Privacy Policy

Effective date: August 23, 2018

About this privacy policy

This document sets out the policy of Horwood Q (ABN: 73 603 983 964) (referred to as “us”, “we”, or “our”) operating the www.horwoodq.com website relating to the collection, handling, use, privacy and disclosure of your personal information (“Privacy Policy”). It also deals with how you can complain about a breach of privacy laws, how you can access the personal information we hold about you and how to have that information corrected.
This Privacy Policy applies to all your dealings with us regarding the collection, use, and disclosure of personal data when you use the site and access the services provided on the site (Service) and the choices you have associated with that data.
You accept this Privacy Policy and expressly consent to our collection, use and disclosure of your personal information as described in this Privacy Policy by using our website, completing any application forms or conducting any other business with us.
We are committed to protecting the privacy of the personal information we collect and receive. We are bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth).

Your Consent:

We advise that you read and understand the terms of our Privacy Policy to ensure you have full confidence in our handling of your personal information. When you read, browse or download information from our website, regardless of registration, you will be deemed to have provided consent to the following:
• us using your personal information as set out in this Privacy Policy;
• the collection use, storage and processing of your personal information through your use of this website, your registration with this website and your use of the Services; and
• you agree to any changes and modifications that we may make to our Privacy Policy in the future.

If you do not agree to this Privacy Policy please do not use the site.

Information Collection And Use

We will collect your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.horwoodq.com

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and we consider reasonably necessary for our functions and activities (“Personal Data”). Personally identifiable information may include, but is not limited to:
• Name, age, and contact details (including phone number, postal address, facsimile and email)
• Identification information (e.g. passport number, drivers licence number)
• Financial Information
• Billing Information (e.g. bank account numbers, digital currency account information)
• Cookies and Usage Data (e.g. IP address, device information, operating system, web log information)

How we collect your personal information:
We collect your personal information in a variety of ways, including but not limited to: • when you visit the site; • when you register on the site; • when you fill out a form; • by electronic systems such as applications; and • in connection with other activities, Services, features or resources we make available on the site.

Unsolicited personal information

Unsolicited personal information is personal information we receive that we have taken no active steps to collect.
We may keep records of unsolicited personal information if the information is reasonably necessary for one or more of the Services. If not, it is our policy to destroy the unsolicited information or ensure that the information is de-identified provided it is lawful and reasonable to do so.

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data
Horwood Q uses the collected data for various purposes:
• To provide and maintain the Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer care and support
• To provide analysis or valuable information so that we can improve the Service
• To monitor the usage of the Service
• To detect, prevent and address technical issues
To advertise, send you offers, updates, events and information about products or services that we believe may be of interest to you. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us you wish to do so.

Transfer Of Data

Your information, including Personal Data, may be disclosed, used, transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. This may occur if: • our offices or related entities are overseas; • we outsource certain activities overseas; • transactions, information, Services or products have an overseas connection; or • our computer systems including IT services are overseas.
You consent to the collection, use, storage and processing of your personal information outside of Australia as set out in this Privacy Policy.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Horwood Q will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
We cannot guarantee that personal information will be protected against unauthorized access or misuse and we do not accept any liability for the improper actions of unauthorised third parties. We will retain your personal information for as long as necessary to fulfil our obligations to you, to protect our legal interests, to comply with an Australian law or as otherwise stated to you when we collected your information.

Disclosure Of Data
Legal Requirements

Horwood Q may disclose your Personal Data in the good faith belief that such action is necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of Horwood Q
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
We may use and disclose personal information for related purposes to third parties. Types of organisations to which we may disclose your information include:
• any of our related companies;
• financial institutions, payment processors or identity service providers;
• anyone to whom our assets or business (or any part of it) is transferred;
• individuals appointed by a government responsible for the investigation and resolution of disputes or complaints concerning your use of our services;
• where you have otherwise consented;
• as otherwise required or authorised by law;
• government bodies such as ATO, ASIC, Australian Prudential Regulatory Authority and the police or courts (as required by law);
• professional or government organisations; and
• our contracted service providers and third party service providers on the site who are bound by similar obligations of confidentiality including consultants and marketers, information technology service providers, dealers and agents and professional advisers.

Security Of Data

The security of your data is important to us, however, 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 Data, we cannot guarantee its absolute security and do not accept any liability for any breach of security.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and you consent to this.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service and you consent to this.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility and do not accept any liability for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. You acknowledge and agree it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Changes to this Privacy Policy are effective when they are posted on this page.

Resolving your Privacy Issues

If you have issues to discuss with us about how we have collected or managed your information please contact our Privacy Officer. For information about privacy or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

Our Privacy Officer

Our Privacy Officer can be contacted at:

Email: [email protected]

Accessing and updating your personal information: You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.