Kids Connecting Parents Privacy Policy

1 Introduction

1. Kids Connecting Parents Pty Ltd (ACN 664 219 416) is referred to in these Terms and Conditions as KCP or “we”, “us”, “our” and similar.
2. We provide access to downloadable software called the KIDS CONNECTING PARENTS application for social networking between parents and carers who have lost a child, and associated software support services (Goods and Services).
3. The website at the domain name https://www.kidsconnectingparents.com (Website) is owned and operated by us.

2 Privacy

1. By accessing or using our Website, or any KIDS CONNECTING PARENTS social media site; purchasing and/or downloading, creating an account for and/or accessing and/or subscribing to any KIDS CONNECTING PARENTS application; providing us with any material or information, via the Website, KIDS CONNECTING PARENTS social media site or KIDS CONNECTING PARENTS application, or via email, telephone or otherwise; completing any questionnaire, emailing or telephoning us, contacting us via LinkedIn or otherwise communicating with us or engaging us to provide any services, you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this privacy policy.
2. The personal information we collect may include your name, email address, and other contact details and information for identification purposes. If you pay for any Goods or Services by credit card, debit card, electronic transfer or direct debit from your bank account we will collect your card or bank account details. Importantly, we will collect and share your geolocation data with other users of the app. You consent to this. You may be able to nominate whether this data is shared only while you are using the app or at all times. It is your responsibility to ensure that the app settings align with your preferences.
3. To the extent practicable and reasonable, you may deal with us on an anonymous basis or through the use of a pseudonym. However, if you engage us to provide any paid Goods or Services, it will not be practicable to correspond with you in this manner and your personal information will be required.
4. We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.
5. We undertake to take due care with all information we collect. However in providing us with such information you accept that we are not liable for its misuse due to error in transmission or any viruses, trojans, worms, logic bombs or other malware or material which is malicious or technologically harmful.
6. We will manage your personal information in compliance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) and the GDPR (where GDPR means the European Union General Data Protection Regulation, more specifically Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC), where applicable.

2.2 When do we collect information?

1. We do not automatically collect personal information from you, such as your name, address, phone number, email address or other personally identifiable information about you (personal information).
2. We collect four categories of information:
   1. Your approximate geolocation data;
   2. the personal information you voluntarily provide with your informed consent;
   3. personal information about you from other sources, such as a complaint made about you from a fellow user; and
   4. “cookie” based information that makes your use of our Website easier by recording your preferences so that when you return to our Website the “cookie” re-loads that information into your web browser.

2.3 Why do we use “cookies” and other tracking technologies?

1. General information about visits to our Website is collected by our computer servers through “cookies” (small files containing a unique identification (ID) number that our Website transfers to your computer’s hard drive through your Web browser to be stored in the cache of your computer) and other tracking technologies.
2. The “cookies” that are shared with your computer can’t be used to discover any personal information such as your name, address or email address. The anonymous non-personal information that we collect and analyse via “cookies” and other tracking technologies is not personal information as described in the Privacy Act.
3. We collect information using “cookies” and other tracking technologies for the following reasons:
   1. to help us monitor the performance of our Website so that we can improve the operation of the Website, any KIDS CONNECTING PARENTS social media site and/or the KIDS CONNECTING PARENTS application, and the Goods and Services we provide;
   2. to recognise your computer or other device when you next visit our Website, any KIDS CONNECTING PARENTS social media site and/or the KIDS CONNECTING PARENTS application, or otherwise utilize our Goods and Services, to provide a personalized and more rewarding experience;
   3. to log the internet protocol address (IP address) of visitors to our Website, any KIDS CONNECTING PARENTS social media site and/or the KIDS CONNECTING PARENTS application, so that we can work out the geographic locations of the computers or devices; and
   4. to improve marketing and advertising of the KIDS CONNECTING PARENTS application, our company, and our Goods and Services.
4. If you are unhappy about having “cookies” sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, our Website or some of our services may not function properly.

2.4 How do we store your information?

1. We use different technologies and procedures to help protect personal information from unauthorised access, loss, alternation, disclosure or use. Some of the safeguards we use are physical access controls, anti-virus software and access authorisation controls to where your personal information is held. Our commitment to data security means:
   1. we have procedures to limit access to personal information within our organisation;
   2. we use security measures and technologies within our organisation to protect your personal information; and
   3. we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where personal information is being transferred.
2. All Customer Data collected in connection with the KIDS CONNECTING PARENTS application is primarily stored in Australia via an Australian cloud provider with infrastructure based in Australia. However, certain services, such as authentication and analytics, may involve processing through Google’s global infrastructure, which could result in data being temporarily stored or processed outside of Australia, including in the United States or other locations. Additionally, while the KIDS CONNECTING PARENTS application itself is hosted in Australia, the Website and any KIDS CONNECTING PARENTS social media sites may be hosted outside of Australia. As a result, data associated with the Website and social media interactions may be transferred to and stored by foreign hosting service providers, including but not limited to those in the United States. You acknowledge and accept that we may transfer any and all Customer Data (including all personal information) overseas to the United States of America or elsewhere as the case may be.
3. By submitting your personal information to us, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. We will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy. However, by providing your consent, under the Privacy Act 1988 (Cth), we are not required to take all steps as may be reasonable in the circumstances.

2.5 How long do we keep your personal information?

Your Customer Data is stored in a cloud database, that is continuously updated. Thus, any Customer Data that you enter into the database whilst connected to the Internet, should be retrievable from the cloud in the event of any loss of Customer Data from your local device. Data limit per customer is 1GB, and your account data will be automatically deleted after a period of 3 years of inactivity. You may elect to delete your Account and any Customer Data at any time if you wish, by clicking the delete button inside the KIDS CONNECTING PARENTS application. This will immediately delete your Account and all of your Customer Data, including from the cloud, and we will no longer store or have any record of it.

2.6 What use do we make of your personal information?

1. Provision of Goods and Services:
   1. Communicating with you;
   2. Allowing you to communicate with others via the KIDS CONNECTING PARENTS application;
   3. Receiving and processing payments.
2. After-sale services:
   1. Refunds or re-performance of work;
   2. Customer service functions, including complaints and warranty claims; and
   3. Sending off-risk correspondence.
3. Marketing and consumer analytics:
   1. Providing you with information regarding goods and services or events that may be of interest to you;
   2. Improving our Goods and Services (including contacting you about those improvements and asking you to participate in surveys and reviews about our products and services); and
   3. Marketing and promotional activities by us (including by targeted Meta and Google ads and direct marketing by email, SMS and MMS messages).
4. Events, competitions and promotions, and social media:
   1. Drawing and contacting winners;
   2. Adding entrants to marketing database;
   3. Responding to social media messages; and
   4. Fulfilling social media platform rules.
5. General administrative and security use:
   1. Protecting the Website, KIDS CONNECTING PARENTS social media sites, and KIDS CONNECTING PARENTS application from security threats, fraud, or other criminal activities;
   2. Administration and management of KCP;
   3. Maintenance and development of our Goods and Services, business systems and infrastructure; and
   4. Customer service and quality assurance.
6. Background checks for employment applications with us:
   1. Assessing candidate suitability for role;
   2. Verification of candidate identity and age;
   3. Conducting:
      • bankruptcy and directorship searches and company checks;
      • Social media activity background checks including publicly available information including Facebook, Twitter, Instagram, and YouTube; and
      • Criminal history background checks;
   4. Confirmation of eligibility to work in Australia;
   5. Confirmation of education and qualifications;
   6. Confirmation of previous employment; and
   7. Consideration regarding medical leave.
7. Administration and performance monitoring of employees, whether or not the employment or contractor relationship is prospective, current or past:
   1. Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be);
   2. Facilitating any purchase of any products or services and associated staff discounts; and
   3. Monitoring systems, performance and time, and internet usage.
8. Creation of de-identified data, which can then be used for marketing, promotion and research.

2.7 To whom will we disclose your personal information?

1. Your geolocation data to other users of the KIDS CONNECTING PARENTS application.
2. Agents and subcontractors engaged by us to assist in the provision of our Goods and Services to you.
3. Our third party partners, including advertising agencies, digital advertising networks (for example Google and Facebook).
4. Service providers (including IT service providers).
5. Third parties connected with the sales and after sales process including, payment platform providers, financial institutions, credit service providers, credit reporting bodies, and any third party providers who provide us with ecommerce services, or who assist us in providing our products and services to you.
6. Third parties connected with the marketing process, including messaging service providers, marketing list providers or third parties who assist us in providing our products and services to you.
9. Any other person when we believe release is appropriate to comply with the law, enforce our subscription agreements, these Terms and Conditions, or protect ours or others’ rights, property, or safety.

2.8 Direct Marketing

1. You give your express and informed consent to us using your personal information to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications). In addition, we may send you occasional company news and information about other products and services or special promotional offers of our affiliated companies. If at any time you would like to stop receiving future commercial messages from us, you may do so by using the “unsubscribe” facility included in the Direct Marketing Communication.

2.9 The Notifiable Data Breaches Scheme

1. In accordance with the NDB scheme, we will notify you and the Office of the Australian Information Commissioner (OAIC) about any ‘eligible data breaches’ that affect you. An eligible data breach occurs when the following criteria are met:
   1. There is unauthorised access to or disclosure of personal information held by an entity (or information is lost in circumstances where unauthorised access or disclosure is likely to occur).
   2. This is likely to result in serious harm to any of the individuals to whom the information relates.
   3. The entity has been unable to prevent the likely risk of serious harm with remedial action.
2. If it is not clear if a suspected data breach meets these criteria, we will conduct an investigation to determine whether the breach is an ‘eligible data breach’ that triggers notification obligations.

2.10 How can you access the personal information that we collect?

1. We are happy to provide you with details of personal information held about you.
2. To access this information, you need to email us at admin@kidsconnectingparents.com.
3. If you are concerned that any personal information held about you is inaccurate, out of date, incomplete, irrelevant or misleading you need to email us at admin@kidsconnectingparents.com and we will take reasonable steps to correct the personal information held about you.
4. If you believe that your personal information has been misused, you need to email us at admin@kidsconnectingparents.com and we will attempt to resolve your complaint. If you are not satisfied with the outcome of your complaint you may refer the matter to the Office of the Australian Information Commissioner (OAIC). Telephone: 1300 363 992. Email: enquiries@oaic.gov.au. OAIC complaints page: http://www.oaic.gov.au/privacy/privacy-complaints