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Effective Date December 2020
Upside.Digital Pty Ltd
ACN: 139 669 248
ABN: 65 139 669 248

Our Commitment to Protecting your Privacy

Upside.Digital Pty Ltd respects your privacy and is committed to protecting it.
This Privacy Policy explains how and why we collect personal information, what we use it for,
and to whom and when we disclose it. It is an important document so please take the time to
read it.

We will treat your personal information in accordance with our obligations under the Australian
Privacy Principles (APPs), the Privacy Act 1988 (Cth) and related Australia laws. We refer to
these collectively as “the Privacy Law”.

“Personal information” has a specific meaning set out in the Privacy Law, but includes any
information we hold which is about you or is reasonably identifiable as being about you.
By providing us with personal information, visiting our websites or by using our services, you
consent to the terms of this Privacy Policy.

What Type of Personal Information Do We Collect?

We only collect personal information where necessary and relevant so that we can provide you
with access to information or other services. This may include, for example, when you request
to receive further information from an advertiser.

● The extent and type of personal information collected will vary depending on how you
interact with us, but will usually include:
● data about you, your interests, and products/services you select to receive
communications about;
● contact details such as your name, address, phone number and email address;
● other information such as your year of birth, gender, family size including children and
pets, your type of mobile phone, personal income, employment situation, online
shopping habits and personal interests.

Some personal information may be collected for activities not specifically outlined in this Privacy
Policy, and where reasonable, we will make clear why we are collecting it when we do so.

How Do We Collect Your Personal Information?

We collect personal information from you in a variety of ways, including when you interact with
us electronically or in person, when you access our websites and when we provide our services
to you. We may receive personal information from third parties. If we do, we will protect it in
accordance with this Privacy Policy.

How Do We Use Your Personal Information?

We use and disclose personal information to fulfil the purpose for which it is collected or else for
related purposes. This includes, for example, providing you with information, updates and
services.

We may make you aware of new and additional products, services and opportunities available
to you. We may also use your personal information to improve our products and services and
better understand your needs.

We may contact you by a variety of measures including, but not limited to telephone, email,
SMS (text message) or mail.

We may disclose your personal information to any of our employees, officers, insurers,
professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for
the purposes set out in this Privacy Policy. Personal information is only supplied to a third party
when it is required for the delivery of our services.

We may from time to time need to disclose personal information to comply with a legal
requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal
proceeding or in response to a law enforcement agency request.

We may also use your personal information to protect the copyright, trademarks, legal rights,
property or safety of Upside.digital Pty Ltd, https://realkiwiheroes.co.nz/ and
http://UpsideDigital.com.au, our customers or third parties.

If there is a change of control in our business or a sale or transfer of business assets, we
reserve the right to transfer to the extent permissible at law our user databases, together with
any personal information and non-personal information contained in those databases. This
information may be disclosed to a potential purchaser under an agreement to maintain
confidentiality. We would seek to only disclose information in good faith and where required by
any of the above circumstances.

If we need to disclose your personal information to an overseas recipient such as an advertiser
or data warehouse who is not in Australia, we will take reasonable steps to ensure that the
recipient adheres to the Privacy Law in relation to your personal information.

We may also provide your information directly to third-party service providers for the purposes of
servicing your requests or enquiries. These providers have their own obligations under the
Privacy Law and will have their own privacy policies. Your interactions with those providers will
be governed by those separate policies, and by using our Services you are consenting to the
disclosure of your personal information on that basis.

How Do We Hold and Disclose Your Personal Information?

We hold your personal information on secure servers located in Australia and the United States.
We disclose personal information to our advertisers, customers, third party agents, directors,
employees and contractors only for a purpose that is consistent with the way we have informed
you that we will use the information in this Privacy Policy.

How Do We Keep Information Secure?

We are committed to ensuring the security of the information we hold about you. We will always
try to ensure that we take all reasonable steps to protect your information from misuse,
interference and loss, and from unauthorised access, modification or disclosure.

If we no longer need any information, we will take reasonable steps to destroy and/or de-identify
the information, unless this is required to be retained to comply with any of our legal
requirements.

We have no control over information that may be transmitted over the internet, so therefore
cannot guarantee its safety whilst in transit.

What Happens if There is a Data Breach?

If a suspected data breach occurs, we will determine the extent of the breach. A data breach
may occur if your personal information is lost or subjected to unauthorised access or disclosure.

If we believe that the suspected data breach is likely to result in serious harm to you, we will
notify you and the Office of the Australian Information Commissioner as soon as practicable and
as required by the Privacy Law. This notification will set out a description of the data breach, the
kinds of information concerned, and recommendations about the steps you should take in
response to the data breach.

What Additional Data Do We Collect via Our Websites?

When you come to our websites (e.g. https://BillySumo.com.au and http://UpsideDigital.com.au)
we may collect certain information such as browser type, operating system, website visited
immediately before coming to our site, etc.
This information is used in an aggregated manner to analyse how people use our site, such that
we can improve our service.

Our web server will also collect the following information:
● Your Internet service provider’s address;
● The number of users who visit the website;
● The date and time of each visit;
● The pages accessed;

Data collected from our websites remain the property of Upside.digital Pty Ltd.

Cookies

A cookie is a small piece of computer code which remains on your computer and contains
information which helps us identify your browser and previous information viewed in relation to
our services. When you visit our websites, the cookie records certain details including the date,
time and advertising content. None of the information in the cookie contains personally
identifiable information about you.

If you do not want us to use cookies then you can easily stop them, or be notified when they are
being used, by adopting the appropriate settings on your browser. If you do not allow cookies to
be used some or all of our websites might not be accessible to you.

By using our websites you consent to us sharing a hashed, anonymous, readable version of
your email with our partner Service Providers who will drop a cookie on your browser for the
purpose of improving the relevance of online advertising and content by third parties that are
unaffiliated with our websites.

By accessing our websites you agree that we and our partners may use cookies for marketing
and other purposes.

Third party sites

Our websites may from time to time have links to other websites not owned or controlled by us.
These links are meant for your convenience only. Links to third party websites do not constitute
sponsorship or endorsement or approval of these websites. Please be aware that we are not
responsible for the privacy practices of other such websites. We encourage our users to be
aware, when they leave our websites, to read the privacy statements of each and every website
that collects personal identifiable information.

How do you contact Us to Amend, Delete, Unsubscribe or Access Your Personal Information?
We try to ensure that all information about you that we collect, use or disclose is accurate,
complete and up-to-date.

Under the Privacy Law, you have the right to obtain access to any personal information which
we hold about you, and to advise of any inaccuracy, if it is out of date, incomplete, irrelevant or
misleading. There are some exceptions to this right set out in the Privacy Law.

If you want to correct data about you as you believe the data we hold is incorrect or you want to
request the deletion of your personal information from our database or you simply require
access to any personal information that we hold about you, then you should inform us and we
will make every reasonable efforts to provide it and, if required, correct it.

If you would like to unsubscribe at any time you may simply click the hyperlink located at the
bottom of all our branded mailings.
Any enquiries or requests should be in writing to: Privacy Officer, Upside.Digital, Level 5, 501/22
Central Avenue, Manly, NSW, 2095, Australia.

Complaints

If you wish to make a complaint or provide any comments on our Privacy Policy please contact
us on either: info@upside.digital or +61 2 9114 6715 or write to us at The Privacy Officer,
Upside.Digital Pty Ltd, Level 5, 501/22 Central Avenue, Manly, NSW, 2095, Australia.
The Privacy Officer will act upon all substantiated complaints or comments made on the privacy
policy by return mail, and or email as soon as reasonably possible.

Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this
Policy at any time, in our sole discretion and all modifications will be effective immediately upon
our posting of the modifications on our website or notice board. Please check back from time to
time to review our Privacy Policy.