1. Easyweb means Easyweb Digital Pty Ltd (ABN 79 145 583 099) of 54-56 Langridge St, Collingwood, Melbourne, Victoria, 3066, Australia (Easyweb or we).
  2. This Privacy Policy (Policy) details how we treat your personal information whenever you deal with Easyweb, or use Easyweb’s services or when you access an Easyweb website or if your Easyweb service provider discloses your personal information onto Easyweb (collectively the Easyweb Services).

Definitions

  1. End Users means the ultimate user of the Easyweb Services.
  2. System Users means the individuals You (the subscriber of the Easyweb Services) permit to access (and configure) the Easyweb Services. If You wish, You can allow Your System Users to create their own System Users. Your System Users may create End Users.

What personal information?

  1. We collect certain personal information about visitors and users of the Easyweb Services.
  2. The type of personal information we usually collect includes: username, your login details, your gender, email address, birthdate, job title, your payment gateway login credentials, IP addresses, internet usage information, MAC address and user agent string, your location when you access Easyweb Services, contact details, images, payment information from payment gateway providers , transactional details, tax information, support queries, content you direct Easyweb to make available on Easyweb’s portal (such as problem solving tips), your actions on Easyweb Services (including any selections or inputs into items) and web and email analytics data. We will also collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes).

How does Easyweb collect personal information?

  1. We collect personal information directly when you provide it to Easyweb, automatically as you navigate through the Easyweb Services, or through other people when you use Easyweb Services through a third party.
  2. We collect your personal information when you provide it to Easyweb when you complete your subscription registration, or use an Easyweb Services, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send Easyweb a communication.
  3. If you allow End Users to use Easyweb Services, your End Users will have to provide express and voluntary consent prior to being able to access Easyweb’s Services.

Personal information we collect about you from others

  1. Although we generally collect personal information directly from you, on occasion, we also collect certain types of personal information about you from other sources. In particular:
    • financial and/or transaction details from payment gateway providers that you choose to process your payment transaction;
    • third party service providers (like Facebook) if you use a third-party service provider to access Easyweb Services (such as Facebook’s login API) in which case Facebook sends Easyweb information such as your registration and profile from that service. The information varies and is controlled by that service provider or as authorized by you via your privacy settings at that service provider; and
    • other third-party sources/and or partners whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you.

How we use personal information

  1. We use your personal information:
    1. 11.1.   to enable you to access Easyweb Services;
    2. 11.2.   where your personal information is necessary for purposes which are in our, or third parties’, legitimate interests such as:
      • operating, maintaining, improving and promoting the Easyweb Services;
      • process any financial transactions you have with Easyweb;
      • providing you with support or professional services;
      • updating you about anything that is relevant to you regarding the Easyweb Services including updates and planned or emergency outages;
      • monitoring activity on the Easyweb Services to minimise the risk of fraudulent activity and to ensure System Users and End Users comply with Easyweb’s subscription terms;
      • managing Easyweb’s legal and operational affairs (including, managing risks relating to content and fraud matters);
      • training Easyweb staff in relation to customer service issues; and
      • processing your job application to Easyweb;.
    3. 11.3.   when you give Easyweb consent:
      • to market products and services to you; and
      • customising the Easyweb Services such as through cookies or similar technologies – in order to provide a more personalised experience.
    4. 11.4.   When we are required to use your personal information by law, For purposes which are required by law.
    5. 11.5.   For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.

When we disclose your personal information

  1. We will disclose personal information to the following recipients:
    • if applicable, the System User that gave you access to the Easyweb Services as an End User, who maybe located in any of the countries Easyweb Services are available in;
    • subcontractors and service providers who assist Easyweb with the ways we use personal information (as set out above), in particular: website hosting providers which are located in the geographically closest region in which your System User resides ,technical and customer support services which are located in Australia, recruitment agencies which are located in Australia, sales, marketing and analytics services which are located in  Australia; security and fraud prevention services which are located in Australia; your payment gateway provider; and identification verification services located in the Australia. Easyweb’s subcontractors and services providers may also transfer and access such information from other countries in which they have operations.
    • our legal and commercial professional advisers which are located in Australia;
    • regulators and government authorities in connection with Easyweb’s compliance procedures and obligations;
    • a purchaser or prospective purchaser of all or part of Easyweb’s assets or Easyweb’s business, and their professional advisers, in connection with the purchase;
    • a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
    • a third party, in order to enforce or defend Easyweb’s rights, or to address financial or reputational risks;
    • a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
    • other recipients where we are authorised or required by law, or requests by government, a court of law, or law enforcement authorities, to do so.

Where we transfer and/or store your personal information

  1. We are based in Australia so your data will be processed in Australia.

Security of your personal information

  1. We may store personal information on secure servers that are managed by Easyweb and Easyweb’s service providers that are located in the geographically closest region in which your System User resides, and occasionally hard copy files that are kept in a secure location in Australia. Personal information that we store or transmit is protected by industry standard security and access controls.

Your access to your personal information held by Easyweb

  1. If you are a System User, you can access some of the personal information that we collect about you by logging in to your account. Currently, End Users are not able to access the personal information Easyweb has collected about them.
  2. You can request Easyweb correct any errors in that data Easyweb holds about you.
  3. You can request to access personal information we hold about you. Easyweb reserves the right to charge you a USD$25 to contribute to Easyweb’s time and administrative costs in complying with your request for access. Easyweb may request you to verify your identify before Easyweb provides you with access to your personal information.
  4. You can also close the account you have with Easyweb for any of the Easyweb Services at any time. To make an access or correction request, contact Easyweb’s privacy officer using the contact details at the end of this policy.

Marketing Choices regarding your personal information

  1. When you subscribe to Easyweb’s email list or otherwise have indicated that you are interested in receiving offers or information from us), Easyweb will send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
  2. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of the Easyweb Services may not work properly in your case.

Easyweb’s website cookies and web analytics

  1. When you visit the Easyweb website, Easyweb’s website collects certain generally anonymous information and that does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. The generally anonymous information we may collect include:
    • your IP address or proxy server IP address’;
    • the domain name you requested;
    • the name of your internet service provider;
    • the date and time of your visit to the website;
    • the length of your session;
    • the pages which you have accessed;
    • the number of times you access the Easyweb site within any month;
    • the file URL you look at and information relating to it;
    • the website which referred you to the Easyweb Services;
    • the operating system which your computer uses; and
    • the technical capabilities of your web browser.
  2. Occasionally, we will use third party advertising companies to serve ads based on prior visits to the Easyweb Services. For example, if you visit the Easyweb Services, you may later see an advertisement for Easyweb’s products and services when you visit a different Site.
  3. You can control or reset your cookies and similar technologies through your web browser, which will allow you to customise your cookie preferences and to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Easyweb Services may not function properly if the ability to accept cookies is disabled.

Information about children

  1. If you are under 16 we ask that you do not use the Easyweb Services without the supervision of your nearest responsible adult or give Easyweb your personal information. If you are from 16 to 18 years, you can access the Easyweb Services but you’ll need the supervision of a parent or guardian to become a registered user, if this is required by the System User that administers your Easyweb Services. It’s the responsibility of parents or guardians to monitor their children’s use of the Easyweb Services.

Information you make public or give to others

  1. If you make your personal information available to other people, such as on a public forum or on social media, Easyweb can’t control nor is Easyweb responsible for the way those other people use or manage that data. Before making your information publicly available or giving your information to anyone else, think carefully and check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

How long we keep your personal information

  1. We retain your personal information for as long as is necessary to provide the Easyweb Services to you and others, and to comply with Easyweb’s legal obligations. If you no longer want Easyweb to use your personal information or to provide you with the Easyweb services, you can request that we erase your personal information and close your Easyweb account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for Easyweb’s reasonable business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

When we need to update this policy

  1. We will need to change this policy from time to time in order to make sure it stays up to date with the legal requirements and Easyweb’s privacy management practices.
  2. When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

How you can contact us

  1. If you have any questions about Easyweb’s privacy practices or the way in which we have been managing your personal information, please contact Easyweb’s privacy champion in writing at 54–56 Langridge St Collingwood VIC 3066 Australia or privacy@easywebdigital.com.

If your personal information has been compromised

  1. If your personal information in our control is compromised as a result of a breach of security, Easyweb will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose personal information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

European Economic Area users

  1. For, European Economic Area (EEA) Easyweb users, Easyweb is obliged to comply with the requirements of the General Data Protection Regulation with respect to your personal information including the General Data Protection Regulation (GDPR). The GDPR governs how Easyweb may process your information, and the rights that EEA users have in relation to it.
  2. For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.
  3. If you are an Easyweb user to whom the GDPR applies, then, in addition to the rights described elsewhere in this policy, and subject to the exceptions provided for in the GDPR, you may require Easyweb to delete the personal information Easyweb holds about you, or that Easyweb ceases using it, if it is no longer required, if you withdraw your consent to Easyweb’s use of it or if you object to Easyweb’s processing of it. You may also require that Easyweb ceases to use your information where there is doubt over its accuracy.
  4. If you are an Easyweb user to whom the GDPR applies, then Easyweb needs your personal information to provide you the Easyweb Services and to fulfil Easyweb’s obligations under Easyweb’s Terms of Service. This use of your personal information is in Easyweb’s legitimate interests. Easyweb’s legitimate interests include providing properly functioning and improving Easyweb Services, obtaining payment for the Easyweb Services (if applicable), sending you marketing and enhancing our Service via research and development, data analytics, data labelling and machine learning. We do not rely on this lawful basis where our legitimate interest is overridden by your interest in protecting your data.
  5. If you are an Easyweb user to whom the GDPR applies, then You consent to Easyweb or have a reasonable expectation of Easyweb using your information in a certain way – for example, to inform you about new features or offers.
  6. All enquires relating to the processing of personal information and Pathfinder’s compliance with the GDPR, including any requests relating to the deletion or our ceasing to use your information should be addressed to the Privacy Officer at the details set out above.

Your consent to use your personal information

  1. Sometimes, Easyweb requires your personal information to comply with legal or contractual obligations. In this instance, then provision of such data is mandatory if you wish to use the Easyweb Services in the manner in which they were designed.
  2. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

Both personal information and personal data have the same meaning in this Privacy Policy.

Easyweb Privacy Policy v1.3, effective date 17th February 2021