Effective date: August 23, 2018
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).
• 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
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.
Types of Data Collected
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.
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
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.
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.
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
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.
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.
We may use third-party Service Providers to monitor and analyse the use of our Service and you consent to this.
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.
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
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.
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.
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.