Privacy Policy
About this policy
smrtr is committed to safeguarding your privacy in accordance with the Australian Privacy Act 1988 (Cth). As a provider of data products and services, we want to assure you that we take privacy seriously.
This Privacy Policy encapsulates our dedication to compliance with the Australian Privacy Principles (APPs), which govern the entire lifecycle of personal information – from collection and use to disclosure, security, accessibility, and disposal. You can explore these principles further on the Office of the Australian Information Commissioner’s website (https://www.oaic.gov.au/privacy/australian-privacy-principles).
This Privacy Policy applies regardless of where you are located.
Overview
smrtr is a provider of data products and services, some of which include personal information data. Due to the volumes of data required, collection directly from individuals is impracticable, therefore we license privacy-compliant data about you collected by trusted third-party providers. We also collect information about you if you provide it directly to us, for example, via our website.
Our clients may use the data we provide to them for marketing purposes or to enhance their customer databases. One of our key business offerings involves creating lists (audiences) for clients’ direct marketing campaigns to ensure that the marketing materials you receive are relevant to you. Your information will only be used for direct marketing purposes if you’ve explicitly consented to such use.
Your information may also be used to generate actionable insights and reports to help our clients make informed business decisions.
Occasionally, we may sell data to other providers offering similar products to ours. We will not directly market to you.
We strive to maintain accurate and current information about you. If you want to access or correct your information or wish to opt-out of having your information shared with our clients you can do so by following the steps provided below.
Your privacy matters to us, and we’re here to address any concerns you may have.
Personal Information We Collect
At smrtr, we only obtain personal information that is necessary for our data products and services. This collection depends on circumstances, but typically includes:
- Name
- Address
- Telephone number
- Email address
- Mobile device ID
- Age
- Gender
- Geographical location
- Derived information such as interests and opinions
Website Information
When you visit smrtr.com.au, we and our technology partners may collect:
- Information provided through our Contact Us or Opt-Out forms
- Website analytics, covering page access, device details, and geographic location
Apart from statistical and website interaction data, we don’t collect information unless you voluntarily provide it.
Additional Information Collection
In conducting our general business operations, we may collect:
- Employee contact details
- Job applicants’ information, including resumes and background checks
- Business contacts’ details and communication records
We use our best efforts not to collect personal information about individuals under 18 years old or sensitive information, as defined in the Privacy Act. Exceptions exist for job applications where sensitive information may be necessary with your explicit consent, for example, criminal background checks.
How We Collect Information
We obtain personal information from third parties, employing reasonable efforts to ensure it has been collected with your consent. Data analytics and statistical methods also help us deduce information about you. We may also collect information from you that you provide directly to us, through website interactions, emails, business dealings and if you apply to work for us.
Use and Disclosure
smrtr uses your personal information for the purpose for which it was collected. These activities include:
- To provide our products and services
- To respond to enquiries from you
- To respond to complaints
- To determine whether to hire you to work with us
- To improve our website, our products and our customer service
- For general business communication purposes if you are a client, supplier, prospect or business associate
- As otherwise required or authorised by law
In relation to our products and services, if we are legally entitled to do so, we may provide your information to our clients or the agents or representatives of our clients. These include advertising agencies and mail houses.
Securing Your Information
Ensuring the security of your information is paramount. To protect your personal information from misuse, loss, unauthorised access, modification or disclosure, we employ industry best practices. These include endpoint-secured servers, multi-factor authentication, encryption and strict access controls. Obtaining ISO27001 certification underscores our commitment to information security.
We take reasonable steps to ensure that our data assets are only stored on Australian-located servers, however, the service providers we engage may use international data centres and disaster recovery sites.
While we cannot guarantee absolute security, we will promptly notify you and the relevant authorities as required by law of any data security breaches involving your personal information which are “eligible data breaches” in accordance with the Privacy Act.
Opting Out
If you do not wish us to provide your information to our clients or to anyone else, please let us know and we’ll take all reasonable steps to action your request at the earliest possible opportunity. You can opt-out here:
smrtr.com.au/opt-out-form
We keep a record of requests in our suppression database which enables us to ensure you are not contacted in the future by our clients should your personal information be provided to us again.
This process will not prevent other companies from contacting you. However, you can visit the page below to register on ADMA’s Do Not Mail Register to reduce the volume of marketing materials you receive.
adma.com.au/do-not-mail
Accessing Your Information
You can request access at any time to your personal information we hold by using this website’s contact-us form. We will require you to adequately identify yourself when requesting a copy of your personal information.
We will process your straightforward request within a reasonable time, usually 30 days. Depending on the nature of the request, we may need more time. There is no fee for requesting access to your personal information, however, we may charge you the reasonable cost of processing your request. If a fee applies, we will advise you before we provide access..
If there is a reason for not granting you access to any of your personal information, we will provide you with a written explanation of the reasons for the refusal (unless unreasonable to do so) and inform you of the mechanisms to complain about the refusal.
Correcting your personal information
We try to ensure that all information we hold about you is accurate, complete and up to date. You may ask us at any time to correct personal information held by us about you, that you believe may be incorrect or out of date. We will deal with your request within a reasonable time.
If you would like to update or correct any personal information we hold about you, please let us know by using this website’s contact-us form.
We may also need to verify your identity when you request to update or correct your personal information.
Remaining Anonymous
So far as is reasonably possible we are happy to deal with you anonymously or under a pseudonym if you prefer. Generally, we can provide information about our products and services without requiring you to provide contact details. However, you should be aware that if you elect to remain anonymous or use a pseudonym, it may impact our ability to provide complete and detailed information, products, services or assistance to you.
Third Parties
This Privacy Policy does not apply to websites operated by others or the business practices of third parties.
If we refer you to a third-party website via a link on this website, we are not making any representations to you regarding the privacy or security of your personal information when collected or held by the other website. The privacy practices applicable to other websites may differ substantially from ours so you should read their privacy policies before using them. We do not accept responsibility for the content or practices of websites operated by third parties that are linked from our websites.
Consent
Where the law requires that we have your consent to do something, we will take reasonable steps to ensure such consent has been provided.
You may have provided your consent to a third party for them to provide your information to us to use as set out above. Where information about you is collected from third parties and provided to us, we review whether it has been collected in compliance with the Privacy Act, including that the third party is entitled to provide the information to us and that you have provided appropriate consent as required by law.
By using our website, or providing us personal information, you agree to the terms of our Privacy Policy.
You have the right to withdraw your consent at any time and may do so via the opt-out form on this website.
Policy Updates
We regularly review this Privacy Policy and our privacy practices.
We may amend this policy from time to time. If we do, we will update the Privacy Policy on our website. The changes will come into effect immediately upon notification on our website. You should check our website occasionally to understand how our Privacy Policy’s current version applies to you.
This policy was last updated on 6 December 2023.
Contact and Complaints
If you have a complaint about our use, handling or disclosure of your personal information, please contact our Privacy Officer in writing at [email protected].
Following receipt of your complaint, we will investigate and respond to you within a reasonable period.
If you are dissatisfied with our response, you may also contact the relevant regulator such as the Office of the Australian Information Commissioner. As of the date of this Privacy Policy, the contact details are as follows:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: [email protected]
Online: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
If you would like more information about the Privacy Act or Australian privacy requirements in general, please visit the Office of the Information Commissioner’s website at www.oaic.gov.au.
