Runway Switched-on Group Privacy Policy

This is the privacy policy (“Privacy Policy“) that governs how we, switched on group (SOG). and our affiliate brands Runway, Master plans, Capsule etc (collectively, “SOG“, “we“, “us” or “our“), use Personal Information (defined below) pertaining to each of our registered users and/or our unregistered visitors (“User“, “you“) that we collect, receive and store in connection with the use of our websites. Any capitalised but undefined term in this Privacy Policy shall have the meaning given to it in the Terms, available at: privacy@runway.com.au

Please read this Privacy Policy carefully, before using our Site, so you can fully understand our practices in relation to Personal Information.

1. Introduction.

We are committed to respecting your privacy and we recognize your need for the protection and management of any Personal Information that you share with us. We provide this Privacy Policy to explain, in as clear and plain language as possible, our online information practices, how we collect and use information pertaining to each of our Users, and the choices you can make about the way your Personal Information is collected and used in connection with the Site. You will also find an explanation of certain rights you have (see the section addressing “your rights”) in respect of your Personal Information. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy provides you with information about:

• What information we collect, why we collect it, and how it is used;
• How we protect and store your information;
• How we share your Personal Information
• Transferring Personal Information
• The legal basis for using your Personal Information
• Your rights
• Direct marketing and how you can manage your preferences
• Cookies
• Opt-out Option
• How to Contact Us

We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site and your continued use of the Site thereafter means that you accept those changes, and therefore we ask you to check back periodically for the latest version of the Privacy Policy. If there will be any significant changes made to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Site.

SOG will request your consent to collect your personal information Your Personal Data will be used for the purposes set forth in this Privacy Policy only and will not be shared or sold to any external and or 3rd party organization except as contained herein.

2. What Personal Information We Collect, Why We Collect It and How We Collect It.

We receive and/or collect Personal Information from you when you:

• Submit a website enquiry
• Post comments on our Social Media pages
• Request to receive updates and newsletters from us
• Request access to product demos
• Request access to download a brochures or other online material
• Commence direct communications with us either in relation to a new business or Support query.
• Submit a Website Enquiry. We collect Personal information when you send us a request to receive updates via our Site enquiry form. In order to receive update, we will request the following Personal Information from you: Your first name, email address, telephone, company name. This information is mandatory so we could contact you and respond to your request and send information such as newsletters and product releases.
• Posting comments on our User Communication Platforms. The community Forum. Information we collect includes first name, last name, email address, telephone, company name.
• Request to receive updates and newsletters from us. We collect Personal information when you send us a request to receive updates via our Site enquiry form. In order to receive update, we will request the following Personal Information from you: Your first name, last name, email address, telephone, company name. This information is mandatory so we could contact you and respond to your request and send information such as newsletters and product releases.
• Commencing direct communications with us either in relation to a New Business or Support Query We collect Personal Information when you commence direct communications with us by send us a “contact us”, “Jira Ticket”. We will request the following Personal Information from you:. Your first name, last name, email address, telephone, company name. This information is necessary so we can contact you and respond to your request and send information. When you commence direct communications with us, we will retain such communication(s) and the accompanying Personal Information you provide together with them for the amount of time necessary to adequately and professionally process your inquiries, respond to your requests and improve our services to our Users.

3. General use of our Site.

The Site makes use of log files. We use log files to collect the following information: internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the site, track user’s movement around the Site, and gather demographic information. Cookies.

• Some of our Site pages use “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about Site activity. Our Site uses two types of cookies: session cookies and persistent cookies. Session cookies are created temporarily in your web browser directory while you are visiting a website and are deleted once you leave the website. Persistent cookies remain in your web browser and are activated again once you visit the website that created that specific cookie. A web beacon is a small file used by a website or an advertisement-related action to keep track of your navigation through a single website or a series of websites. A pixel is a small line of code which is used by a website or an advertisement-related action to assign online activities to a computer or browser.
• We use cookies and other technologies in order to ensure proper operation of our Site, collect non-personal information and ensure information security. Although our collection of non-personal information does not personally identify users, we are still committed to giving you the opportunity to exercise your choice of opting out from our collection of such non-personal information.
• We will not use the above technologies to collect Personal Information without obtaining your permission, unless where we are permitted to do so under applicable privacy laws. Note that your consent to our collection and use of information, as described in this Privacy Policy, includes the collection and use of information that might generally be inaccessible in the event you had activated the “Do Not Track” option or a similar option or feature in your browser settings.
• Please note that your browser enables you to disable all cookies (if you do not know how to do this, check out the “Help” file of your browser), however, this may interfere with your use of the Site or other internet websites.
• If you would like to opt-out of the non-personally identifying cookies that our Website may use, please email us at privacy@runway.com.au
• If you use a new computer, upgrade or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.

4. How We Use and Share Personal Information.

We will Collect, Use and Share your Personal Information in the following circumstances:

• We will use the Personal Information you provide in connection with a request for updates that you submit on the Site and its related services to notify you about and send you updates and/or newsletters (for marketing or other purposes), regarding our offers, products and/or services.
• We will use some (or all) of your Personal Information to identify and authenticate your access to the parts of the Site and the related services that you are authorized to access.
• We will use your Personal Information that you provide in connection with a “contact us” “demo request” and “Support” request that you submit on the Site to contact you in response to your inquiry.
• In addition, we will share some (or all) of your Personal Information in the manner and for the purposes described below:
  • with our third-party service providers (such as a hosting provider, service provider or a payment processor) who assist us with managing our business operations and providing the Site and its related services, as well as complying with applicable privacy and data protection laws, and will use any Personal Information we share with them solely for the purpose of providing the contracted service(s) to us. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers that post a Privacy Policy governing their processing of Personal Information. Our third party service providers are located in Victoria and New South Wales.
  • We may disclose your Personal Information or any information you submit, if we have a good faith belief that disclosure of such information is reasonably necessary, to: (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, and/or (iv) protect against harm to the rights, property or safety of SOG, its users, yourself or the public.

5. Transferring Personal Information.

SOG will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests. To this end:

• where we transfer your Personal Information outside of SOG, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Information.
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.
• Subject to applicable laws, you have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your Personal Information when this is transferred as mentioned above. See “Your Rights” section below for more details.

6. The Legal Basis for Using Your Personal Information.

We will only collect, use and share your Personal Information where we are satisfied that we have an appropriate legal basis to do this. Such legal basis’ include:

• our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g., providing you with our services, creating your user account, communicating with you in relation to a query or complaint, as well as your general use of the Site);
• you have provided your consent to us using the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and
• our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g., the disclosure of information to law enforcement or tax authorities).

If you would like to find out more about the legal basis for which we process Personal Information please contact us at privacy@runway.com.au

7. Direct Marketing.

SOG regularly send marketing materials to our database:

• We may use your Personal Information to let you know about our products and services that we believe will be of interest to you. We may contact you by email, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
• To protect privacy rights and to ensure you have control over how we manage marketing with you, we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.

8. Opt-Out.

We take your preferences seriously:

• You may choose not to receive future emails from us by pressing an unsubscribe link added at the bottom of each email that you receive from us.
• Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative emails (for example, invoices) that are necessary to facilitate your use of the Site or the Account.

9. Your Rights.

Know your Rights.

• Accuracy and Correction of Personal Information. To the extent that you do provide us with Personal Information, please ensure that it remains accurate. If your Personal Information changes, or you wish to remove or modify certain Personal Information that we are storing, you may either correct or update it by logging-in to your Account and making the change(s), or by contacting us at privacy@runway.com.au. Your email should include adequate details of your request and also contain the following email topic: “PERSONAL INFORMATION UPDATE REQUEST”. We will provide initial responses to such requests within a reasonable period of time.
• Access. You have a right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law.
• Restriction of Processing. You have a right to restrict the processing of your Personal Information, for example in case when we no longer need your Personal Information for the initial purposes for which they were collected.
• Complaint. You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
• Right to Withdraw Consent. You have the right to withdraw consent at any time with respect to the data collected with your consent (see above). However, withdrawing consent shall not affect the lawfulness of processing based on consent before the withdrawal.
• Exercising Your Rights.
  • When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
  • You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.
  • In the event that your request, for example, would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Last Updated May 2018