PRIVACY POLICY FOR SPANET SPALINK

Last Revised: 31st May 2019

 

STATEMENT

Spa Net Pty Ltd, an Australian limited liability company (“SN” or “we”), respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. We adhere to the National Privacy Principles established by the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information. “Personal information” is information we hold which is identifiable as being about you.

Please read the following carefully to learn more about our privacy practices that govern your use of our website(s), products, services (including products which connect to the Internet such as the SmartLink module and SmartStream module), mobile applications (including the SpaNET SpaLINK mobile application), and other firmware and software (collectively, the “Services”). By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies as outlined in this Privacy Policy, and you hereby consent that we will collect, use, store, and share your information in the certain ways as described within this Privacy Policy.

Your use of our Services and website(s) is at all times subject to SN’s Terms of Use, which incorporates this Privacy Policy. Any terms or capitalized words we use in this Privacy Policy without defining them have the meanings given to them in the Terms of Use. The Terms of Use are available at https://www.spanet.com.au/app-terms/

 

COLLECTION OF PERSONAL INFORMATION

This Privacy Policy addresses our collection, treatment, storage and use of personally identifiable information (“Personal Information”) that we gather when you access or use our Services, but not the practices of companies we don’t own or control, or people that we don’t manage.

SN collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our software applications (SpaNET SpaLink, and SpaLink AskMySpa) and when we provide our services to you. SN will, from time to time, receive and store this personal information you enter onto our software applications; provide to us directly, or give to us in other forms.

You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide basic functionality of our Services, personalize and improve our Services, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, post ratings and reviews, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

If you provide your third-party account credentials to us (for example, your login credentials for third party sites), you recognize some information and/or content within those accounts (“Third Party Account Information”) may be transmitted into your SN account with us, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy (such as profile information, images, friends, avatars and other authorized information).

Additionally, we may also collect any other information you knowingly provide while interacting with us.

 

USE OF THE PERSONAL INFORMATION

SN may use personal information collected from you to provide you with information, updates and our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs, and provide customer support when you contact us with an inquiry.

The Services may make third party social media features available to its users. We cannot ensure the security of any information you choose to make public in a social media feature. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy.

If you have provided us with a means of contacting you, we may use such means to communicate with you by a variety of measures including, but not limited to telephone, email, sms or mail. If you have consented to us doing so, we may send these items electronically and that you will be able to unsubscribe or opt out of receiving our commercial electronic messages. Please note that you may not be able to opt out of certain transactional-types of electronic messages from us (for example, notices, account statements etc.).

 

 

DISCLOSURE OF YOUR PERSONAL INFORMATION 

We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.

We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Spa Net Pty Ltd, its application, website and customers or third parties.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.  These may include, but are not limited to New Zealand, Europe and USA.

 

 

SECURITY OF YOUR PERSONAL INFORMATION

SN is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy, due to unauthorized entry or use, hardware or software failure, and other factors which may compromise the security of user information at any time.

If we reasonably believe a breach of security has affected your Personal Information that is under our control, and such breach creates a risk of significant harm, we will investigate the situation and, where appropriate, notify you. We will take all other steps which we believe are appropriate or legally required.

 

 

ACCESS TO YOUR PERSONAL INFORMATION

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988(Cth). 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 info@spanet.com.au.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

 

 

MOBILE APPLICATION (THE “APPLICATION”)

  1. Automatic collection

When you use our Application we may collect certain information automatically, including, but not limited to , the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

We also collect information on the types of devices that you use with SpaNET SpaLink, including control systems, keypads, pump and accessories for your spa pool or hot tub. Other information we may collect may include: app settings and historical information such as error codes, voltage readings and power usage.

  1. Cookies

We may from time to time use cookies on our software application. Cookies are very small files which a website uses to identify you when you come back to the application and to store details about your use of the application. Cookies are not malicious programs that access or damage your computer, tablet or smartphone. Most devices automatically accept cookies but you can choose to reject cookies by changing your devise settings. However, this may prevent you from taking full advantage of our Application.

  1. Third parties

Our software Application may from time to time have links to other applications or websites not owned or controlled by us. These links are meant for your convenience only. Links to third party applications and websites do not constitute sponsorship or endorsement or approval of these third parties. Please be aware that SN is not responsible for the privacy practises of other such applications or websites. We encourage our users to be aware, when they leave our application or website, to read the privacy statements of each and every application or website that collects personal identifiable information.

  1. Geo-location

When you visit the mobile Application, we may use GPS (global positioning system) technology (or other similar technology) to determine your current location in order to determine the city you are located within to provide you with location-based information and advertising. We will not share your current location with other users or partners. If you want to deactivate this feature you can deactivate GPS on your mobile device.

 

 

COMPLAINTS ABOUT PRIVACY

If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 4/103 Railway Road North, Mulgrave, New South Wales, 2756. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

 

 

OPT OUT RIGHT

You can stop all collection of information by our mobile application(s) easily by uninstalling the mobile application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at info@spanet.com.au.

 

 

CHANGES TO PRIVACY POLICY

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the revised Privacy Policy and changing the “Last Revised” date at the top. It is your responsibility to check back from time to time to review this Privacy Policy. It governs your user of the Services, and you are responsible for reading and understanding it. You are bound by any changes to the Privacy Policy when you use the Services after such changes have been posted.

 

 

CONTACT INFORMATION FOR QUESTIONS

If you have any questions about this Privacy Policy, including how we collect, use and disclose your Personal Information please contact us and we will try to address your concerns https://www.spanet.com.au/contact-us/