GDPR). If we do collect sensitive information, we will only do so with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, information about your sexual orientation, religious beliefs, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection will share this information with our trusted third parties in the manner stated on the Website or in this Privacy Policy.

HOW CollaborUP COLLECTS AND HOLDS PERSONAL INFORMATION

  1. We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties including social media platforms such as Instagram and Facebook and any other third parties or categories of third parties from whom personal information is collected].

ACTIVE INFORMATION COLLECTION

  1. information may be collected (and combined) via our Collection Channels if you:
    1. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
    2. sign-up and/or register to become a member of any Collection Channel;
    3. download and use a mobile and/or tablet application including the CollaborUP Influencer App;
    4. submit any content to or participate in any way via a Collection Channel, including engaging with other users or taking part in campaigns;
    5. subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
    6. complete and submit any forms or applications to us;
    7. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
    8. participate in any offers, promotions or marketing activities;
    9. interact with a Website for a specific purpose;
    10. interact with or browse a Website generally; or
    11. if you are a business we trade with, complete a credit application.
  2. Personal information is requested in order to allow you to participate in a Collection Channel, to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), marketing materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other CollaborUP or third party opportunities and products, services, offers, competitions or events which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in you being unable to participate in a Collection Channel and CollaborUP being unable facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, offer or event information or accept competition entries or other content from you (where applicable).
  3. We may collect your personal information from legitimate third party sources including social media channels, list brokers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so. If you are a representative of a business we trade with, we may also obtain your credit history information from a credit reporting body, and trade history information from references you provide us with.
  4. We may collect personal information from you in a passive manner including through the use of cookies and other tracking tools such as internet tags, tracking pixels, web beacons and unique device identifiers. Further information about the use of passive personal information collection is outlined in this Privacy Policy.

CHILDREN

  1. The collection of personal information is neither intended for, nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be collected by any person who is known by CollaborUP to be under the age of sixteen (16) without the consent of a parent or legal guardian. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.

PASSIVE INFORMATION COLLECTION

  1. As with many commercial websites and mobile and tablet applications, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
  2. As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth)or the GDPR. This is dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
  3. Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
  4. For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.

PURPOSES FOR WHICH CollaborUP COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

  1. Personal information collected will be used for the following primary purposes:
    1. For the purposes stated in a privacy collection statement on a particular Collection Channel.
    2. To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
    3. To fulfil obligations in respect of any upload terms of use, sale and purchase contract and/or any other contract between you and CollaborUP.
    4. To send you any technical, administrative or legal notices important to our Websites.
    5. To allow you to create an account, sign in and use the functionality of a particular Collection Channel including the CollaborUP Influencer App.
    6. To allow you to respond to opportunities, briefs or campaigns created by other users of a Collection Channel;
    7. To allow you to publish posts to your social media channels via a Collection Channel.
    8. To facilitate payments from you and to you via a Collection Channel.
    9. To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), content, services and products.
    10. To provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
    11. To provide you with relevant advertising when you use our Websites or those of a third party.
    12. To maintain our relationship with you.
    13. To render services related to our company (such as after sales services and enquiries).
    14. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
    15. To respond to customer enquiries, complaints and complaints handling.
    16. To improve Website and system administration.
    17. To obtain opinions or comments about products and/or services and to conduct other research and development.
    18. To record statistical data for marketing analysis and to conduct market research.
    19. To share personal information with our group companies, our promotional partners, trusted brands using a particular Collection Channel and their related bodies corporate and agents, and other trusted third parties in the manner described below.
    20. If you are a business we trade with, to carry on our trading relationship with you including identifying and contacting you, invoicing your correctly, assessing the risks of providing credit to you or your business, and securing and recovering any debts owed to us.
    21. Any other purpose as may be deemed reasonably necessary by CollaborUP in the circumstances.

CONSEQUENCES OF NOT PROVIDING INFORMATION

  1. Failure to provide personal information may result in you being unable to access or use certain Collection Channels, products or services or in CollaborUP being unable to provide you with certain content, information, products, services, upcoming opportunities, promotions, event or product information and/or accept content from you (where applicable).

HOW WE MAY SHARE YOUR PERSONAL INFORMATION

  1. For the purposes described above, personal information may be shared with CollaborUP group companies, CollaborUP promotional partners and their related bodies corporate, and other trusted third parties including brands and companies using the CollaborUP Platform (and their directors, servants and agents) either in Australia or overseas, including, but not limited to, New Zealand, the United States of America, the Philippines and the United Kingdom. Failure to provide personal information may result in CollaborUP being unable to provide you with certain content, information, upcoming opportunity, promotion, event or product information and/or accept content and promotion entries (where applicable).
  1. In order to operate a Website or deliver a service (including for example, processing of credit card payments), personal information may also be shared with CollaborUP group companies, selected service providers and their related bodies corporate, and/or other trusted third parties either in Australia or overseas countries which may include, but are not limited to, New Zealand, the United States of America, the Philippines and the United Kingdom. CollaborUP group companies, selected service providers and/or other trusted third parties may be engaged by CollaborUP to perform a variety of functions, such as legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions, marketing and email services, and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchase. They are not used for any other purpose and will never be supplied to a third party other than CollaborUP or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
  2. We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, CollaborUP reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of CollaborUP, any member of the CollaborUP group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

CONTACT BY CollaborUP

  1.  CollaborUP group companies (and their directors, servants and agents), CollaborUP promotional partners and their related bodies corporate or trusted third parties (including users of a Collection Channel) and other selected service providers and other non-CollaborUP companies or professionals either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
  2.  CollaborUP does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful. If you receive communications from CollaborUP which you do not wish to receive, you may remove your name from the database in the manner indicated in the communication, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting CollaborUP at the contact details in this Privacy Policy. Please allow 30 days for this request to be processed.
  3. Despite removing your name from the database from receiving future advertising and marketing information, CollaborUP may send you non-commercial “Administrative Emails”. Administrative Emails relate to a CollaborUP user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular CollaborUP user account. If you do not wish to receive such communications from CollaborUP, you may remove your name from the database by utilising the functional unsubscribe facility.

ABILITY OF OTHERS TO VIEW INFORMATION

  1.  CollaborUP may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users including commercial users and brands, provide reviews for content, products and/or services, utilise functionalities that allow you to post content to your own social media channels, or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our Websites. CollaborUP is not responsible for the conduct of others who may read, collect and use this information.

YOUR PRIVACY RIGHTS

  1. You have a number of rights under Australian privacy law the GDPR and the privacy law of various states in the United States. These include:
    1. (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, CollaborUP may determine that it is not legally required to give an individual access to personal information, in which case CollaborUP will provide you with a written notice of its refusal to provide access;
    2. (correction) to request that we correct your personal information;
    3. (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message;
    4. (transparency) to be informed generally about the collection and use of your personal data, including where we intend to further process your personal data for additional purposes other than as discussed above
    5. (complaint) to complain about a breach of the Australian Privacy Principles (or applicable privacy law); and
    6. (deletion) you may also request that we delete your personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in CollaborUP and its service providers or partners being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other product content, or services information, upcoming promotion, competition or event information, and/or provide certain content, goods or services. Unless required by applicable law, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.
  2. If you are an individual in the EU, you have additional rights under the GDPR that you can exercise against the “controller” of your data. Where we are the controller of your data, your rights include:
    1. (access) to request that we transfer your personal information to another service provider of your choosing;
    2. (erasure) to request that we erase your personal data. All reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain services (including the uploading, access to, and receipt of content on a website or the CollaborUP Application, and purchase transactions undertaken on a website);
    3. (objection and restriction) in some circumstances, to object to the use of your personal data by us and request that we restrict our use of your personal information; and
    4. (complaint) to lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the GDPR.
  3. To exercise these rights, please contact us at the contact details listed at the end of this Privacy Policy. Please allow for a reasonable amount of time for us to process your request, which will generally be up to 30 days.
  4. CollaborUP does not make decisions that produce significant effects on you which are solely based on automated decision making. CollaborUP may use limited automated decision-making based on your social media following to determine your eligibility to utilise aspects of the CollaborUP Platform.

STORAGE AND SECURITY OF PERSONAL INFORMATION

  1.  CollaborUP takes appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification or destruction of personal information. CollaborUP, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by CollaborUP.
  2. CollaborUP also takes reasonable steps to keep personal information accurate, up to date, complete and relevant. CollaborUP takes reasonable steps to ensure only those necessary have access to your personal information.  Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, as described above. CollaborUP retains your information only for as long as necessary for the purposes listed in this Privacy Policy.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS

  1. For individuals in the EU, please note that the recipients of your personal information may be located in countries in which the privacy or data protection laws differ from those of the European Union, and which are not the subject of an adequacy decision by the European Commission. For recipients of your personal information in Australia, the United States, and the Philippines appropriate or suitable safeguards over your personal data have been put in place by virtue of our compliance with the standard data protection contract clauses approved by the European Commission. Please contact our Privacy Officer for more information. For New Zealand, a data protection adequacy decision has been made by the European Commission.
  2. In some cases, CollaborUP may disclose your personal information to overseas recipients, including but not limited to recipients in New Zealand, the United States, the Philippines and the United Kingdom. CollaborUP employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by CollaborUP. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. CollaborUP will not be held responsible for events arising from unauthorised access to personal information.

CollaborUP AND LINKS TO OTHER WEBSITES

  1. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. CollaborUP is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
  2. We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by CollaborUP or any of its affiliates. CollaborUP is not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

RELATED CollaborUP WEBSITES

  1. All Websites operated by CollaborUP will adhere to this Privacy Policy. The policies on the Websites of some members of the CollaborUP group may vary, however, because of local customs, practices or laws.

SALE OF THE COMPANY

  1. If CollaborUP merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

PROBLEMS OR QUERIES

  1. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:

Italy

Address: The Privacy Officer
2018 © Copyrights ZETAWORKS SRLS
Via Montenapoleone 18, Milano
P.IVA 10270030967
Telephone:
Email: privacy@collaborup.com
  1. Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page, or, for individuals in the EU, to the data protection supervisory authority in your country.

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