Privacy Policy

Last updatedSeptember 24, 2024


This Privacy Notice for Affilo Tech PTY LTD (trading as TheAffilo) ("we," "us," or "our"), sets out the way and why we may access, collect, store, use, and/or share ("process") your personal information when you access and use our services ("Services"), including when you:

  • Access our website at https://www.theaffilo.com, or any of our sites that reference this Privacy Notice.
  • Interact with us in other ways related to our business, including any sales, marketing, or events.

Any questions and concerns? Read this notice to understand your privacy rights and choices. We make the decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you have questions or concerns, please do so at legal@theaffilo.com.



SUMMARY OF KEY POINTS


This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.


What personal information do we collect? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.


Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.


Do we collect any information from third parties? We do not collect any information from third parties.


How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.


In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.


How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.


What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.


How do you exercise your rights? The easiest way to exercise your rights is by visiting theaffilo.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.


Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.



TABLE OF CONTENTS


1. WHAT INFORMATION DO WE COLLECT?
In Short: Your personal information, as you provide it to us.
We collect personal information that you voluntarily provide to us when you register on the Services, when you express your interest in obtaining information regarding us or our Services and products, when you engage in activities on the Services, or otherwise when you make contact with us.
Personal Information You Have Provided
Personal information we collect varies with the context of your interactions with us and the Services, your choices, and the products and features used by you. Personal information that we may collect includes the following:
  • names
  • phone numbers
  • email addresses
  • mailing addresses
  • usernames
  • passwords
  • contact preferences
  • billing addresses
  • website information
  • company details
Sensitive Information
We do not process sensitive information.
All information that you submit to us must be accurate, complete, and up-to-date, and you are required to let us know of any changes to such information.
Information collected automatically
In Short: Certain information is automatically collected as you interact with our services.
When you use our services, we collect non-identifiable information such as device information, IP address, browser and operating system, location and usage information automatically. We use this to keep things secure, improve features, and for internal analysis and reporting.
Similar to most companies, we also collect data via cookies and other technologies. You can learn more about this in our Cookie Notice.
The data we collect includes:
  • Log and Usage Data: Service-related, diagnostic, usage, and performance data such as IP address, browser type, device info, language settings, pages visited, searches, and timestamps.
  • Device Data: Data from the device you use such as IP address, device ID, browser type, hardware model, OS, system config, ISP, and carrier.
  • Location Data: Data regarding your device location (precise or imprecise) using GPS, IP address, or other technologies. You may opt out, but some features may be affected.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information for several reasons. From providing and improving to communicating and fraud prevention, we do everything in accordance with the law. We may also process your information for other purposes with your consent.
We process your personal information for a number of different reasons, depending on how you use our Services, including:
  • To enable account creation and authentication and otherwise to administer user accounts. We can process your information to allow you to create and sign in to your account and maintain your account in working condition.
  • In order to save or protect an individual's vital interest. We can process your information when required to save or protect an individual's vital interest, for example, in order to prevent harm.
3. WHY WE ARE ALLOWED TO USE YOUR INFORMATION
In Short: We only process your personal information when we conclude it's necessary and we have an appropriate legal basis to do so under applicable law, such as with your consent, to comply with applicable laws, to provide you services to enter into or fulfill our contractual obligations, to protect your rights, or in fulfillment of our legitimate business interests.
This section is relevant for users in the UK and the US
The UK GDPR and GDPR make it mandatory for us to explain the appropriate legal bases we depend on to process your personal data. Consequently, we may base processing of your personal data on the following legal bases:
  • Consent: We can process your data if you have provided us with consent (i.e., agreement) for us to use your personal data for a particular reason. You can withdraw consent at any time.
  • Legal Requirements: We can process your information where we have a belief it is required for compliance with legal requirements, for example, to assist with a law enforcement agency or regulatory body, to enforce or protect our legal rights, or to disclose your information as evidence in proceedings that we are part of.
  • Vital Interests: We can process your information when we believe that such processing is required to safeguard your vital interests or the vital interests of another party, as in cases involving possible dangers to the safety of any individual.
This section is relevant for users in Canada
We can process your data if you have explicitly provided us with consent (i.e., express consent) to process your personal data for a particular purpose, or where your consent may be implied (i.e., implied consent). You are free to withdraw your consent at any moment.
We can also process your data in certain exceptional situations without your consent, if legally allowed, including:
  • If collection is obviously in a person's interest and consent cannot reasonably be sought in a timely manner
  • For investigations and anti-fraud and anti-money laundering purposes
  • For commercial transactions where specified conditions are satisfied
  • If it is in a witness statement and collection is required to evaluate, process, or settle an insurance claim
  • For locating injured, sick, or deceased individuals and contacting next of kin
  • If we believe someone has been, is, or may be a victim of financial abuse
  • If collecting with consent would likely jeopardize the availability or accuracy of the information and it’s reasonable for investigation of a breach or law contravention
  • If disclosure is necessary for a subpoena, warrant, court order, or legal rules regarding production of records
  • If the data was created by someone in a professional role and the collection is appropriate for its intended purpose
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is public and this is permitted by regulation
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share data in certain circumstances explained in this section and/or with the following third parties.
We may be required to share your personal data in the following situations:
  • Business Transfers: We may share or transfer your information if our business is merged with, sold to, or taken over by another company, or as part of a business deal like a sale of assets or financing.
5. ARE COOKIES AND OTHER TRACKING TECHNOLOGIES USED BY US?
We might use cookies and other tracking technologies to collect and retain your information.
Certain online tracking technologies assist us with the security of our Services and your account, avoid crashes, repair bugs, retain your preferences, and help with general site features.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences).
Third parties and service providers apply their technology to deliver advertising for products and services customized to your interests which can show up either on our Services or other websites.
To the extent the online tracking technologies constitute a "sale"/"sharing" (including targeted advertising, as defined in the relevant laws) under relevant US state laws, you may opt out of these online tracking technologies by requesting as outlined below under section "Do United States Residents Have Specific Privacy Rights?"
6. HOW LONG DO WE HANDLE YOUR INFORMATION?
We only handle your personal information for as long as necessary to fulfil the purposes we have set out in this privacy notice or as legally required or permitted.
We will not keep your information longer than it is required, and in practice, only for as long as you have an account with us. The useless information will be deleted or stored anonymously.
7. HOW WE PROTECT YOUR INFORMATION?
In Short: We seek to safeguard your personal data by means of a system of technical and organisational security measures.
We employ suitable technical and organizational measures to help restrict the use of your personal information. But no system or internet connection is secure. We cannot and do not guarantee there is no way for hackers or other unauthorized people to access, steal, or modify your information, despite our efforts. While we will take our best efforts to guard your personal information, the transmission of personal information to and from our Services is your own risk. You may only access the Services from a secure environment.
8. DO WE CALL INFORMATION FROM CHILDREN UNDER 18?
Sum Up: We do not share information with minors who are under 18.
It should be noted that we do not, in any circumstances, collect personal data from minors. Neither do we sell them any products. However, if we ever did, then we will disable that account and delete all data related to it. If you believe we have collected such information, please contact us at legal@theaffilo.com so we can take steps to remove it from our systems.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Brief: If you live in areas like the US, UK, and Canada, then you may enjoy certain privacy rights. These rights may include the ability to view, update, or delete your account at any time.
In certain areas such as the EEA, UK, Switzerland, and Canada, you have specific rights under the relevant data protection laws. These can include the right:
  • To access and receive a copy of your personal information
  • To request correction or erasure
  • To restrict processing of your personal information
  • Where relevant, to data portability
  • Not to be subject to automated decision-making
In some situations, you are also entitled to object to the processing of your personal data. You can do so by contacting us using the contact information set out in the section "How Can You Contact Us About This Notice?"
We will review and respond to any request in line with data protection legislation applicable.
If you are in the EEA or UK, and you believe we are processing your personal information unlawfully, you have the right to complain to your Member State data protection authority or the UK data protection authority.
If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner.
Withdrawal of your consent: If we rely on your consent to process your personal information, you have the right to withdraw it at any time. You can do this by contacting us using the contact details listed in the section "How Can You Contact Us About This Notice?"
However, your withdrawal will not affect the lawfulness of the processing carried out before the withdrawal, nor will it affect processing done under other lawful grounds.
Opting out of marketing and promotional messages: You can opt out of our marketing and promotional messages at any time by:
  • Clicking the unsubscribe link in our emails
  • Replying to SMS with “STOP” or “UNSUBSCRIBE”
  • Contacting us using the contact details provided in this notice
You may still receive service-related messages even if you opt out of marketing communications.
Account Information:
If you would like to view or edit your account information, or make changes to your account, you can:
  • Log into your account settings and update your user account
  • Contact us using the contact details provided
Please note that we may retain certain information even after account deletion if required for investigation or compliance.
Cookies and other technologies:
Most web browsers accept cookies by default. You can usually modify your browser settings to delete or block cookies. This may affect some features or services. For more details, visit our Cookie Notice.
If you have questions or comments about your privacy rights, please email us at legal@theaffilo.com.
10. FEATURES FOR DO NOT TRACK CONTROLS
Most web browsers and some mobile operating systems and applications include a Do Not Track (DNT) feature or setting that you can activate to signal your preference not to have your online browsing activities tracked or collected.
However, currently there is no universal technology standard for recognizing and honoring DNT signals. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
If a future standard for online tracking is adopted that we must follow, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to state how we handle DNT browser signals. Since there is no accepted industry or legal standard for recognizing them at this time, we do not respond to DNT signals.
11. DO UNITED STATES' RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Collected
1. Identifiers Contact details, such as real name, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet address, email address, and account names. NO
2. Personal information in the California Customer Records statute Name, contact information, education, employment and history, and financial information NO
3. Characteristics under state or federal law Gender, age, date of birth, national origin, marital status, and other demographic data NO
4. Commercial information Transaction information, purchase history, financial details, and payment information NO
5. Biometric information Fingerprints and voiceprints NO
6. Internet or other similar network activity Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements NO
7. Geo-location data Device location NO
8. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
9. Professional or employment-related information Business contact details to provide our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO
10. Education Information Student records and directory information NO
11. Inferences drawn from collected personal information Inferences drawn to create a profile about an individual’s preferences and characteristics NO
12. Sensitive personal Information — NO

We might also gather other personal details beyond these categories through interactions with us via:

  • Customer support interfaces
  • Participation in surveys or competitions
  • Assistance in service delivery and answering inquiries

We’ll use and store the gathered personal data as necessary to deliver the Services or for:

Category H – While the user has an account with us

Sources of Personal Information

Learn more in the section titled "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

See the section "HOW DO WE PROCESS YOUR INFORMATION?"

Will Anyone Else See Our Information?

We may share your personal information with our service providers under written agreements. See "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal data for internal research or product improvement. This is not considered “selling.”

We have not shared, sold, or disclosed personal information to third parties for business or commercial purposes in the last 12 months. We do not plan to do so in the future.

Your Rights

You have rights under U.S. state data protection laws, including:

  • Right to know whether we process your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your data
  • Right to delete your personal data
  • Right to receive a copy of your provided personal data
  • Right to non-discrimination when exercising your rights
  • Right to opt-out of targeted advertising, sale of personal data, or profiling

Depending on your state of residence, additional rights may include:

  • List of types of third parties receiving your data (CA, DE laws)
  • List of individual third parties receiving your data (OR law)
  • Right to restrict sensitive data use/disclosure (CA law)
  • Right to opt out of collection via voice/facial recognition (FL law)
How to Exercise Your Rights

Contact us via:

We respect GPC (Global Privacy Control) opt-out signals in supported browsers.

Authorized Agent Requests

Authorized agents must present valid, written authorization. We may request ID verification for the requester.

Appeals

If we deny your request, you may appeal by emailing info@theaffilo.com. We will respond with a written explanation and instructions for filing a complaint if needed.

"Shine the Light" (California)

Under Civil Code § 1798.83, California residents can request a list of personal data types shared with third parties for direct marketing once per year, free of charge.

For more help, refer to the section: "How Can You Contact Us About This Notice?"

12. Do Other Regions Have Specific Privacy Rights?

In Short: You might have privacy rights that are specific to the country where you live.

Australia and New Zealand

We obtain and handle your personal information under the conditions and requirements of:

  • Australia’s Privacy Act 1988
  • New Zealand’s Privacy Act 2020

This Privacy Notice complies with both Privacy Acts by detailing:

  • What personal information we collect from you
  • How we collect it and from where
  • The purpose of collection
  • Any third parties your information is shared with

Note: If you choose not to provide certain personal information, it may impact our ability to:

  • Provide you with the products or services you request
  • Respond to or assist with your inquiries
  • Administer your account with us
  • Verify your identity and protect your account

You may request access to or correction of your personal data at any time.

For more information, refer to the section “How Can You Review, Update, and Delete the Data We Collect from You?”

If you believe we have mishandled your personal information, you have the right to file a complaint with:

  • The Office of the Australian Information Commissioner (OAIC)
  • New Zealand Privacy Commissioner
13. Do We Make Updates To This Notice?

In Short: Yes, we will revise this notice as needed to remain in compliance with applicable laws.

We could amend this Privacy Notice whenever we feel the need, with the changes indicated with a new "Revised" date shown at the top of the notice. It will be shared with you. Hence, we encourage you to reread the notice to stay informed about how we protect your information.

14. How Can You Contact Us About This Notice?

If you have any comments or queries regarding this notice, you can email us at legal@theaffilo.com or write to us at:

Affilo Tech PTY LTD
24 Glendenning St, St Albans VIC 3021, Australia
St Albans, Victoria 3021
Australia

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