Privacy Policy

Your privacy is important

This privacy policy outlines how iCommand Ltd (ACN 150 827 900) (We, Us, or Our) collects, uses, and discloses personal information in relation to the use of Our website at www.101pro.com and the iCommand application operated by Us (Platform) as required by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

This privacy policy does not apply in respect of the collection, use, or disclosure of information contained in employee records held by Us where the collection, use, or disclosure is directly related to a current or former employment relationship between Us and an employee.

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The kinds of personal information

We collect and holdWe collect and hold personal information about users of Our Platform and persons whose information is uploaded onto the Platform by any person, business, company, or organization (You, Yourself, You're) who has access to, or uses, the Platform (Platform Users).

The kinds of personal information We collect and hold may include Your name, email address, residential address and other contact details, correspondence You send to Us, billing information, and information obtained when You use the Platform, including without limitation:

• Your username and password;
• Your age and gender;
• Your activities on the Platform, including information that You or other Platform Users upload, publish, post, or otherwise make available on the Platform (Post, Posting, and Posted), web pages and advertisements on the Platform that You view, hyperlinks on the Platform that You click on and search queries that You conduct on the Platform; and
• Your computer’s internet protocol address, Your mobile device’s identifier, standard server log information, and other information that We collect through the use of cookies and other similar technologies (see below).

When You use the Platform or other Platform Users use the Platform and Post information about You on the Platform, We may also collect information or an opinion about Your racial or ethnic origin, political opinions, membership of a political association, religious beliefs, or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, and health information (i.e. sensitive information).

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Manner and purpose of collection of personal information

We will generally collect personal information about You by way of collecting information You or other Platform Users Post on the Platform, forms and other documents or information provided to Us by You (including online), correspondence You provide to Us, and any discussions We have with You.

We may also collect personal information about You from third parties. For example, We may collect personal information about You from service providers, related entities, business partners, and other third parties, including, without limitation, third parties handling Platform support inquiries or providing payment processing or marketing services.

We will only collect, hold and use personal information (except sensitive information, see below) for the following purposes unless otherwise required or permitted by law or expressly approved by You:

• to enable Us to conduct and improve Our business, including monitoring and profile who is accessing and using the Platform and making information that You Post on the Platform available for viewing by other Platform Users;
• to communicate with You, provide customer support to You (including trouble-shooting), and/or seek or receive feedback from You regarding the Platform and any other services or support We provide to You from time to time;
• to carry out marketing initiatives and analysis, including without limitation by providing You with marketing materials in relation to the Platform, Our service offerings from time to time, and Our other functions and activities via any medium including mail, telephone, and email;
• to manage the payment and recovery of any amounts payable to Us by You;
• to enforce the terms of use that govern the use of the Platform and to comply with Our legal obligations including under applicable legislation and prevent illegal activities; and
• for other purposes which are reasonably necessary in connection with Our ordinary functions and activities.

We will only use sensitive information for the purposes for which it was provided or for a purpose directly related to such purpose unless You agree otherwise or the use of such sensitive information is required or authorized by law.

If We are unable to collect personal information relating to You, We may be unable to provide You with access to the Platform or otherwise continue Our relationship with You.

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Disclosure of Your Personal Information

We may disclose personal information about You to the following types of entities if required in connection with the purposes listed above:

• other Platform Users;
• Our associates and related entities and other third parties who provide Us with services in connection with Our business or the Platform generally;
• any industry body, tribunal or court, or otherwise in connection with any complaint made by You about Us; and
• any entity involved in a transfer of all or part of Our assets or businesses; and
• other entities with Your consent or as permitted or required by law.

Information You Post on the Platform will be made available to other Platform Users (including users located overseas). By using the Platform, You consent to the disclosure of Your information to other Platform Users (including those located overseas).

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How We hold personal information

We hold personal information in paper form and electronic form. We have in place steps to protect the information We hold from misuse, interference, and loss and from unauthorized access, modification, or disclosure. For example, only authorized employees and service providers are provided with access to personal information that has been provided to Us for purposes other than for Posting such information on the Platform (e.g. Your Platform account password).

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How to obtain access to Your personal information

You may obtain access to personal information which We hold about You by contacting Us using the contact details set out below. When You request copies of Your personal information held by Us, We will endeavor to provide You with such personal information as soon as reasonably practicable.

We may charge You a fee in relation to identifying and providing access to Your personal information on a per-request basis. We may require You to verify Your identity and specify what information You require before completing a request for access. There may be occasions when access to personal information We hold about You is denied. Such occasions would include where the release of the information would have an unreasonable impact on the privacy of others.

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Accuracy and completeness of personal information

While We will endeavor to ensure that the personal information collected from You is up-to-date, accurate, and complete, We will assume that any personal information provided by You is free from errors and omissions. You may request that We update or vary the personal information that We hold about You using the contact details set out below.

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Lawful basis for EU & UK residents

The General Data Protection Regulation (EU) 2016/679 (GDPR) and the United Kingdom’s Data Protection Act 2018 (UK GDPR) require a “lawful basis” to collect any personal information of people in the European Union and the United Kingdom. We collect personal information on a number of lawful bases in respect of the GDPR and the UK GDPR, including without limitation:

• legitimate interests: where We have a good and fair reason to use Your personal information, including to enable Us to provide You with access to the Platform, We do so in ways that do not hurt Your interests and rights. In accordance with this privacy policy and Our terms of use, We may, on occasion, process Your personal information to pursue Our legitimate interests in a way that might reasonably be expected as part of running Our business and the Platform provided that We do not materially impact Your rights, freedom or interests;
• consent: where relevant, if You provide Us with Your personal information voluntarily and with Your express consent;
• contractual obligations: where relevant, to fulfill Our contractual obligations to You under our terms of use and any other agreement we have with You; and
• legal compliance: where relevant, We collect and use personal information in order to comply with Our legal obligations.

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Specific rights for EU and UK residents only

If You are in the EU or the UK, then You have additional rights which apply in specific circumstances, such as:

• withdrawing Your consent for Us to process Your personal information without affecting the lawfulness of processing, provided this processing was based on Your consent before the withdrawal;
• asking Us to confirm if We are using Your personal information;
• asking Us to delete Your personal information in certain circumstances, provided it is not necessary for Us to process Your personal information for the purposes for which it was collected, where We are required by law to retain the information, or where the information is relevant to a legal dispute;
• asking Us to stop or restrict how We process Your personal information in limited circumstances only and not when We are required to process the information to carry out Our day-to-day business functions or where We have compelling legitimate grounds for processing the information; and
• asking Us about the protections that We have in place if We transfer Your personal information overseas.

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How to make a complaint about a breach of Your privacy rights

If You are of the view We have breached the Australian Privacy Principles or any related privacy code in dealing with Your personal information, You may make a complaint by writing to Us using the contact details set out below and We will endeavor to provide You with confirmation as to how We propose to deal with the complaint as soon as reasonably practicable.

If You are not satisfied with Our response to Your complaint, You may make a complaint to the Office of the Australian Information Commissioner by visiting the following website and following the relevant steps: http://www.oaic.gov.au/privacy/privacy-complaints.

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Direct marketing communications

From time to time We may use Your personal information (except sensitive information) to provide You with marketing materials in relation to the Platform, Our business, or Our service offerings from time to time. If You would not like to receive direct marketing materials from Us, You may notify Us using the contact details set out below.

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Cookies and other website-related information

A cookie is a data file that a website transfers to Your computer. This enables the website to track the pages You have visited. A cookie only contains information You supply. It cannot read data on Your computer. The Platform may use cookies. You can set Your browser to refuse cookies, however, this may mean You are unable to take full advantage of the Platform.

Our internet server may also automatically record details about any computer used to access the website (such as the IP address, domain name and browser type), the date and time of access, and details of the information downloaded. This information is used for internal statistical purposes and to improve the Platform. Any other information supplied to Us (for example if You send Us an email) is treated in accordance with this privacy policy.

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Links to external websites

The Platform may contain hyperlinks to third-party websites. This privacy policy does not apply to those websites. We suggest that You consider the privacy policies set out on any website that You access after following a link from the Platform.

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Information about others

Before Posting any personal information about another person to the Platform, or otherwise providing personal information to Us, You must obtain that person’s consent to do so. If that person is under the age of 15 years, You must obtain the consent of that person’s parent or guardian. Unless We are notified otherwise, We will assume that all information about another person that You Post on the Platform, or otherwise provide to Us, has been posted or provided to Us with that person’s consent or, where that person is under the age of 15 years, the consent of that person’s parent or guardian.

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Information about children

If We become aware that we have obtained information about a person under the age of 15 without the consent of a parent or guardian of that person, We will remove that information from the Platform and destroy all records of the information that We hold. If You believe that information about a person under the age of 15 years is available on the Platform, or that We otherwise hold such information, without the consent of a parent or guardian of that person, You can notify Us using the contact details set out below.

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Variation of policy

We reserve the right to change this privacy policy from time to time to take account of new laws and technology, changes to Our functions and activities, and to make sure it remains appropriate. The updated policy will be available on Our website.

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Contact details

Please direct all complaints, requests, and queries in relation to Your privacy to Privacy Officer, 1N 1st Street, Level 6, Phoenix, AZ 85004, privacyofficer@icommand.com