PRIVACY POLICY

Last updated: March 2019

JLN Trading Pty Ltd trading as Andee (hereafter referred to as “” or “us” or “we”) is the owner, operator and licensor of the website at pufferbuddy.com.au (“Website”) and we provide psychological consulting services and related products including those available on and through the Website (“PufferBuddy”). Your rights to use the Website and Service (collectively the “Service”) are set out in this Privacy Policy (“Privacy Policy”) and in our Terms of Service (“Terms of Service”).

Our Terms of Service and our Privacy Policy are collectively referred to as the Agreement (“Agreement”).

We provide this Privacy Policy to help you make an informed decision about whether to use or continue using the PufferBuddy website and/or the Service. If you do not agree to our practices, please do not use the Website or Service.

This Privacy Policy is subject to the Terms of Service. Your use of the Website and the Service and any Personal Data you provide on the Website or Service remains subject to the terms of this Agreement.

Capitalised terms defined in the PufferBuddy Terms of Service have the same meaning in this Privacy Policy.

We know how important security and privacy is to you. We strive to make things as safe and clear as possible for everyone involved.

This Privacy Policy sets out how we treat the privacy of those who use our Website and associated services and others with whom we interact.

Please take a moment to read this Privacy Policy so you understand how your Personal Data will be used.

Part A: Privacy Policy

1. Application

This Privacy Policy applies to all Personal Data processed by us, including, but not limited to Personal Data and Billing Information submitted by Users through the Service.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we doe not employ or manage, including any of the third parties to which we may disclose User information as set forth in this Privacy Policy.

2. Changes

From time to time we will review our Privacy Policy to keep pace with changes in our Service and any data protection and privacy laws applicable to the processing of Personal Data that we are committed to comply with, including:

(a) the Privacy Act 1988 (Cth, Australia);

(b) the Privacy Act 1993 (New Zealand);

(c) the Personal Data Protection and Electronic Documents Act, SC 2000, c5 (federal, Canada);

(d) the Personal Data Protection Act (Alberta, Canada);

(e) the Personal Data Protection Act (British Columbia, Canada);

(f) all applicable United States federal and state privacy laws, including, but not limited to, the California Online Privacy Protection Act (CalOPPA), Early Learning Personal Data Protection Act (ELPIPA);

(g) the General Data Protection Regulation (EU);

(h) the Data Protection Act 2018 (UK);

(i) any other applicable privacy legislation.

The above are collectively referred to as “Data Protection Laws”

This Privacy Policy is our most recently updated Privacy Policy. Your continued use of the Website and Service constitutes your agreement to this Privacy Policy and any amendments. We encourage you to read our Privacy Policy carefully.

3. Collection of Personal Data

We may collect the following categories of Personal Data in in the following situations:

(a) Personal Data you voluntarily provide to us:

This includes Personal Data provided by the User directly (whether face-to-face, by telephone, email, post, through social media or by communicating with us in any way), when you make an enquiry or comment through our Website or over the phone or when you enter into a transaction with us by purchasing a PufferBuddy product you are voluntarily giving us the Personal Data that we collect. This further includes data collected through questionnaires on the Website in relation to customers feedback on products and other resources we develop.

Categories of Personal Data: The Personal Data we may collect includes your name, business name, position, physical address, email address, phone number, age, feedback and suggestions for the Service and billing information.

(b) Our email marketing list: If you elect to sign up to our email marketing list, we may collect your name, email address, and email marketing preferences.

(c) Personal Data we collect automatically: When you use our Service or browse our Website, we may collect information about your usage and web browsing. We may collect the Personal Data as log files, or through cookies or other tracking technologies (see the “Cookies and tracking” below for more information), store it, and link it to the other Personal Data we hold about you.

Categories of Personal Data: The Personal Data we may collect includes your IP address, your operating system, your browser ID, time, date, your browsing activity, your interaction with the Service.

(e) Statistical information: We may collect statistical (non-personal) information about your use of the Website and the Service to improve the features and overall user experience. This may include statistical information such as pages accessed on the Website and the Service, search terms, links that are clicked on, Website and Service visit times, browsers and operating systems, IP address, and cookies.

(f) Cookies and tracking: We may use various technologies to collect and store information when you use our Service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. You may control the use of cookies at the individual browser level, however your use of the Website and Service may be affected.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

The Website does not currently recognize Do Not Track (DNT) signals sent by our Users’ web browsers.

(g) Embedded content from other websites: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

4. Use of Personal Data

We process Personal Data for the following purposes:

• to respond to enquiries, feedback or complaints received from you;
• to perform authorised financial transactions;
• to provide a personalised service;
• to analyse and evaluate our User’s use of the Website;
• to combat and prevent breaches of our Terms of Service, other user agreements, this Privacy Policy and our other policies;
• for directly marketing to you (including by email, post, other means, or through functionality within the Service) with information about our Service;
• to protect our legal interests and fulfill our regulatory obligations (if and to the extent necessary);
• in other circumstances, provided we comply with applicable Data Protection Laws.

5. Lawful Basis for Processing

Performance of a contract: You acknowledge and agree that the processing identified below is necessary for the performance of a contract to which the Personal Data is central.

(a) to manage and deliver the Service; and

(b) to manage any disputes (including disputes over invoices or delivery of Service).

Legitimate interests: In respect of all other processing of Personal Data detailed in this Privacy Policy (including direct marketing activities), such processing is necessary for the purposes of a legitimate interest pursued by us, and we have assessed that such interests are not overridden by the interests or fundamental rights and freedoms of the persons to whom the Personal Data relates. You have the right to object to the way we process your Personal Data where the processing is based on legitimate interests. For more information see “Your Rights” section below.

6. Retention and deletion of Personal Data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website, we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

We take steps to regularly destroy Personal Data, however we may:

(a) in some cases, retain a copy of your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements and to comply with our trust and safety obligations. Personal Data retained for this purpose will be archived and stored in a secure manner and will not be accessed unless required for any of these reasons; and

(b) retain Personal Data in an aggregated, de-identified or otherwise anonymous form, such that there is no reliable way of identifying you from the information.

7. Disclosure of Personal Data

We will not sell Personal Data to anyone.

We may at our discretion use other third parties to provide essential services on our website or for our services. We may share your details as necessary for the third party to provide that service.

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your Personal Data and use your Personal Data only for the purposes that we give it to them.

8. Disclosure of Personal Data

Personal Data stored in our system is protected by electronic and procedural safeguards. We take reasonable precautions to protect Personal Data (and other content) from accidental loss and theft by storing it in secure data centres. Communication between Users and our servers is encrypted via industry-standard secure sockets layer (SSL).

In relation to website security, the Website is protected with an SSL Certificate. An SSL Certificate serves as a digital “passport” that allows data to be transmitted over secure networks — protecting financial and credit card transactions, signups, web access to mail, sensitive information and intranets. It authenticates and encrypts the data transferred through the Website to the server.

We take all reasonable steps to protect Personal Data, including through internal and external security, restricting access to Personal Data to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices.

Given internet transmissions cannot be guaranteed to be entirely secure, you acknowledge and agree that you use the Service at your own risk.

In case of a Security incident or any other breach of security safeguards, such as unauthorised disclosure of Personal Data under our control, we will respond in accordance with applicable Data Protection Laws.

9. Your Rights

You may decline to submit Personal Data through the Website or the Service, in which case we may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please discontinue use of the Service. Your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Service.

You have the right to:

(a)        access and correct your Personal Data that is held by us at any time.

(b)        request the erasure of any or all of your Personal Data;

(c)        restrict or object to the processing of any or all of your Personal Data; and

(d)        withdraw any consent to processing that you have previously given in respect of any or all of your Personal Data.

Please contact us (see contact details at the end of this Privacy Policy) with any questions or comments about this Privacy Policy, your Personal Data, your consent, access, correction requirements, or your opt-in or opt-out choices.

Please note that where we are not, or are no longer, in a position to identify you within the information we hold (including because of any de-identification techniques we may have employed), then your rights as described above shall not apply.

We will respond to any request made in respect of the above in accordance with the applicable Data Protection Laws.

We will respond to any request made in respect of the above without delay, but in any case within one (1) month of a request, or two (2) months where the requests are complex or numerous (in which case, we will inform you of such delay).

Part B: Your Responsibilities

10. Uploading and transferring other people’s Personal Data through the Service

By accessing and using the Service to upload and transfer other people’s Personal Data, you agree that you:

(a) Comply with all Data Protection Laws: will comply with your obligations under all applicable Data Protection Laws;

(b) Obtain consent: have obtained (or shall obtain) all consents necessary under Data Protection Laws, for us to process the Personal Data through the Service as you direct, and that such consent is obtained from the correct person.

 (c) Withdrawn consent or objection to processing: must notify us without undue delay if any User withdraws their consent, or any part of their consent, or objects to any processing of Personal Data through the Service. This shall include any withdrawal of consent.

(d) Security breach: upon becoming aware of a security incident, or any other breach, or suspected breach, of your security safeguards, must notify us without undue delay and shall provide timely information relating to the security incident as it becomes known or as is reasonably requested by us;

(e) Evaluation of the Service: are responsible for reviewing the information made available by us relating to data security and making an independent determination as to whether the Service meet your requirements and legal obligations under Data Protection Laws.

(f) Updates to Terms of Service and Privacy Policy: acknowledge that the Service is subject to technical progress and development and that we may update or modify our Terms of Service and this Privacy Policy from time to time, and you agree to review the latest version of the Terms of Service and Privacy Policy from time to time.

11. Questions and Comments

If you have any questions or comments, or want to access, update, or delete the Personal Data we hold about you, or have a privacy concern please email us at:

info@pufferbuddy.com.au

Please provide sufficient detail about the information in question to help us locate it. We will respond to any privacy request in compliance with the applicable Data Protection Law.