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Privacy Policy

Introduction

All organisations that collect personal or sensitive data must do so in compliance with standard Privacy Principles. This includes your consent for Loyalty Innovation Pty Ltd Australia (“make ”) use of your personal details to process and fulfil your order as well as service your account.

make is an crowd-funding platform and is committed to protecting your privacy and developing a website that gives you an enjoyable and secure online experience. In this Privacy Policy, when the words "we", "us" or "make " are used, they are references to make . In all dealings by us involving the collection, storage and use of customers' personal information, make has taken and will continue to take reasonable steps to:

  • implement practices, procedures and systems that will ensure that we comply with all relevant privacy codes; and
  • be able to deal with privacy related inquiries and complaints in a prompt manner.

Note:'Personal information' is defined as information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not, and
  • whether the information or opinion is recorded in a material form or not.

Security of your Personal Information

make has implemented security systems for protecting your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. This is done using information technology security systems, strictly monitored internal staff access controls, ongoing staff privacy training and privacy audits. make also has established procedures for identifying and reporting privacy breaches and for receiving and responding to complaints and inquiries. make has also adopted a program of periodic review of the adequacy and currency of our Privacy Policy and of the practices, procedures and systems implemented under it.

Kind of personal information make collects and holds

make collects and holds personal information such as your name, email address and computer cookies. This information is only collected for identification & communication purposes, including when you subscribe to our e-newsletter, (where name and email address only is retained). make does not retain credit card or bank account details on our platform, however these are stored on our payment gateway providers platforms in accordance with PCI compliance standards.

How personal information is collected and held

make collects and stores your personal information whenever:

  • you create a Creator or Supporter account
  • you subscribe to our newsletter
  • you pledge support to a Supporter
  • you apply for a Creator payment
  • or you send us an email

Your personal information is stored and secured using our third party data storage provider. Purposes for which make collects, holds, uses and discloses personal information make collects, holds, uses and discloses your personal information for the primary purpose of:

  • maintaining your account
  • ensuring pledged Supporter payments are deducted from you
  • ensuring owing Creators payments are paid to you
  • properly managing and fulfilling any payment issues or erros
  • receiving and resolving complaints
  • marketing activities conducted by make (specifically our e-newsletter) and
  • our professional advisers, accountants, lawyers and auditors.

Any offers sent to you by make will contain a clear and easy-to-read "opt-out" button which you can use to stop make from sending you such offers in the future.

Cookies

This website uses "cookies" to help you personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used on this website: a persistent cookie and a session cookie. A persistent cookie gets entered by your web browser into the "Cookies" folder on your computer and remains in this "Cookies" folder after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. A session cookie is held temporarily in your computer's memory and disappears after you close your browser or shut down your computer. This website may also use web "beacons" (also called "clear GIFs" or "pixel tags") in conjunction with cookies for the same reasons. Web beacons are small strings of code that are placed in a Web page. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise make pages, the cookie helps make record your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same website, information you previously provided can be retrieved, so you can easily use the make features that you customised. You can configure your internet browser (such as Microsoft Internet Explorer, Chrome, Mozilla Firefox or Safari) to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browsers instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies, if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the make websites you visit.

Accessing and seeking correction of your personal information

Members can gain access to or seek the correction of the personal information that make holds. make members have a right to make a reasonable request for access to their personal information and to request its correction. Requests to access or seek to correct your personal information can be made by email to the Privacy Officer at make@make.fund. When we receive such a request, we have the right to ask for and obtain your position title, telephone number and email address in order for you to access and correct personal information.

Pseudonyms

A person can deal with make by not identifying themselves or using a pseudonym. The circumstances under which a customer can use only a pseudonym are when submitting a support request which is not order or account related.

make's access to your information

make staff that will have access to your personal information after it is collected will be limited to make administration only. make staff authorised to access your personal information are trained in compliance with our Privacy Policy and have access only to carry out the primary purpose.

Third Party Access to your information

The following third party recipients may have access to your personal information for the primary purposes noted above:

  • payment gateway providers

Length of time Personal Information is retained

make will keep and retain your personal information for a period of 10 years, or such other period of time as is required by Law.

Changes to our Privacy Policy

make updates its Privacy Policy from time to time, as and when the Act is amended. We notify our customers of changes to our Privacy Policy by asking them to agree to the new policies when they next place an order. Alternatively, we may post a link on the website headed "Changes to our Privacy Policy" for customers to read.

Consequences for you if your personal information is not provided to us

If some or all of the personal information that we request is not provided to us, the main consequence is that we may not be able to deduct payments or make payments. Other consequences may include that we might not be able to resolve any complaint you have against make .

make may use or disclose personal information about you for the purpose of direct marketing if

  • make collected the information from you;
  • you would reasonably expect make to use or disclose the information for that purpose
  • make provides you with an option to 'opt-out' of receiving direct marketing communications from us, and
  • you have not made such an 'opt-out' request to us.

Requests by you to stop direct marketing communications

If make uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from us. make will not charge you for making or giving effect to your data and we will stop sending direct marketing communications within a reasonable period after your request is made (usually within 5 working days from receiving your request).

You may also ask us to identify the source of the personal information. make will notify you of the source, unless this is impracticable or unreasonable, which will depend on a number of factors, including:

  • the consequences for you if you are not notified of the source
  • the length of time that has elapsed since the personal information was collected by us
  • the time and cost involved.

Destroying or de-identifying personal information

make will take reasonable steps to destroy or de-identify personal information it holds if it no longer needs the information for any purpose for which it may be used or disclosed under this policy. The requirement to take reasonable steps to destroy or de-identify does not apply if personal information is contained in a Commonwealth record, or if an Australian law or a court/tribunal order requires it to be retained.

Verifying your identity

make must be satisfied that a request for personal information made by the individual concerned, or by another person who is authorised to make a request on their behalf, for example, as a legal guardian or authorised agent. It would generally be extremely difficult for make to deal with an anonymous request for personal information. However, it may be practicable to deal with a pseudonymous request, for example, where you have previously transacted under that pseudonym and can establish your identity as that individual. The steps required for make to verify your identity will depend on the circumstances. In particular, whether you are already known to or readily identifiable by make . The minimum amount of personal information needed to establish your identity will be sought. In a telephone call make may request information that can be checked against records held by us.

Refusal to give Access

Whilst every effort will be made by make to provide access in a manner that is as prompt, uncomplicated and inexpensive as possible, make may refuse to give you access to your personal information. There are a number of grounds upon which make can refuse to give you access to your personal information. These reasons may include (without limitation):

  • if make reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety
  • giving access would have an unreasonable impact on the privacy of other individuals
  • the request for access is frivolous or vexatious
  • the information relates to existing or anticipated legal proceedings between you and make , and would not be accessible by the process of discovery in those proceeding
  • giving access would reveal the intentions of make in relation to negotiations with you in such a way as to prejudice those negotiation
  • giving access would be unlawful
  • denying access is required or authorised by or under law or a court/tribunal order
  • make has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to make's functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter
  • giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
  • giving access would reveal evaluative information generated within make in connection with a commercially sensitive decision making process.

Privacy Complaints

All complaints are required by the Act to be made in writing to make and make is then allowed a reasonable time (usually 30 days) to respond to complaints. We may ask you to participate in a dispute resolution scheme (such as mediation) in order to resolve your complaint.

An individual can complain about an alleged breach by make of the APPs by sending an email to the Privacy Officer at make@make.fund setting out details of the complaint.