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Streamtime Australia Pty Ltd ABN 52 654 231 777 and Streamtime Software Limited (Registration Number 06507751) (together, Streamtime) is committed to protecting your privacy and your security in accordance with applicable privacy and data protection laws, such as the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act), the General Data Protection Regulation (EU) 2016/679 (EU GDPR), the UK General Data Protection Regulation and the Data Protection Act 2018 (UK) (UK GDPR).
For the purposes of the EU GDPR and UK GDPR, Streamtime Australia Pty Ltd is the “data controller” in respect of your personal information.
We want to be as transparent as possible and never want to hide anything from those individuals who trust us with their important information. We take protecting your privacy very seriously.
We strongly encourage you to read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about Streamtime’s handling of your personal information, please contact us using the relevant contact details set out in section 17.
This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. It sets outs how we collect, store, process, use and disclose personal information.
In this Privacy Policy, "we", "us" and “our” refer to Streamtime, and "you" and “your” refers to any individual we collect personal information about. References to “personal information” includes “personal data” as that term is defined under the EU GDPR and the UK GDPR.
This Privacy Policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through streamtime.net and app.streamtime.net (together, our Websites), Streamtime Classic, our Streamtime iOS app, our social media channel pages which we control, or any email or other messages that we may send to or receive from you (together with any and all future online and offline service offerings operated by or on behalf of us, our Services).
Other privacy terms and conditions may apply to you, such as:
When collecting personal information, we do so to ensure we’re providing you with the best service possible. The type of personal information that we collect or request from you, and how we collect or request this personal information will depend on who you are and how we are interacting with you.
Information you provide to us
We collect personal information when you input it into our Services or otherwise provide it directly to us. We may ask you to provide some or all of the following types of information:
Information we collect automatically when you use our Websites
We automatically collect certain information when you navigate and use our Websites, otherwise known as usage data. This includes information that your browser or device sends whenever you visit our Websites, which may include:
Information we receive from other sources
We may receive information about you from other sources, including through third party services and organisations, to supplement information provided by you. This includes:
What happens if you don’t provide your personal information?
You can always decline to give us any personal information we request, but that may mean we cannot provide you with some or all of the Services you have requested or we may not be able to do business with you effectively or meet the expectations of customers. If you have any concerns about the personal information we have requested, please let us know.
Streamtime collects personal information that is reasonably necessary to carry out our business, to assess and manage our customers' needs, provide our Services to you, and comply with our legal and contractual obligations. We may also collect information to fulfil administrative functions associated with our products and services, for example billing, entering into contracts with you and/or third parties and managing customer and other business relationships.
The purposes for which Streamtime usually collects and uses personal information depends on the nature of your interaction with us, but may include:
We have a legitimate interest in using your information in the ways listed above. It is also fundamental to the nature of the products and services we provide. In some cases, it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s, statutory or public functions or because the law permits or requires us to.
Streamtime generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
For personal information which is subject to the UK GDPR or the EU GDPR, we must have a legal basis to process your personal information. We rely on the following legal bases to process your personal information:
Where we process special category personal information (as defined in the UK GDPR and the EU GDPR), we will also ensure we are permitted to do so under the UK GDPR and/or the EU GDPR, e.g.:
Generally, you control the amount and type of information you provide to us when using our Websites. You may visit our Websites without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy.
When you use our Websites, we may automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information may not necessarily be personal information.
Our Websites use “cookies” to identify the areas of our Websites that you have visited. A “cookie” is a small piece of data stored on your computer or mobile device by your web browser, which assists in managing customised settings of the Website and delivering content to personalise your browsing experience. You can use the settings in your browser to disable the use of cookies.
Google use cookies to serve ads on third party websites (including Google) based on someone’s past visits to our Website. Any data collected will be used in accordance with our own Privacy Policy and Google’s privacy policy. You can opt out of Google’s use of cookies by visiting Google’s Ad Settings.
We use third party products and services (such as third party tracking tools) to improve the performance and features of our Websites. These third party products and services are designed to collect information about your use of the Websites, but you are not identifiable from the information. We may use third party products and services including: Intercom (in-app customer support & email marketing analytics), Fullstory (user analytics), Mixpanel (website analytics), and Google AdWords (remarketing).
In particular:
If you wish to opt out of any data collection, you can install browser analytics blocker plug-ins (eg. Ghostery). You can also opt out of Fullstory by navigating here.
As set out at Section 3, we automatically receive usage data when you navigate and use our Websites. Please see Section 3 for further information on the type of usage data we collect. Please see Section 4 for how we use your information, including usage data.
Our Websites may contain links to third-party websites. You should make your own enquiries as to the privacy policies of these parties. Streamtime is not responsible for the content or privacy practices of websites that are linked to our Website.
Most of the time, we will need your real name as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. For example, this includes when providing you with access to our Services. This means that if we do not collect your personal information, we may not be able to provide you with the products and/or services you have asked for.
In some circumstances however, Streamtime will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable. This includes, for example, when you make a general enquiry via our Websites.
Security of personal information
We are committed to protecting your personal information, and ensuring that we securely store any personal information we collect (and in accordance with applicable privacy laws).
We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.
The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We implement a variety of security measures to maintain the safety of your personal information, including:
If you are a Streamtime Classic customer, your system is FileMaker based (the FileMaker privacy policy can be found here) and you are responsible for managing your own FileMaker Server.
If Streamtime agrees to provide hosting services to you in connection with the use of Streamtime Classic then that Service is as per section 9 of our Terms. These server providers have their own privacy policies: Blue Pineapple (Amsterdam), Servers Australia (Melbourne), Amazon Web Services & Servers Australia (Sydney), Nimbus Hosting (London), Productive Computing (New York).
Storage of personal information
We store electronic records in secure databases, using trusted third party storage providers. We store your personal information in the United States of America and Australia. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores).
Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Data retention
We will only keep the personal information we collect about you for as long as is necessary for the purposes set out in this Privacy Policy (see above section 4 above) or as required to comply with legal obligations to which we are subject.
We will not keep your personal information for longer than necessary. Different retention periods apply to different types of personal information. To determine the appropriate retention period for personal data, we consider, for example:
We take steps to destroy or de-identify information that we no longer require or as required by applicable law.
We may share personal information with third parties:
In particular, we may share personal information in the following situations set out below.
To other Service users
When you use our Services, we disclose certain information about you to other Service users.
To contractors and other service providers (including integrated services)
We may disclose information to third parties we engage in order to provide our Services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
For administration and management
We will also disclose personal information for a range of administrative, management and operational purposes. This includes:
With our affiliates
We may share your personal information with our affiliates, in which case, we will require those affiliates to comply with this Privacy Policy.
For business sale or corporate transaction
We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us).
With your consent
We may share your personal information for any other purpose with your consent.
With law enforcement agencies
We may share your personal information with regulatory bodies and law enforcement bodies to comply with our legislative or regulatory obligations (such as to assist with police investigations).
Where required to do so by applicable law
Under certain circumstances, we may be required to disclose your personal information if required to do so by applicable law or in response to valid requests by public authorities (e.g. a court or a government agency).
For other uses and disclosures
We may share your personal information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy.
We have a legitimate interest in processing your personal information for promotional purposes and we may use or disclose your personal information for the purpose of informing you about our Services, upcoming promotions, or other opportunities that may interest you or as otherwise permitted under applicable privacy and spam laws.
This means under certain privacy or spam laws we do not usually need your consent to send you marketing communications. For example, under the EU GDPR and the UK GDPR, where we have a legitimate interest in using your personal information for marketing purposes, we do not need your consent to send you such communications. However, where consent is required under applicable privacy and spam laws, we will ask for this consent separately and clearly.
If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below or using the opt-out functionality contained in the electronic message. If you opt-out of receiving marketing material from us, we may still contact you in relation to its ongoing relationship with you.
We collect personal information in Australia and any country in which users of our Service are located. As Streamtime operates internationally, it is likely that we will share your Personal Information with overseas recipients located in the UK, Europe and the United States. These recipients include our Service Providers who may handle, process or store your Personal Information on our behalf.
We will only disclose your personal information outside the jurisdiction in which it was collected where we are permitted to do so under applicable privacy laws. Generally, this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.
Disclosures outside of the EEA / UK
Where we transfer your personal information outside of the European Economic Area (EEA) or the UK, we only do so if we are satisfied the transfer complies with the EU GDPR and/or the UK GDPR (as applicable) by ensuring that appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for you.
If there is no adequacy decision, we may transfer your personal information to another country using legally-approved transfer mechanisms, such as the standard contractual clauses, to deliver the Service to you or otherwise perform our functions. It is sometimes necessary for us to share your personal information outside the UK/EEA, e.g.:
Under the EU GDPR and/or UK GDPR, we can only transfer your personal information to a country or international organisation outside the EEA/UK where:
These are explained below.
Adequacy decision
We may transfer your personal information to certain countries, on the basis of an adequacy decision. These include: Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Republic of Korea, Switzerland, United States (commercial organisations participating in the EU-US Data Privacy Framework) and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal information to another country or international organisation if we are satisfied the transfer complies with applicable data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal information to a third country or international organisation where an exception applies under relevant data protection law, such as:
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal information on this ground.
You are entitled to access your personal information held by us on request. To request access to your personal information, please contact us using the contact details at Section 17 below.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
If the EU GDPR and/or UK GDPR applies to you, you have the following additional and specific rights in relation to your personal information (where applicable):
To make a request to exercise any of these rights (where applicable) in relation to your personal information, please contact us using the contact details at Section 17 below.
You may contact us at any time using the contact details at Section 17 below if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
You may make a privacy complaint about the way Streamtime handles your personal information using the contact details at Section 17 below.
Streamtime will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally acknowledge the receipt of your complaint within a week.
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website: www.oaic.gov.au.
If you are located in the European Union, you may wish to take your complaint up with the local European Data Protection Authority. A list of the local authorities can be found on the European Data Protection Board’s website: https://edpb.europa.eu/about-edpb/about-edpb/members_en data protection.
If you are located in the UK, you may wish to take your complaint up with the Information Commissioner’s Office by telephone 0303 123 1113 or by using the contact details on the website: https://ico.org.uk/.
We may amend this Privacy Policy from time to time, with or without notice to you. However, where we make a material change to the Privacy Policy, we will provide notice to you (including by updating our Websites, notifying you via the Services and, where appropriate, notifying you directly via email), prior to the change becoming effective. We recommend that you visit our Websites regularly to keep up to date with any changes.
You can contact us using the help link in the app or on the ‘contact us’ link on our Websites. Alternatively, you can contact us using the following details:
help@streamtime.net
Streamtime Australia Pty Ltd
Level 18, 383 Kent Street, Sydney
NSW 2000
Australia
