PRIVACY POLICY

Introduction

M-SQUARE is committed to being transparent about how and when we collect, use and safeguard your personal information. Our Privacy Policy is designed to help you understand our privacy practices so you can make informed decisions.

By using the Service, our Website or by entering into an agreement with us in relation to any of the above you are taken to have read, and agreed to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.

M-SQUARE may, from time to time, review and update this Privacy Policy to take account of new laws, technologies and changes to M-SQUARE’s operations.

All personal information held by M-SQUARE will be governed by M-SQUARE’s most recent Privacy Policy. The most recent Privacy Policy will always be available on our Website or by contacting the M-SQUARE using the contact details displayed on our Website. You should review this Privacy Policy periodically so that you are updated on any changes.

In collecting and handling personal information, M-SQUARE is bound by the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1998 (Cth), and any other applicable privacy laws in Australia.

This Privacy Policy is in addition to the general Terms of Service governing your use of the Service (available at www.kweo.com) and should be read in conjunction with such Terms of Service. Capitalised terms in this Privacy Policy not otherwise defined carry the same meaning as those terms defined in the Terms of Service.

Who are ‘We’?
When we refer to ‘we’ (or ‘our’ or ‘us’), that means M-SQUARE Pty Ltd ACN 151 893 328 of Level 5, 115 Pitt Street, Sydney, Australia and our Related Entities.

We provide the ‘kweo’ online management platform made available to you via the Website, together with documentation, user instructions and any additional services provided to you (the “Service”).

If you want to find out more about the Service, please see our Website.

What Information we Collect?

Personal Information

As part of our normal operations we may collect your personal information. “Personal information” means identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on.

If you can’t be identified (for example, when personal information has been aggregated and anonymised), then this Privacy Policy doesn’t apply.

The types of personal information we collect will vary depending on the nature of your dealings with M-SQUARE and the Service. In general, the type of personal information M-SQUARE collects and holds could include, but is not limited to:

your name, address (postal and email) and contact details;
your geographic location (including your suburb or post code);
your bank account details;
transaction details relating to your use of the Service;
information about what you do when you use the Service
when you upload data, the data you upload; and
any preferences you tell us about.
Information which is not Personal Information

We also collect additional information about your interaction with the Service, and the related products and services without identifying you as an individual. For example, we may track and log your interaction with the Service, including the data and information you input in to the Service, for quality and security monitoring reasons, and to allow us to improve the Service. We may also use website analytics tools on our Service and Website to retrieve information from your browser, including the website you came from, the search engine(s) and the keywords you used to find our Website, the pages you view within the Service and our Website, your browser add-ons, and your browser’s width and height. We also use technologies, such as cookies, to collect information about the pages you view, the links you click and other actions you take on our Website and in the Service. Additionally, we receive certain standard information that your browser sends to every Website you visit, such as your IP address, browser type and language, access times and referring Website addresses.

Further, when you receive newsletters or promotional emails from M-SQUARE, we may use customised links or similar technologies to determine whether the email has been opened, which links you click on, and if and when you opt-out or unsubscribe from such email correspondence, in order to provide you with more focused email communications or other information.

How we Collect your Data
When you use the Service, or you visit our Website, we collect personal information. The ways we collect your personal information can be broadly categorised into the following categories:

Information you provide to us directly
When you use the Service or visit our Website, we might ask you to provide personal information to us. For example, we ask for your contact information when you sign up for a free trial, create an account, take part in training and events, contact us with questions or request support. If you don’t want to provide us with personal information, you don’t have to, but it might mean you can’t use some parts of the Service or our Website.

Information we collect automatically
We collect some information about you automatically when you use the Service or visit our Website, like the information and data you upload and input in to the Service, the way you use the Service, your IP address and browser and device type. We also collect information when you navigate through the Service and our Website, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using the Service and our Website so that we can continue to provide the best experience possible (e.g. by personalising the content you see and pre-loading information).

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at the sections below.

Information we get from third parties
The majority of information we collect, we collect directly from you. Sometimes we might collect personal information about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal information we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal information you provide.

Where we collect personal information, we’ll only process it:

to perform a contract with you; or
to make enhancements, improvements, modifications or new versions of the Service; or
where we have legitimate interests to process the personal information; or
in accordance with a legal obligation; or
where we have your consent.
If we don’t collect your personal information, we may be unable to provide you with all our Services, and some functions and features on our Service and Website may not be available to you.

If you do not have a relationship with us but believe that a Subscriber has entered your personal information into our Service or Website, you’ll need to contact that Subscriber for any questions you have about your personal information (including where you want to access, correct, amend, or request that the user delete, your personal information).

How we use your information

Use of Personal Information

First and foremost, we use your personal information and Your Data to operate our Service and Website, to provide you with our Services, and to manage our relationship with you. We also use your personal information and Your Data for other purposes, which may include the following:

To communicate with you. This may include:(i) providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you;
(ii) operational communications, like changes to our Service and Website, security updates, or assistance with using our Service, Services and Website;
(iii) marketing communications (about the Service or another product or service we think you might be interested in) in accordance with your marketing preferences; and
(iv) asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To support you: This may include assisting with the resolution of technical support issues or other issues relating to the Service, Services or our Website, whether by email, telephone, in-platform support or otherwise.
To enhance our Website and Services and develop new services: This may include:(i) storing your data and information for further processing;
(ii) tracking and monitoring your use of the Service and our Website so we can keep improving, or by carrying out technical analysis of the Service and our Website so that we can optimise your user experience and provide you with more efficient tools; and
(iii) making the Service and our Website easier to use by eliminating the need for you to repeatedly enter the same information.
To protect: So that we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using the Service, Services and our Website fairly and in accordance with our Terms of Service.
To market to you:In addition to sending you marketing communications, we may also use your personal information to display targeted advertising to you online – through our own Service or Website or through third party websites and their platforms.
To analyse, aggregate and report: We may use the personal information we collect about you and other users of the Service, Services and our Website (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.
Following termination or deactivation of your account with the Service, we may retain Your Data and other information for a commercially reasonable time for backup, archival, or audit purposes.

When you update Your Data and other information, we may keep a backup copy of the prior version(s) for a reasonable period of time to enable reversion to the prior version of that information.

Use of Information which is not Personal Information

We may share information which is not personal information, including information obtained through tools such as cookies and log files:

in any manner permitted for personal information; and
with our third-party business partners for the purposes described in the section above.
We may also aggregate or otherwise strip data of all personal identity characteristics and may share that aggregated, anonymized data with third parties.

This is discussed further in section 11 below.

How we can share your information
There will be times when we need to share your personal information with third parties. We will only disclose your personal information to:

M-SQUARE’s Related Entities;
Third Party Providers;
regulators, law enforcement bodies, Government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;
an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of M-SQUARE’s business; and
other people where we have your consent.
Further, when you use the Service, you should be aware that any data which you voluntarily upload and transmit to the Service may be viewed and used by other Authorised Users of the Subscriber (e.g. other people within your organisation). We are unable to control such uses of your information, and by using the Service you assume the risk that the information provided by you may be viewed and used by other Authorised Users.

International Data Transfers
When we share information, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States of America, where some of our Third Party Provider’s servers are located. These countries may have laws different to what you’re used to.

Where we disclose personal information to a third party in another country, M-SQUARE will take reasonable steps to ensure that all personal information is handled in a manner that is consistent with this Privacy Policy.

Treatment of Sensitive Information
In referring to ‘sensitive information’ we mean information relating to a person’s racial or ethnic origin, membership of political bodies, religions, trade unions or other professional or trade association, sexual preferences, criminal record and health information.

If you decide to provide M-SQUARE with sensitive information, it is M-SQUARE’s policy that this information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise or use or disclosure of this information is allowed by law.

Security
We strive to ensure the security, integrity and privacy of personal information submitted to our Service, Services and Website, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

We take physical, electronic and managerial steps to ensure that the personal information we hold is secure from unauthorised access, destruction, use, modification or disclosure. We only permit your details to be accessed by authorised personnel and we educate our staff about their responsibilities under the APPs. M-SQUARE has also appointed a Privacy Officer to oversee M-SQUARE’s management of personal information in accordance with this Privacy Policy and the Privacy Act. by You may contact the M-SQUARE Privacy Officer by sending an sending an email to [email protected].

Retention
The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).

We’ll retain your personal information for as long as we have a relationship with you and/or the Subscriber and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.

Cookies and Log Files
Cookies

Cookies are data that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies, which are industry standard and are used by most websites, including our Website and the Service, can facilitate your ongoing access to and use of our Website and the Service.

All pages on the Service and our Website are coded with measurement software which is transparent to you. The software makes use of an invisible image at the bottom of the web page. This software stores a “cookie” in the browser, which contains a unique string. This information is collected and aggregated, and in no way does this unique identifier identify a user personally.

When you use the Service, visit our Website, or visit other websites that have our services embedded, we may place one or more cookies on your computer in order to recognise your computer each time you visit these websites. These cookies allow us to collect certain information about your web browsing behavior. We use cookies to enable you to sign in to the Service and to help personalise your online experience. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalised content.

When you sign in to the Service using your sign-in credentials, a unique ID number is stored in an encrypted cookie on your hard disk. This cookie allows you to move from page to page at the site without having to sign in again on each page. When you sign out, these cookies are deleted from your computer. Cookies are also used to improve the sign in experience. For example, your email address may be stored in a cookie that will remain on your computer after you sign out. This cookie allows your email address to be pre-populated, so that you will only need to type your password the next time you sign in. If you are using a public computer or do not otherwise want this information to be stored, you can select the appropriate button on the sign-in page, and this cookie will not be used.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Service and Services that depend on cookies. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you chose to delete cookies, any settings and preferences, controlled by those cookies will be deleted and may need to be recreated.

Log Files

Log file information is automatically reported by your browser each time you access a web page. When you use the Service and our Website, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Your rights
It’s your personal information and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to [email protected].

You also have rights to:

know what personal information we hold about you, and to make sure it’s correct and up to date;
request a copy of your personal information, or ask us to restrict processing your personal information or delete it; and
object to our continued processing of your personal information.
You can exercise these rights at any time by sending an email to [email protected].

If you’re not happy with how we are processing your personal information, please let us know by sending an email to [email protected]. We will review and investigate your complaint and try to get back to you within a reasonable time frame. If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:

Tel: 1300 363 992

www.oaic.gov.au

For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner Website www.oaic.gov.au

Contact details
If you have any questions regarding this Privacy Policy, complaints regarding how we handle your personal information or would like to make an access request, please contact M-SQUARE by emailing [email protected].

Last updated: 1 January 2022