Where the processing of your personal information is not subject to the Privacy Act or GDPR, different rules may apply under your applicable law.
We, Willow Technology Corporation Limited of Level 5, 320 Pitt Street, Sydney NSW 2000 or one of its subsidiaries which is identified in our communication with you, including Willow Technology Operations Pty Limited ABN 23 641 434 899 or Willow Digital Pty Ltd ABN 16 606 612 088 both of Level 5, 320 Pitt Street, Sydney NSW 2000, will be the responsible controller for any personal information you provide to us in connection with our business relationship or other interaction.
Depending on the nature of our business relation, we may process collect, hold, use and disclose your personal information for the following purposes (“Permitted Purposes“):
Please note: Under the GDPR (Article 21 (2)) you have the right to object to the use of your personal information for direct marketing purposes, including the profiling described above. Please refer to “Your rights” below for further explanation of your rights and how to exercise them.
Where your explicit permission is required for any marketing-related communication, we will only provide you with such information if you have opted in. You may opt out at any time if you do not want to receive any further marketing-related types of communication from us. We will not use your personal information for taking any automated decisions affecting you or creating profiles other than described above.
We will process your personal information for the above Permitted Purposes only:
The legal bases for processing of your personal information are set forth in Article 6 GDPR.
We will typically collect your personal information directly from you when you interact with us, e.g. when you visit our website, social media pages, communicate with us in relation to our products and services, request a product or service, register to our services, receive our newsletter or other specific marketing material or participate in our customer surveys. Where you have expressly given your consent, we may also obtain your personal information from third parties (including our contractors who supply services to us, our partner institutions or from a publicly maintained record) for communication and marketing purposes. In such cases, you will be informed about this in accordance with applicable law. Otherwise, we do not obtain personal information from third parties.
We may hold personal information electronically, or in paper files. We will maintain physical, electronic and procedural safeguards in accordance with the technical state of the art and legal data protection requirements to protect personal information against misuse, intrusion, interference, loss and unauthorised access, modification or disclosure. These safeguards include implementing specific technologies and procedures designed to protect your privacy, such as secure servers, firewalls and SSL encryption and depending on the information and the circumstances, this protection may in particular include:
Where Willow holds personal information that it no longer requires, Willow will take reasonable steps to destroy or de-identify such information, subject to any law or court order requiring retention.
Willow is a globally active enterprise. In the course of our business activities (including because we may use a cloud-based service to store and process personal information), we may transfer your personal information to entities located outside Australia, or where the GDPR applies, outside the European Economic Area including to the USA, Canada, Singapore, China, Hong Kong, Israel, Philippines and the United Kingdom , in which applicable laws do not offer the same level of data protection as the laws of your home country. When doing so, we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your personal information, in particular where the GDPR applies by entering into the EU Standard Contractual Clauses which are available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. You may contact us anytime using the contact details below if you would like further information on such safeguards.
We may share your personal information as follows:
Otherwise, we will only disclose your personal information when you direct or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or when we suspect fraudulent or criminal activities.
We will hold your personal information as long as required to provide you with the products or services or information you have requested and to execute and administer your business relationship with us. If you have asked us not to communicate with you, we will hold this information as long as required to comply with your request. We are also required to keep certain of your personal information (e.g. relating to business or tax relevant transactions) for certain retention periods under applicable law. Your personal information will be promptly deleted when it is no longer required for these purposes.
To obtain access or seek correction of your personal information that we hold, please contact us using the contact details below.
Where we process your personal information under the GDPR, subject to certain legal conditions, you may request access to, rectification, erasure or restriction of processing of your personal information. You may also object to processing or request data portability. In particular, you have the right to request a copy of the personal information that we hold about you. If you make this request repeatedly, we may apply a reasonable charge. Please refer to Articles 15-22 of the GDPR for details on your data protection rights.
If you have given us your consent for the processing of your personal information, you may withdraw your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If you withdraw your consent, we will only continue processing your personal information where there is another legal ground or where we are legally required to do so.
For any of the above requests, please send a description of your personal information concerned and appropriate proof of identity (e.g. your name or customer number) as proof of identity to the contact details below. We may require additional proof of identity to protect your personal information against unauthorized access. We will carefully consider your request and may discuss with you how it can best be fulfilled.
If you have any concerns about how your personal information is handled by us or wish to raise a complaint on how we have handled your personal information, you can contact us at the contact details below to have the matter investigated. Where a complaint is received, the Privacy Officer will consider the complaint, and within a reasonable time, will decide whether the complaint warrants further investigation. The complainant will be advised by Willow of the outcome of its investigations within a reasonable time.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you may refer the matter to the Office of the Federal Privacy Commissioner at Website: http://www.oaic.gov.au Phone: 1300 363 992. If your personal information is being processed within the scope of the GDPR, you can complain to the competent data protection supervisory authority in your country.
As a general principle, you will provide us with your personal information entirely voluntary; there are generally no detrimental effects on you if you choose not to consent or to provide personal information. However, there are circumstances in which Willow cannot take action without certain of your personal information, for example because this personal information is required to register your attendance at an event, provide you with a response to a communication or query, or to provide you with access to a web offering or newsletter or to carry out a legally required compliance screening. In some instances, we may be unable to provide you access to the services. In these cases, it will unfortunately not be possible for Willow to provide you with what you request without the relevant personal information.
Willow may gather information by cookies or other web-tracking or analytics technologies. A cookie is a small text file that is stored on your device for record-keeping purposes. You can remove cookies by following directions provided in your Internet browser’s “help” file or clearing out your browser’s cache. You may also decline our cookies if your browser permits, but doing so may interfere with your use of our website or the provision of our services.