PRIVACY POLICY

This Privacy Policy explains how Three-brains (ABN 39 638 563 867) collects and manages your personal information.

OUR PRIVACY COMMITMENT

We recognise the importance of, and are committed to, managing any personal information that we collect in compliance with all applicable laws. This includes the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (set out in Schedule 1 of the Privacy Act). We care about how your personal information is used and we acknowledge the importance of protecting your privacy.

How we collect personal information and why

We collect personal information for our business and activities. 

We collect personal information when dealing with consumers and our business contacts. Consumer information is collected when consumers contact us, participate in promotions and competitions or engage in our product and service offers.

The personal information we collect may include your name, date of birth, address and contact details, information relevant for promotions and competitions, and a record of any queries you have made. On our Digital Platforms, it can also include information to support the processing and delivery of product and/or service orders; access information, such as IP address and the usage of our Digital Platforms, including the content you access and any services you utilise.

You are not required to provide any personal information to us, but if you do not, we may not be able to deal with your query.

We use this personal information for our business and activities, and in our efforts to improve and grow our business. Examples include:

  • to confirm your identity;
  • to provide services and products to you, including dealing with any query or complaints;
  • to administer and manage promotions and competitions;
  • to promote and market directly to you products and services that we consider may be of interest to you, unless you tell us not to do so;
  • to evaluate our products and services and conduct consumer research;
  • for a business or professional relationship we may have with you;
  • to amend records to delete personal information.

SOURCES OF INFORMATION

Depending on your contact with us, we may collect your personal information in different ways. Examples include:

  • directly from you when you contact us;
  • from information you provide to us or our agents and contractors in connection with a promotion or competition;
  • from our customers if you contact our customer and they refer your inquiry to us;
  • from third parties if it is not reasonable or practicable to collect the information from you;
  • from other people and organisations who might be representing you or assisting or representing us.
  • you interact with us on our Digital Platforms, including when you register for an account on the Digital Platform, or send or post queries or comments;
  • you place an order, or request certain products, samples or services from us;

OUR WEBSITES, SOCIAL MEDIA, APPS AND ADVERTISING

Like many companies, we use technology and tools that tell us when a computer or device has accessed our digital platforms.

We notify you when we might or will collect personal information such as through entering a promotion or competition.

If we use your personal information to contact you and you would prefer not, please let us know and we will do our best to respect your preference.

When we send a marketing offer directly to you, we provide a way for you to opt out.

AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you interact with our Digital Platforms, we may use automatic data collection technologies via a third party to collect certain information about your equipment, browsing actions, and patterns. Some of this information may be linked to you personally. This information helps our Digital Platforms function correctly, helps us understand the needs of our users and may be used for the other purposes set out in this Privacy Policy. Examples of this information include:

  • Digital Platform related traffic data, location data, logs and other communication data;
  • data related to your use of the Digital Platforms.  This includes the pages you visit, the resources and services that you access; the time you spend on each page, the date and time of your visit, referring pages (pages you came from or go to) and statistical and other aggregated data derived from your use of the Digital Platforms;
  • information about your device, computer and network connection, including your IP address, operating system, hardware version and browser type; and

The technologies we use for this automatic data collection may include log files, usage monitoring software and cookies. Cookies are small pieces of information that are stored on a user’s device that can identify the device you are working from. The cookie file gives us details such as your IP address, platform, browser and domain (whether you are accessing the Digital Platform from Australia or elsewhere). It has a unique ID assigned to your device and enables the Digital Platform to remember your actions and preferences (such as location, language, font size and other display preferences) over a period of time.

We may also use cookies to measure traffic patterns, to determine which areas of our websites have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services.  

If you disable cookies it may limit your access to some of the Digital Platforms’ content and features. You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. You do not need to have cookies turned on to use our Digital Platforms, but your experience may be affected.

Some of our Digital Platforms use Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

OTHER TRACKING TECHNOLOGIES

We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, and better understand the visitors to our Digital Platforms, we may collect certain information via our Digital Platforms through our advertising service providers. We or our vendors use several common online tracking tools to collect information about our users, such as browser cookies, web beacons, and other similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Digital Platforms, search engine referrals, browsing activities over time and across other websites following your visit to one of our Digital Platforms or applications, and responses to advertisements and promotions on the websites and applications where we advertise.

SOCIAL MEDIA AND APIs

Our Digital Platforms may include social media features such as the Facebook like button, Twitter Tweet widgets, share buttons or interactive programs that run on our site. These features may collect your IP address, which pages you visit on our site, and how long for. If you’re a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other personal information. Social media features and widgets are either hosted by a third party or hosted directly on our Digital Platform. Your interactions with these features are governed by the privacy notice of the third party providing it and to the maximum extent permitted by law we accept no responsibility for the actions of those third parties.

We may provide an application programming interface (API) to enable third party applications to interface with our Digital Platforms. Some applications enable you to interact with us through the API in a way that requires you to log in. To do this, most of these applications will direct you through a process where you are able to let the application connect to your account.

If you allow an application to connect to your account on our Digital Platforms, including if you set up your account on our Digital Platform using an API with a third party social media platform, that application will be able to access information that you can see when you are logged in to our Digital Platforms. You should only allow applications you trust to access your account on our Digital Platforms.

If you set up your account on our Digital Platforms using an API with a third party social media platform, you also consent to us obtaining and using your information from such platforms. 

AMAZON ASSOCIATES PROGRAM

Three-brains.com is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.com.au

STORAGE AND DISCLOSURE OF PERSONAL INFORMATION

We use various systems and services to safeguard the personal information we store, as part of our business systems and processes.

These systems and services may be located both in and outside Australia.

Your personal information may be held and processed overseas by our related companies or our service providers.

When we pass on personal information to others or outside Australia, we take steps to ensure it is treated in the same way that we would treat it.

We delete or amend personal information that is no longer needed.

We also share with others and disclose information from which personal information has been removed so that no privacy is affected.

We sometimes have to pass on personal information for legal or safety reasons or other special circumstances.

ACCESSING AND CORRECTING YOUR INFORMATION

You can ask for access to personal information we hold about you at any time, by contacting us at hello@three-brains.com. We will respond as soon as we reasonably can, including if we are unable to provide you with access (such as when we no longer hold or use the information).

We do not impose any charge for a request for access, but we may charge you a reasonable fee for our costs associated with providing you with access and retrieval costs.

You should also contact us in the same way if you believe that any of the personal information we hold about you is out-of-date, incomplete or inaccurate and you wish to update or correct it, have it deleted, or to report any misuse of your personal information.

For complaints about privacy, we will establish in consultation with you a reasonable process, including time frames, for seeking to resolve your complaint.

HOW TO MAKE A COMPLAINT

If you wish to make a complaint about the way in which we handle your personal information, please contact us using the ‘Contact Details’ set out below.  We will acknowledge and investigate any complaint promptly and will respond to written complaints within a reasonable time from the date of receipt.

If you are dissatisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner for guidance on alternative courses of action that may be available (see https://www.oaic.gov.au/).

CHANGES TO THIS POLICY

We may modify this Privacy Policy from time to time to reflect changes in the law and/or our business needs.  When we make changes to this Privacy Policy, we will amend the revision date at the bottom of this page, and such modified or amended Privacy Policy shall be effective as to you and your personal information as of that revision date.  We encourage you to periodically review this Privacy Policy.

HOW TO CONTACT US

If you have any questions about three-brains and privacy, please contact us at hello@three-brains.com. We’ll be happy to answer your questions or hear your concerns.

Last updated: April 2020