We at Tech 4 Good Pty Ltd trading as pungle.com with ABN 87634472352 and ACN 63447235 (Pungle) respect your concerns about privacy and value the relationship we have with you. These Principles set forth Pungle’s requirements for complying with the Australian Privacy Principles (APPs) that went into effect on March 12, 2014.
For purposes of this Notice, “Personal Information” means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an Australian consumer, customer, supplier or other individual (excluding Pungle employees) (hereinafter “Individual”), whose identity is apparent, or can reasonably be ascertained, from the information or opinion. This Policy applies to Individuals.
I. APP 1 – Open and Transparent Management of Personal Information
Pungle has ongoing practices and policies in place to ensure that it manages personal information in an open and transparent way. This Policy is freely available on Pungle’s website. An Individual may also obtain a copy and/or complain about a breach of the APPs by contacting us as specified below.
Pungle collects certain Personal Information such as name, email address, postal address and telephone number of an Individual.
Pungle processes some Personal Information in the United States and Australia.
II. APP 2 – Anonymity and Pseudonymity
You have the right to deal with Pungle without using your true name, but in so doing you may prevent us from sharing free content with you or providing you with other services.
III. APP 3 – Collection of Solicited Personal Information
Pungle will not knowingly collect Personal Information about you unless the information is reasonably necessary for one or more of Pungle’s functions or activities. Pungle collects information on Individuals from those Individuals unless it is unreasonable or impractical to do so. In addition, we will not knowingly collect Sensitive Personal Information about you without your consent; for purposes of this Policy, Sensitive Personal Information includes:
i. racial or ethnic origin;
ii. political opinions;
iii. membership in a political association;
iv. religious beliefs or affiliations;
v. philosophical beliefs;
vi. membership in a professional or trade association;
vii. membership in a trade union;
viii. sexual preferences or practices;
ix. criminal record; or
x. health/genetic/biometic information.
IV. APP 4 – Dealing with Unsolicited Personal Information
When Pungle receives unsolicited Personal Information, it will determine whether it would have been permitted to collect the information under APP 3, above. If so APP 3 applies to that information. If the information could not have been collected under APP 3, Pungle will destroy or de-identify that information if it is lawful or reasonable to do so.
V. APP 5 – Notification of the Collection of Personal Information
At or before the time (or, if that is not practicable, as soon as practicable after) Pungle collects personal information about an Individual from the Individual, Pungle notifies the Individual about the purposes for which we collect and use Personal Information, the types of third parties to which we disclose the information, the choices Individuals have for limiting the use and disclosure of their information, and how to contact us about our practices concerning Personal Information.
VI. APP 6 – Use and Disclosure of Personal Information
Pungle will not use or disclose Personal Information for purposes other than those for which it was collected except in accordance with the “permitted general situations” under Section 16a of the APPs, in accordance with “permitted health situations” under Section 16b of the APPs, or as otherwise required or permitted by law. Pungle may use or disclose Personal Information for “secondary purposes” in accordance with Section 6 of the APPs (formerly Section 2 of the National Privacy Principles).
We use Personal Information of Individuals (i) to respond to your requests, (ii) to evaluate the quality of our products and services, (iii) to communicate with you about our products, services and related issues, (iv) to notify you of and administer offers, contests, sweepstakes and other promotions, and (v) for internal administrative and analytics purposes and to comply with our legal obligations, policies and procedures.
Through the use of the Pungle platform, some of the public information visible on your supporter page may also be displayed publicly on other parts of the Pungle platform or third party sites via the Pungle API.
VII. APP 7 – Direct Marketing
Pungle will comply with the APPs in connection with direct marketing to Individuals, obtain consents from Individuals for such marketing whenever reasonable, practical and feasible, and honor all requests to cease such marketing submitted properly through the simple means provided by Pungle for such requests. Pungle will also provide the Individual with the source from which Pungle received the Individual’s Personal Information upon request, unless it is impractical or unreasonable to do so.
By creating an account or making a donation through Pungle you are consenting to receive marketing communications from us including community-related content, event partner opportunities, cause-related information, product updates, competitions and promotional campaigns. You can opt-out from any of these campaigns using the ‘unsubscribe’ instructions provided in the communication or by contacting us at email@example.com
VIII. APP 8 – Cross-Border Disclosures
When information subject to the APPs is transferred by Pungle to the United States, it will remain subject to the protections of this Policy, in the same way as recorded information from the European Union transferred to the US is subject to the EU-U.S. Privacy Shield framework accepted by the European Union, under which Pungle self-certifies.
IX. APP 10 – Quality of Personal Information
Pungle takes reasonable steps to ensure that Personal Information collected by Pungle is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current.
X. APP 11 – Security of Personal Information
Pungle maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
XI. APP 12 – Access to Personal Information
Pungle provides Individuals with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the APPs. To obtain access to Personal Information, Individuals may contact Pungle as specified in the “How to Contact Us” section of this Policy.
XII. APP 13 – Correction of Personal Information
Pungle takes reasonable steps to ensure that Personal Information collected by Pungle is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. Individuals may correct their Personal Information whenever necessary. To correct their Personal Information, Individuals may contact Pungle as specified in the “How to Contact Us” section of this Policy.
XIII. How to Contact Us
Please address any questions or concerns regarding our practices concerning Personal Information by contacting us at firstname.lastname@example.org
The Policy may be amended from time to time in compliance with law and the APPs. Please check this Policy for updates.
This Policy was last updated and posted on 19 June 2019.