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Privacy Policy

 > Privacy Policy

In this Privacy Policy, the expressions “Books Connect”, “we”, “us” or “our”) are a reference to 3 Step

World Pty Ltd (ACN 626 795 015) trading as Books Connect and its Related Bodies Corporate (as defined by the provisions of the Corporations Act 2001 (Cth) (Books Connect). Books Connect respects your right to privacy, and we are committed to safeguarding the privacy of our customers and visitors to the Books Connect app, website www.booksconnect.com.au and all sub-domains (App).

This Privacy Policy applies to personal information collected by us. We are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act) which govern the way private sector organisations collect, use, keep secure and disclose personal information.

If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint. Please see Section 13 for further details.

This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the App or Services to you, and you should stop accessing the App.

1. Definitions

Where the definition of a term does not appear in this Privacy Policy it shall be given its definition as outlined in our Terms and Conditions.

“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it no longer identifies or references an individual user.

“Client” means a user of the App.

“Data Controller” means Books Connect, the company responsible for the use and processing of Personal Information.

“Personal Information” means any information or opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information is true or not; and
  • whether the information is recorded in a material form or not.

“Services” means functionality provided by Books Connect or the App.

“Terms and Conditions” means the terms and conditions applicable to the use of the App as stated from time to time.

2. The types of information Books Connect gathers about its users

Information that you give us

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you, unless an exception under the Privacy Act applies to that disclosure or use.

At or around the time we collect personal information from you, we will endeavour, if requested by you, to provide you with a notice which details how we will use and disclose that specific information.

We receive, store and process information that you make available to us when accessing or using our App and Services. We set out some common collection, use and disclosure instances in the table below.
Information that you give us

We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you, unless an exception under the Privacy Act applies to that disclosure or use.

At or around the time we collect personal information from you, we will endeavour, if requested by you, to provide you with a notice which details how we will use and disclose that specific information.

We receive, store and process information that you make available to us when accessing or using our App and Services. We set out some common collection, use and disclosure instances in the table below.

Purpose Type of Information Uses Disclosures
General enquiries (via app, website, email or in person) Contact information: Such as your name, email address, phone number, address.

Other personal information volunteered by you in the content of your enquiry.

Customer Service: Any personal information collected in connection by our customer services department in processing and addressing your enquiry.

The uses we will make of Personal Information collected for this purpose include:
Services: the provision of our services to you including:

  • Using your Personal Information in order for you to use the products and services we offer;
  • To provide customer service functions, including handling customer enquiries and complaints.

Marketing: using your Personal Information for the purposes set out in “Marketing Services” section below.

General administrative and security use:

  • To protect Books Connect’s app and website from security threats, fraud or other criminal activities.
  • The use for the administration and management of Books Connect.
  • For Books Connect’s marketing and customer base analytics.
  • The maintenance and development of our products and services, business systems and infrastructure.
  • In connection with the sale of any part of Books Connect’s business or a company owned by a Books Connect entity.
  • To provide customer services to clients and for quality assurance purposes.
The types of disclosures we will make of Personal Information collected for the type of purposes listed include, without limitation, to:

  • Service providers (including IT service providers and consultants) who assist Books Connect in providing our products and services.
  • Related Bodies Corporate of Books Connect (including related entities).
  • Third parties in connection with the sale of any part of Books Connect’s business or a company owned by a Books Connect entity.
  • As required or authorised by law.
Online account and subscription (via website, email or online form) Contact and identifying information:

  • Such as your name, company name, email address, phone numbers, address.
  • The same details as above for each of the users registered on an account.
  • Other personal information volunteered by you during the transaction

Transaction: To the extent relevant to your subscription of transaction, we will collect:

  • Delivery information.
  • Billing and account details.

Customer Service

Subscription Payments:

Online accounts: If you create an account with Books Connect and opt to receive our products and services by way of subscription, and you provide us your Personal Information for this collection purpose, we will use it for:

  • Registering your account and providing you with a limited licence to use our products and services
  • Provide you with notifications
  • Processing of your subscription.
  • Customer service related contact.
  • The uses listed under “Marketing Services”.

General administrative and security use as detailed in the Uses column for “General enquiries”.

In summary, we may disclose this type of Personal Information to:

  • Our contractors, agents and third party providers who assist us in providing our products and services to you.
  • Third party users of the App.
  • The parties listed in the Disclosure column for “General enquiries”.
Marketing Services Contact information: Such as your name, email address, phone number, company (including those details on your business cards or email signature).

Mailing list: Personal Information collected upon registration for a mailing list.

General marketing and consumer analytics: using your Personal Information:

  • To aggregate with other information and to then use it for marketing and consumer analytics.
  • To offer you updates on our product or services and information that may be of interest to you.
  • For marketing and promotional activities by us (including by direct mail, telemarketing and email) such as our email alerts and newsletters.
  • For the Uses detailed above in “General enquiries”.

Online accounts or social media: If you create an account with Books Connect or participate in our social media platforms (such as Facebook, Twitter and Instagram) and you provide us your Personal Information, we will use it for:

  • Adding account holders to the marketing database.
  • Customer service related contact.
  • Responding to social media messages.
  • Fulfilling social media platform rules.
We may disclose your Personal Information to:

  • Third parties connected with the marketing process who assist us in providing our products and services to you.
  • The parties listed in the Disclosure column for “General enquiries”.

3. Collecting & holding Personal Information

Collection generally

As much as possible, or unless provided otherwise in this Privacy Policy or a collection notice statement, we will collect your Personal Information directly from you.

 

We may collect your Personal Information from you in a variety of ways, including: by email, through the App and forms. When you engage in certain activities, such as filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

 

Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.

 

Other collection types

We may also collect Personal Information about you from other sources, such as:

  • when we collect Personal Information about you from third parties; or
  • when we collect Personal Information about you from publically available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc.).

Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including the following circumstances:

  • where information is collected from publically available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc.); or
  • as otherwise required or authorised by law.

Unsolicited Personal Information

In the event we collect Personal Information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Books Connect (in its absolute discretion) that the Personal Information is not required, we will destroy the information or ensure that the information is de-identified.

 

How we hold your Personal Information

Once we collect your Personal Information, we will hold it securely and store it on either, infrastructure owned or controlled by us, or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act. Refer to Section 11 for more information.

 

Cookies and other Technologies

Books Connect’s App may use cookies and other similar technologies, such as such as web beacons and tracking URLs, which enable us to monitor traffic patterns and trends, and to serve you more efficiently if you revisit our App. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer. However, in some cases, cookies may enable us to aggregate certain information with other personal information we collect and hold about you. We may also allow our business partners to use their cookies and other tracking technologies on the App.

 

Therefore, when you access or use the App, you provide or make available certain information to us and to our business partners.

 

Books Connect extends the same privacy protection to your personal information, whether gathered by cookies or from other sources. Accordingly, our Privacy Policy will apply to our treatment of personal information we obtain via our cookies.

 

Books Connect uses cookies for a number of purposes, including:

  • to enable, facilitate and streamline the functioning of the App across different webpages and browser sessions;
  • to simplify your access to and use of the App;
  • to monitor and analyse the performance, operation and effectiveness of the App, so that we can improve it; and
  • to show you content (which may include advertisements) that is more relevant to you.

While you may disable the usage of cookies through your browser settings, our practices do not change in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application. We track your activities if you click on advertisements for Books Connect services on third party platforms such as search engines and social networks, and may use analytics to track what you do in response to those advertisements.

 

We may, either directly or through third parties we engage to provide services to us, also continue to track your behaviour on our own App for the purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the App and pay for your activities on the App. We may also, either directly or through third parties we engage to provide services to us, track your behaviour on our own App to market and advertise our services to you on the App and third party websites.

 

Third parties may not collect information about users’ online activities on the App except as described in this policy and our Cookie Policy.

 

Third-party social plugins

Our App may use social plugins which are provided and operated by third-party companies, such as Facebook’s Like Button. Consequently, you may send to the third-party company the information that you are viewing on a certain part of our App and your interactions with the social plugin may be recorded by the third party.

 

Please refer to the third party’s privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.

4. Using & disclosing Personal Information

Use and disclosure details

We provide a detailed list at Section 2 of some common uses and disclosures we make regarding the Personal Information we collect. We may also use or disclose your Personal Information and in doing so we are not required to seek your additional consent:

  • when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your Personal Information to be used or disclosed for such a purpose;
  • if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
  • if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
  • if it is required or authorised by law.

 

Use and disclosure procedures
In the event we propose to use or disclose such Personal Information other than for reasons set out in the above table at Section 2 or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

Your Personal Information is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your Personal Information.

 

Communications opt-out
If you have received communications from us and you no longer wish to receive those sorts of communications, you should use the Unsubscribe link in all of our email communications, or contact us via the details set out in Section 13 and we will ensure the relevant communication ceases. Any other use or disclosure we make of your Personal Information will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

5. Sensitive information

Sensitive information generally

Sensitive information is a subset of Personal Information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

 

Collection and use of sensitive information

In general, we do not collect sensitive information from you, but depending on the uses you make of our products and services this may not always be possible and we may collect sensitive information from you in order to provide our services to you. However, we do not collect sensitive information from you without your consent.

We do not use sensitive information to send you Direct Marketing Communications (as set out in Section 6 below) without your express consent.

 

Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

6. Direct Marketing

Express informed consent

You give your express and informed consent to us using your Personal Information set out in:

  • the “General Enquiries” section of the table at Section 2 above; and
  • the “Marketing Services” section of the table at Section 2 above;

to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

 

Inferred consent and reasonable expectations of direct marketing

Without limitation to paragraph 6.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your Personal Information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

 

Opt-out

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 6, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out in Section 13.

7. Your privacy when you leave the App to access third-party websites and resources

The App may contain links to other websites not owned or controlled by Books Connect. Books Connect does not have any control over third party websites and they are not covered by this Privacy Policy. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They may have their own rules about the collection, use and disclosure of Personal Information.

8. Integration with third party sites

We may integrate the App with third party sites such as Facebook, so that you can send invitation messages or requests for references via the third party site itself. These messages will be sent by the third party site, and Books Connect does not collect or retain the contact information that is used by that site.

9. Cross Border Disclosure

Any personal information collected and held by Books Connect may be disclosed to, and held at, a destination outside Australia, where we utilise third party service providers to assist Books Connect with providing our goods and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or one of our suppliers, agents, partners or related entities.

 

As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than Australia.

 

In addition, we may utilise overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist Books Connect with providing our products and services to you.

 

By submitting your personal information to Books Connect, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

 

The Privacy Act requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act. By providing your consent, under the Privacy Act, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

 

If you do not consent to the disclosure of your personal information outside Australia by Books Connect, you should (after being informed of the cross border disclosure) tell Books Connect that you do not consent. To do this, either elect not to submit the personal information to Books Connect after being reasonably informed in a collection notification or please contact us via the details at the end of this document.

10. Consent, modifications and updates

Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, Books Connect may incorporate the terms of this policy such that:

  • certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Books Connect, but do create contractual obligations on the other party to the contract; and
  • the consents provided in this policy become contractual terms provided by the other party to the contract.

Acknowledgement
By using our App, or using Books Connect’s services, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

  • to provide the consents given by you in this Privacy Policy; and
  • that you have been informed of all of the matters in this Privacy Policy.

Modifications and updates
We may change how we collect and use Personal Information at any time and without prior notice, at our sole discretion. We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information due to the changes in our Privacy Policy, please cease providing us with your personal information and contact us via the details set out at the top of this document.

11. Data security & quality

Books Connect’s security generally

We have taken steps to help secure and protect your Personal Information from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or Personal Information, especially where human error is involved or malicious activity by a third party.

Notwithstanding the above, we will take reasonable steps to:

  • make sure that the Personal Information we collect, use or disclose is accurate, complete and up to date;
  • protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure both physically, electronically on our server, and through computer security methods; and
  • destroy or permanently de-identify Personal Information if it is no longer needed for its purpose of collection.

Accuracy

The accuracy of Personal Information depends largely on the information you provide to us, so we recommend that you:

  • let us know if there are any errors in your Personal Information; and
  • keep us up-to-date with changes to your Personal Information (such as your name or address).

We provide information about how you can access and correct your information in Section 13.

12. Change in ownership of Books Connect

If Books Connect undertakes or is involved in any merger, acquisition, reorganisation, sale of assets or bankruptcy or insolvency event, then we may sell, transfer or share some or all of our assets, including your Personal Information. If this is to occur, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.

13. Resolving Privacy Complaints

Complaints generally

We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

 

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, you may contact 3WS by emailing admin@booksconnect.com.au

 

Steps we take to resolve a complaint

In order to resolve a complaint, we:

  • will liaise with you to identify and define the nature and cause of the complaint;
  • may request that you provide the details of the complaint in writing;
  • will keep you informed of the likely time within which we will respond to your complaint; and
  • will inform you of the legislative basis (if any) of our decision in resolving such complaint.

Register of complaints
We will keep a record of the complaint and any action taken in a Register of Complaints.

14. Access to your personal information

You may request details of personal information that we hold about you in accordance with this policy or applicable law. A small administrative fee may be payable for the provision of information.

 

If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at admin@booksconnect.com.au

 

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in this policy, or as permitted by law.

15. Consent, modifications and updates

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more parties. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, Books Connect may incorporate the terms of this policy such that:

  • certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not impose contractual obligations upon Books Connect, but do impose contractual obligations on the other party to the contract; and
  • the consent provided in this policy become contractual terms provided by the other party to the contract.

By using our website, purchasing a product or service from Books Connect, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

  • to the terms of this Privacy Policy;
  • that you have been informed of all the matters in this Privacy Policy; and
  • that you provide your consent, wherever necessary, in accordance with this Privacy Policy.

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