Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in Australia, the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

Key Terms

It would be helpful to start by explaining some key terms used in this policy: We, us, our means Archanaut Pty Ltd.

Our representative means Archanaut Privacy Officer (privacy@archanaut.com).

Our data protection officer means our officer who can be contacted at dataprotection@archanaut.com.

Personal information means any information relating to an identified or identifiable individual.

Special category personal information means personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation.

Personal Information We Collect About You

(a) We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, tax file number, driver’s license number, passport number, or other similar identifiers)

Real name, postal address, residential address, unique personal identifier, address, unique personal identifier, account name

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number,  credit card number, debit card number, or any other financial information, medical information, or health insurance information.

name, signature, address, telephone number, passport number, driver’s license or passport, insurance policy number, bank account number, credit card number, debit card number, credit card number, or any other financial information.

(b) This personal information is required to provide products or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products or services to you.

How Your Personal Information is Collected

We collect most of this personal information directly from you—in person, by telephone, text, email, our apps and via our website. However, we may also collect information:

 ●From publicly accessible sources (e.g., property records);

●Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);

●From a third party with your consent (e.g., your bank);

●From cookies on our website; and

●Via our IT systems, including:

  ○Other IT systems we may implement from time to time.

How and Why We Use Your Personal Information

 (a) Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:

●To comply with our legal and regulatory obligations;

●For the performance of our contract with you or to take steps at your request before entering into a contract;

●For our legitimate interests or those of a third party; or

●Where you have given consent.

(b) A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

(c) The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for

Our reasons

To provide products or services to you

For the performance of our contract with you or to take steps at your request before entering into a contract

To prevent and detect fraud against you or Archanaut Pty Ltd

For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you

Conducting checks to identify our customers and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator.

To comply with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

To comply with our legal and regulatory obligations

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you

Operational reasons, such as improving efficiency, training and quality control

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, such as in relation to our financial performance, customer base, product range or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price

Preventing unauthorised access and modifications to systems

For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations

Updating and enhancing customer records

For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can third party, e.g. making sure that we can

Statutory returns

To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services and those of selected third parties to:—existing and former customers;—third parties who have previously expressed an interest in our services;—third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

Credit reference checks via external credit reference agencies

For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services

External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts

For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional Communications

(a) We may use your personal information to send you updates (by email, text message, telephone or post) about our products or services, including exclusive offers, promotions or new products or services.

(b) We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for

  this consent separately and clearly.

(c) We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

(d) You have the right to opt out of receiving promotional communications at any time by:

(e) We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With

(a) We routinely share personal information with:

(b) We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.

(c) We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

(d) We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymise information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

(e) We will not share your personal information with any other third party.  

Personal Information We Sold or Disclosed for a Business Purpose

(a) In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

  1. (b) In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

We have not sold or disclosed to a third party any personal information that identifies,  relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Where Your Personal Information is Held

(a) Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

(b) Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

How Long Your Personal Information Will Be Kept

(a) We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

(b) We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

(c) When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Hosting and International Data Transfers

(a) Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to United States of America, Singapore, Japan, Germany

(b) We and our other group companies have offices and/or facilities in United States of America, Singapore, Japan, Germany. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from

  Archanaut Pty Ltd's Data Protection Officer.

(c) The hosting facilities for our website are situated in Australia, United States of America, Singapore, Japan, Germany. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Archanaut Pty Ltd's Data Protection Officer.

(d) Our Suppliers and Contractors are situated in Australia, United States of America, Singapore, Japan, Germany. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Archanaut Pty Ltd's Data Protection Officer.

(e) You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Your Rights under the GDPR

Right to Access: the right to be provided with a copy of your personal information (the right of access).

Right to Rectification: the right to require us to correct any mistakes in your personal information.

Right to be Forgotten: the right to require us to delete your personal information—in certain situations.

Right to Restriction of Processing: the right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.

Right to Data Portability: the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

Right to Object: the right to object:

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the CCPA

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

Please note that we are not required to:

Personal Information Sold or Used for a Business Purpose

 In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorisation for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://www.archanaut.com/opt-out.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Please note that we may not delete your personal information if it is necessary to:

Protection Against Discrimination

 You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

Please note that we may charge a different price or rate or provide a different level or quality of products or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Exercise Your Rights

(a) If you would like to exercise any of your rights as described in this Privacy Policy, please email us at privacy@archanaut.com. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by email, you will need to provide us with:

(b) We are not obligated to make a data access or data portability disclosure if we   cannot verify that the person making the request is the person about whom we collected information, or is someone authorised to act on such person’s behalf.

(c) Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

How to File a GDPR Complaint

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Changes to This Privacy Notice

This privacy notice was published on 05 Aug 2023 and last updated on 05 Aug 2023.

We may change this privacy notice from time to time–when we do, we will inform you via e-mail.

How to Contact Us

Please contact us or our Data Protection Officer if you have any questions about this privacy policy or the information we hold about you.

We may be contacted at info@archanaut.com. Our Data Protection Officer may be contacted at dataprotection@archanaut.com.

Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).