This Privacy Policy is applicable to all companies within the SalesPond Group (which includes SalesPond, Datalist and Podiem).
Last updated: November 2021We are actively monitoring privacy laws globally, and, using the highest standards across them, have developed policies and processes that provide assurance within the company and to our clients, partners and interested parties, that the availability, integrity and confidentiality of their information will be maintained.
We adhere to the core requirements of the Australian Privacy Act that are set out in the Australian Privacy Principles (APPs). The APPs set out how an organisation such as SalesPond should collect, hold, use, and disclose personal information. The APPs also give individuals and households a right to know what information an organisation holds about him or her, and a right to correct it if it is wrong.
This Privacy Policy sets out SalesPond’s common global approach for handling personal information that is regulated by the above acts.
You can review the principles at https://www.oaic.gov.au/privacy/australian-privacy-principles
Most of the information we use is from publicly available sources however, the list below outlines the types of items we would gather, however not all of these items will be asked for any single service.
Name (First, Middle, Last) Job Title Department Company Name Phone Number Email Address
When collecting Personal Information our first preference is to collect the information directly from you, as that would be the most accurate. However, in some cases, we are provided personal information about you from our clients, or information suppliers. In these cases we can require them to assure us you have provided your consent for its use, before we use that information.
If we determine your consent has not been provided, we will de-identify or destroy that personal information.
Our internet facing applications collect certain personal information by automated means, using technologies such as cookies, session cookies, pixel tags, browser analysis tools, server logs and web beacons. We treat this information as personal information when it is associated with the individual’s contact information. In many cases, this information is not linked to any personal information you may provide and cannot be used to identify you (e.g. website traffic patterns).
However, before we use any cookies or similar programs we will ask for you (see above) for your consent and provide you the means, if you wish to limit or stop the use of cookies.
Pixel tags and web beacons
These are graphic images placed on website pages or in emails that allow us to determine whether the recipient has performed a specific action. When the recipient accesses these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.
For more details about cookies and how to change your cookie preferences see here https://www.allaboutcookies.org/manage-cookies/
We use personal information about you, only for the purposes contained in a consent received from you, or from our customers.
We will not disclose information that personally identifies you to any third party other than what you have consented to or otherwise required by local Law.
Direct Marketing
If we ask you to agree to allow us or our associates to “direct market” to you, you will be provided the option to accept or decline before we proceed. The default answer will be “No”.
Third Parties & Your Information
We will only collect, store, use or disclose personal information that you have provided consent, either directly or via our clients, unless we are required by law to protect our rights or property (or those of any third party), or to avoid injury to any person, e.g. a court order.
In order to deliver the services that we provide, we, on occasions must disclose your personal information to other organisations, only in relation to providing our services. For example, government agencies as required by law, banks and financial institutions, superannuation funds, health funds and contracted service providers (sometimes called SubProcessors).
We, when needed, will share personal information with business partners, but only, with your consent, either directly or as verified by our customers, and only to the extent required to provide our services.
We take steps to ensure that these organisations are bound by privacy obligations in relation to the protection of your personal information. These include:
Disclosure of Information Overseas
By default we store information in the country we collected it but, when required, will transfer to companies in foreign countries some of your personal information to fulfil the purpose for which it was provided. We will however before doing any such transfers:
Linked Sites
We have relationships with third party companies who may place advertisements on our sites, as well as perform tracking and reporting functions for us. These partners may place cookies on an individual’s computer when they visit our Sites, in order to display targeted advertisements. These partners are not allowed to collect personal information in this process, and we do not give any personal information to them as part of this process.
Our Sites may link directly to websites operated by third parties (Linked Sites), these Sites are not operated by us. We encourage you to always read the applicable privacy policy of any Linked Site on entering the Linked Site. We cannot control and thus are not responsible for the content or practices of the Linked Sites nor their privacy policies regarding the collection, storage, use and disclosure of your personal information. However, you still have the option of managing their cookies – see https://www.allaboutcookies.org/manage-cookies/
Only as long as it is needed to perform the purpose it was collected for, or longer if required by local law.
Once we no longer need your information we will either destroy or anonymise (de-identify) it.
We protect your personal information in a secure environment using industry best practice including, among other things:
These security measures are designed to ensure your personal information is not subject to unauthorised access, loss or misuse however, this security cannot be guaranteed procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Law requirements.
Consent
When we collect information from you, before we use that information, we will ask for your consent. We will tell you:
We will:
The GDPR confers additional privacy rights to E.U. citizens, however the SalesPond Group believes everyone should have these rights and more, so have included them for all in our internal policies and this Privacy Policy. These include, but are not limited to:
- Right to review the accuracy of your information
You have the right to review the information we hold about you, to ensure it is accurate and we only hold what you have consented to.
- Right to erasure
You can, at any time, request that we delete all personal information which relates to you. We will comply with any such request unless we are required to keep that information for:
- Right to restriction on data processing
In certain circumstances, you may also request a restriction on the processing of your personal data. You can make such a request in the following situations:
If you make such a request, we will not process any of your personal information without your consent, unless it is for the purposes of storage, legal claims, protecting the rights of another person or it is in the public interest of either the EU or the respective Member State.
- Right to data portability
In certain circumstances, you may request that we provide you with all personal information that relates to you. If this is the case, we will provide you with that information in a structured, commonly used and machine-readable format. Upon request from you, and subject to certain circumstances, we will also transmit that information to another controller.
- Right to object
You have the right to request that your personal information is not processed by us in various circumstances. These circumstances include the pursuit of business interests, direct marketing and profiling. Unless we have legitimate grounds to object to your request, we will stop processing data for the purposes requested.
If you request access to the personal information we hold about you, we will respond to your request within 30 days and, where reasonable and practicable, give access to the information in the manner you request. This will be subject to any exemptions allowed under the local laws.
You may request information or make a complaint by writing to: Privacy Office at [email protected].
Any requests for information should be directed to our Privacy Office at [email protected] and contain 100 points of identification, so we know you are who you say you are. Using the points table below:
You must supply at least ONE Primary document. Foreign documents must be accompanied by an official translation | Required on document N = Name, P = Photo, A = Address, S = Signature | Points Worth |
---|---|---|
Passport (current) (current or expired within last 2 years but not cancelled) | N-P | 70 |
Citizenship Certificate | N | 70 |
Full Birth certificate (not birth certificate extract) | N | 70 |
Certificate of Identity issued by the resident Government to refugees and non – local citizens for entry to the country | N | 70 |
Local Driver Licence/Learner’s Permit | NAP | 40 |
Current (local) Tertiary Student Identification Card | NP | 40 |
Photo identification card issued for local regulatory purposes (e.g. Aviation/Maritime Security identification, security industry etc.) | NP | 40 |
Current (local) Tertiary Student Identification Card | NP | 40 |
Government employee ID (local Federal/State/Territory) | NP | 40 |
Defence Force Identity Card (with photo or signature) | NP | 40 |
Department of Veterans Affairs (DVA) card | NA | 40 |
Benefits card (with reference number) | NA | 40 |
Birth Certificate Extract | N | 25 |
Birth card (Births, Deaths, Marriages issue only) | N | 25 |
Medicare/aid card | N | 25 |
Credit card or account card | N | 25 |
Marriage certificate (Local Registry issue only) | NS | 25 |
Decree Nisi / Decree Absolute (Local Registry issue only) | NS | 25 |
Change of name certificate (Local Registry issue only) | NS | 25 |
Bank statement (showing transactions) | NA | 25 |
Property lease agreement - current address | NA | 25 |
Taxation assessment notice | NA | 25 |
Local Mortgage Documents - Current address | NA | 25 |
Rating Authority - Current address e.g. Land Rates | NA | 25 |
Utility Bill - electricity, gas, telephone - Current address (less than 12 months old) | NA | 25 |
Reference from Indigenous Organisation | NP | 25 |
Documents issued outside the local jurisdiction (equivalent to local
jurisdiction documents). Must have official translation attached |
NP | 25 |
TOTAL |
SalesPond has appointed “DataRep” as its Data Protection Representative for the purposes of GDPR in the EU/EEA and the Data Protection Act 2018 (as amended) in the UK. DataRep has locations in each of the 27 EU countries, the UK, and Norway and Iceland in the European Economic Area (EEA) so you can contact them in your home country. Please click here for the contact details of your country.
If you are unsatisfied with how we have handled your complaint you can contact your local regulator to complain at:
Austria
Data Protection Council (Datenschutzrat)
www.bundeskanzleramt.at/site/6417/default.aspx (Datenschutzrat : Datenschutz : Fachinhalte : Bundeskanzleramt Österreich) Web page of the data protection council (Datenschutzrat), an advisory body of the federal government (German)
Andorra
www.apda.ad (Agència Andorrana de Protecció de Dades) – Website of the data protection authority of the Principality of Andorra (Catalan)
Argentina
https://www.argentina.gob.ar/aaip (Agencia de Acceso a la Información Pública) – Website of the Argentine data protection agency (Spanish)
Australia
Belgium
www.privacycommission.be (CBPL-CPVP) – Website of the Belgian data protection agency, the Commission de la protection de la vie privée / Commissie voor de bescherming van de persoonlijke levenssfeer (French, Dutch)
Bulgaria
www.cpdp.bg (Комисия за защита на личните данни) – Website of the Bulgarian data protection authority (Bulgarian).
Canada
Croatia
www.azop.hr (Agencija za zaštitu osobnih podataka – Home) – Website of the Croatian personal data protection agency (Croatian, English).
Cyprus
www.dataprotection.gov.cy (Γραφείο Επιτρόπου Προστασίας Δεδομένων Προσωπικού Χαρακτήρα – Αρχική Σελίδα) – Website of the office of the Cypriot commissioner for personal data protection (Greek, English).
Czech Republic
www.uoou.cz (ÚOOÚ – Hlavní stránka) – The website of the Czech office for personal data protection (Czech, English).
Denmark
www.datatilsynet.dk (Datatilsynet: Forside) – Website of the Danish data protection agency (Danish, English).
Dubai
http://dp.difc.ae (DIFC | Data Protection Law) – Website of the data protection agency of Dubai (English)
Estonia
www.aki.ee (Andmekaitse Inspektsioon: Andmekaitse Inspektsioon) – Website of the Estonian data protection agency (Estonian, Russian, English)
Finland
www.tietosuoja.fi (Tietosuojavaltuutetun toimisto – Tietosuojavaltuutetun toimisto) – Website of the Finnish data protection board (Finnish, Swedish, English)
France
www.cnil.fr (CNIL – Commission nationale de l’informatique et des libertés) – Website of the French data protection agency (French, English, Spanish).
Germany
Greece
www.dpa.gr (Αρχή) – Website of the hellenic data protection authority (Greek, English).
Hong Kong
www.pcpd.org.hk (Office of the Privacy Commissioner for Personal Data, Hong Kong) – Website of the Privacy Commissioner for Personal Data of Hong Kong (English, Chinese)
Hungary
http://abiweb.obh.hu/abi/ (ABIWEB – Az Adavédelmi Biztos honlapja) – Homepage of the Parliamentary Commissioner for Data Protection and Freedom of Information in Hungary (Hungarian, English)
Iceland
www.personuvernd.is (Persónuvernd. Þínar upplýsingar, þitt einkalíf.) – Website of the Icelandic data protection authority (Icelandic, English).
Ireland
www.dataprotection.ie (Home – Data Protection Commissioner – Ireland) – Website of the data protection commissioner of the Republic of Ireland (English, Irish).
Israel
http://ilita.justice.gov.il (ראשי – ומידע טכנולוגיה למשפט הרשות – (Website of the Israeli Law, Information and Technology Authority (ILITA), home to the Israeli data protection authority (Hebrew, English)
Italy
www.garanteprivacy.it (Garante per la protezione dei dati personali) – Website of the Italian data protection agency (Italian, English).
Japan
www.soumu.go.jp/english/index.html (Ministry of Public Management, Home Affairs, Posts and Telecommunications) – Website of the Japanese Ministry of Public Management, Home Affairs, Posts and Telecommunications (Japanese, English).
Korea
www.kisa.or.kr (한국정보보호진흥원에 오신것을 환영합니다. 음성서비스를 사용하시려면 컨트롤키와 엔터키를 누르세요) – Website of the Korea Information Security Agency (Korean, English).
Latvia
www.dvi.gov.lv/eng (Data State Inspection .|. Homepage) – Website of the Latvian data protection agency (Latvian, Russian, English, hyperlink leads to English page).
Liechtenstein
www.dss.llv.li (Home – Datenschutzstelle) – Web page of the data protection authority of the principality of Liechtenstein (German-language page only, but there is an English translation of the data protection law).
Lithuania
www.ada.lt (Valstybinė duomenų apsaugos inspekcija) – Website of the Lithuanian data protection agency (Lithuanian, English).
Luxembourg
www.cnpd.lu/de (Commission nationale pour la protection des données – Startseite) – Data protection authority of Luxembourg (German, French)
Malta
www.dataprotection.gov.mt (Welcome to Data Protection) – Website of data protection commission of the republic of Malta (English).
Former Yugoslav Republic of Macedonia
http://www.dzlp.mk/index.cfm?lng=2 (Дирекција за заштита на лични податоци) – Website of data protection commission of the former Yugoslav Republic of Macedonia (Macedonian, English).
Mexico
www.ifai.org.mx/DatosPersonales (Protección de Datos Personales) – Website of Mexican data protection authority (Spanish, parts in English).
Monaco
www.ccin.mc (CCIN – Commission de contrôle des informations nominatives – Principauté de MONACO – Site officiel) – Website of data protection commission of the Principality of Monaco (French).
New Zealand
www.privacy.org.nz (The Office of the Privacy Commissioner, New Zealand / Homepage) – Website of the New Zealand data protection agency (English)
Netherlands
www.cbpweb.nl (College bescherming persoonsgegevens) – Website of the Dutch data protection agency (Dutch, English)
Norway
www.datatilsynet.no (Forsiden – Datatilsynet – personvern og informasjonssikkerhet) – Website of the Norwegian Data Inspectorate (Norwegian, English).
Philippines
Poland
www.giodo.gov.pl (GIODO Generalny Inspektor Ochrony Danych Osobowych) – Website of the Polish Inspector General for the Protection of Personal Data (Polish, English, French)
Portugal
www.cnpd.pt (Página Principal – CNPD) – Website of the Portugese data protection agency, the Comissão Nacional de Protecção de Dados (Portugese, French, English)
Romania
www.dataprotection.ro (ANSPDCP Dataprotection Romania) – Website of the Romanian national authority for the supervision of personal data processing (Romanian, English).
Sweden
www.datainspektionen.se (Datainspektionen – Vi värnar om din personliga integritet i IT-samhället) – Website of the Swedish Data Inspection Board (Swedish, English).
Switzerland
Slovakia
www.dataprotection.gov.sk (Úrad na ochranu osobných údajov Slovenskej republiky) – Website of the Slovakian data protection authority (Slovakian, English).
Slovenia
www.ip-rs.si (IP-RS: Domov) – Website of the Slovenian information commissioner (Slovenian, English).
Spain
Thailand
www.oic.go.th/content_eng/default_eng.asp (Office of the Official Information Commission (O.I.C.)) – English part of the website of the Information Commission of Thailand (Thai, English).
United Kingdom of Great Britain and Northern Ireland
United States of America (USA)
Uruguay
www.datospersonales.gub.uy (Unidad Reguladora y de Control de Datos Personales) – Homepage of the data protection authority of Uruguay (Spanish)