Privacy Policy

Background

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Boldly Pty Ltd

ABN 75 624 737 793 (Boldly, We, Our, Us, and other similar terms) takes all reasonable steps to implement processes and procedures for the responsible management of Personal Information and Data. We have implemented this Privacy Notice in accordance with the Australian Privacy Principles (APPs) and other data protection roles to be open and transparent about how We collect, hold, and use Your Personal Information, and under what circumstances We may disclose or transfer it. This Privacy Policy applies to all Personal Information collected by Boldly in the course of providing services to Our customers (You, Your, and other similar terms) regardless of its source and forms part of the terms and conditions of our various agreements with You.

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Definitions

In this Privacy Notice, unless the context or subject matter otherwise require:

• Data: Any information reduced to electronic form and stored in any of our computer systems.
• Data Breach: Any unauthorized access to, unauthorized disclosure of, or loss of, Personal Information held by Us where the access, disclosure or loss is likely to result in serious harm to any of the individuals to whom the information relates.
• Personal Information: Information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
• Sensitive Information: Information or an opinion about an individual’s: 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 that is also personal information; health information about an individual; genetic information about an individual that is not otherwise health information; or biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or biometric templates.

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Collection

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3.1 Collection of Personal Information

We collect Personal Information:

• When You interact with us online, over the phone, by email, in person or through other means of communication.
• In order to assist You with the supply of goods, the provision of services, and to provide any related assistance or for other purposes requested through such communication.

The type of Personal Information We collect includes Your name, address, telephone number, email, and any additional information You provide to Us. Where You contact Us on behalf of Your employer, the information You provide often contains information about Your employment, position, and employer’s contact details. In those circumstances, certain employment information is collected. Information will only be collected directly from You unless You authorize another person to provide the information.

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3.2 Device information and cookies

When You visit our website at https://www.boldly.com.au/, We may collect certain information about Your device, including details about Your Web browser, IP address, time zone, and some of the cookies that are installed on Your device. Additionally, as You browse, We collect information about the individual Web pages, goods, and services You view, what websites or search terms referred You, and information about how You interact with Us online.

We collect device information using the following technologies:

• Cookies: Data files placed on Your device or computer which may include an anonymous unique identifier.
• Log files: Track actions occurring on the website and collect data including Your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps.
• Web beacons, tags, and pixels: Electronic files used to record information about how You browse Websites.

Please note that We do not alter our Websites’ data collection and use practices when We see a Do Not Track signal from Your browser.

Through Our use of Google Analytics, the information generated by the cookie about Your use of the website (including Your IP address) will be transmitted to and stored by Google LLC on servers in the United States of America. Google will use this information for the purpose of evaluating Your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

You may refuse the use of cookies by selecting the appropriate settings on Your browser; however, if You do, You may not be able to use the full functionality of Our website. We do not collect Personal Information or associate the information collected via cookies, web beacons, tags, log files or pixels with other Personal Information We collect.

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Consent

By agreeing to this Privacy Notice, You give us Your consent to use Your Personal Information as set out herein. You have a right to withdraw Your consent at any time and may do so by contacting Us via the details provided below. By using our website, You consent to the processing of data about You by Google LLC in the manner described in the Google Privacy Policy and for the purposes set out above. You can opt-out of Google Analytics measurement by refusing Google Analytics cookies.

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Use

5.1 General use

We use Personal Information collected as part of Our business operations which are primarily associated with the sale of goods and the provision of services in relation to marine search and rescue activities and training. Examples of when Your information may be used include:

• Informing You about Our goods and services.
• Providing You with the goods and services requested.
• Administration needs in relation to providing You with goods and services, including managing Your account.
• Dealing with requests, enquiries, or complaints and other customer care-related activities.
• Carrying out any activity in connection with a legal, governmental, or regulatory requirement imposed on Us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

We may also use Personal Information for purposes, as would be reasonably expected by You, in connection with those activities described above. However, We will not use Your Personal Information for purposes other than as described in this Privacy Notice or other agreement We have with You unless You consent to that use or there are specific law enforcement, public health, or safety reasons.

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5.2 Direct marketing

Where You have elected to be included on our mailing list or to receive other electronic communications, We may use Your contact details to send You those communications. To opt-out of receiving marketing material, You may contact Us via the details below or select the ‘unsubscribe’ link provided in that communication.

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Accessing Your information

Upon Your request and after satisfying ourselves of Your identity, We will provide access to the Personal Information We hold about You except in certain prescribed circumstances. These include, where:

• We believe giving access would pose a serious threat to the life, health, or safety of any individual, or to public health or public safety.
• Giving You access would be unlawful.
• Granting access would have an unreasonable impact on the privacy of other individuals.
• The request for access is frivolous or vexatious.
• There are anticipated legal proceedings.

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Data integrity

We take reasonable steps to ensure the Personal Information We collect, use, and disclose is accurate, complete, and up-to-date. You have a right to access and correct incorrect Personal Information at any time and may do so by contacting Us using the details provided below. If You become aware Your information is no longer accurate, complete, or up-to-date, please contact Us.

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Sharing information

We may disclose Personal Information to:

• Our employees, a related entity, and Our professional advisors, such as Our lawyers and accountants.
• Emergency services providers to assist in the prevention of harm and risk to life.
• Law enforcement agencies to assist in the investigation and prevention of criminal activities.
• Our third-party contractors or service providers with whom We have a business association, including marketing service providers, accounting service providers, and information technology service providers including cloud application providers.

Finally, We may also share Your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful request for information We receive, or to otherwise protect Our rights. We will not disclose Your Personal Information other than in accordance with this Privacy Notice without Your consent.

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Offshore transfers

The Personal Information We collect may be transferred out of Australia and to countries, including the United States of America, where it is processed by third-party providers of cloud-based services, who assist Us to manage promotional material, email, office administration, and accounting services. Boldly relies solely on reliable service providers such as Google and Facebook. While We do not otherwise actively disclose Your Personal Information to other overseas entities, the service providers We engage may use international data centers and disaster recovery sites. Consequently, these providers may have access to Your information. Regardless of where You reside, Your right to Privacy is protected in Australia pursuant to the Privacy Act 1988 (Cth) which is administered by the Office of the Australian Information Commissioner (OAIC).

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Anonymity and use of pseudonyms

We may interact with You anonymously or through the use of pseudonyms if You have questions that are general in nature. However, You are required to provide true and accurate details when requesting the supply of goods or the provision of services. You agree to provide accurate information if so required.

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Security

We take commercially reasonable steps to protect the Personal Information We hold from misuse, loss, and unauthorized access, modification, or disclosure. We do this by:

• Maintaining and keeping our systems up to date.
• Using secure servers protected from unauthorized access, modification, or disclosure.
• Where possible using multi-factor authentication where it is available.
• Using Secure Sockets Layer (SSL) encryption to transfer data across public networks, such as the internet.
• Relying on reputable service providers.
• Limiting the collection of Your Personal Information to that which We reasonably require.

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Data retention

If We hold Personal Information about You, and We do not need that information for any purpose, We will take reasonable steps to destroy or de-identify that information, in accordance with the APPs, unless We are prevented from doing so by law. Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed. We envisage Your Personal Information will be deleted or de-identified within ten (10) years if it is no longer reasonably required for the purposes for which it was collected. You may make a request to Us in writing to remove Your Personal Information and, where permitted, We will do so in accordance with the APPs.

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Use of de-identified data

The data We collect may have analytical value to Us and other third parties. We reserve the right to process, distribute, or sell information We collect through our services. However, We will only distribute data which has been de-identified. De-identified data will not include Personal Information such as Your name, address, phone number, email address, or other information which would reasonably allow You to be identified.

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Complaints procedure

Boldly is a customer service-oriented business. Therefore, if You have a complaint about Our collection or use of Personal Information pertaining to You, then We would ask You to contact Us. Our Privacy Officer can be contacted via the information provided below. If after investigating Your complaint and reporting to You our findings, You are still not satisfied, then You may contact the OAIC at the below address:

The Office of the Australian Information Commissioner
GPO Box 5218
Sydney, NSW 2001
Australia
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au

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Contacting Us

For more information about our privacy practices, if You have questions, or if You would like to make a complaint, please contact Us using the details provided below:

Privacy Officer
Boldly
52 Prospect Street
Fortitude Valley, QLD 4006
Australia
Telephone: +61 7 3085 7595
Email: hello@boldly.com.au

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Amendments

We are obligated to regularly review and update this Privacy Notice. As such, We may update it from time to time in order to reflect changes to our practices or for other operational, legal, or regulatory reasons. This notice was last updated on 17 November 2023.