Effective Date: September 6, 2018
Policy Statement
Silverth Pty Ltd (“Silverth”, “Silverth.com”, “we”, “us”) is committed to protecting your privacy when you interact with us, our content, products, or services.
Purpose of this Policy
This policy explains our personal information handling practices. It describes how we may collect, use, and disclose information about you or your use of our content, products, or services.
For the purposes of the Policy, the term “personal data” will have the same meaning as in EU General Data Protection Regulation 2016/679(“GDPR”).
Who We Are and What This Policy Covers
We are the folks behind a variety of products and services. This Privacy Policy applies to information that we collect about you when you use:
• Our websites (including silverth.com, patswebdesign.com, tootyhost.com, geniedownunder.com, adirectory.net.au and globeefit.com);
• Our mobile applications (including the globeefit mobile app for Android);
• Our other products and services that are available on or through our websites (including silverth.com, patswebdesign.com, tootyhost.com plans and adirectory.net.au plans); and
• Other users’ websites that use our Services, while you are logged in to your account with us.
Throughout this Privacy Policy we’ll refer to our websites, mobile applications and other products and services collectively as “Services.”
Our respective websites, mobile applications, products and services (including silverth.com, patswebdesign.com, tootyhost.com, geniedownunder.com, adirectory.net.au and globeefit.com) may have additional privacy policy information which applies to its respective services.
By using the Services, you signify your agreement to the terms and conditions of this Policy and to our collection, use and disclosure of your personal data as set out herein. You may change or withdraw your consent to the collection, use or disclosure of your personal data at any time, by using the request forms in section “Seeking access to, and updating information we hold about you” or by contacting the Privacy Officer in writing at the address listed below. In some circumstances, a change or withdrawal of consent may affect your ability to use the Services.
1. Collection of Personal Information
We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.
1.1 How we collect personal information
The main circumstances in which Silverth collects personal information about you are: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
• Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an account with tootyhost.com, geniedownunder.com and/or adirectory.net.au to provide a username and email address.
• Public Profile Information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have an ADirectory.net.au account, your username is part of that public profile, along with any other information you put into your public profile, such as a photo or an “About Me” description. Your public profile information is just that–public–so please keep that in mind when deciding what information you would like to include.
• Transaction and Billing Information: If you buy something from us–a subscription to a tootyhost.com plans, adirectory.net.au plans, a domain name registration, or a hosting account, for example–you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
• Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your website).
• Credentials: Depending on the Services you use, you may provide us with credentials for your website.
• Communications With Us: You may also provide us information when you communicate with our team via email, phone or other social media platform that we use.
Information We Collect Automatically
We also collect some information automatically:
• Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you create or make changes to your listings on ADirectory.net.au.
• Usage Information: We collect information about your usage of our Services. We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
• Location Information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (when, for example, you post a listing with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored Information: We may access information stored on your mobile device via our mobile app. We access this stored information through your device operating system’s permissions
• Interactions with Other Users’ Sites: We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post, so that we can, for example, recommend posts we think may interest you.
• Comments: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
• Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Silverth uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.
Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log into your adirectory.net.au account through another service (like Google) or if you connect your website or account to a social media service (like Twitter), we will receive information from that service (such as your username, basic profile information, and friends list) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.
Silverth policy in relation to Cookies, Beacons, Local Storage and Other technologies described below apply to all Silverth Pty Ltd properties, including those specifically designed for children. Parents and carers should be aware that if their children are using social media sites that were not designed for their age group, they will be exposed to the various tracking and analytic technologies applied by third parties when they access or share Silverth content on or via those sites.
1.2 Purposes for which we collect, use, and disclose personal information
The purposes for which we collect, use and disclose personal information include:
• to provide our services to you – for example, to set up and maintain your account, host your website, backup and restore your website, or charge you for any of our paid Services;
• to improve our products and services, including conducting surveys;
• to monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
• To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
• To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Silverth and others, which may result in us declining a transaction or the use of our Services;
• to manage our relationship with you, including:
(a) communicating with you about our products or services, including providing information about products or services which we consider may be of interest to you;
(b) billing you for any products or services that we charge for;
(c) investigating any complaints made by or about you;
(d) managing any request by you to return or exchange a product at a later date; and
(e) to otherwise offer you assistance, including, by providing technical support;
• to conduct competitions or promotions on behalf of Silverth or industry third parties we have entered into agreements with;
• for statistical and research purposes;
• to obtain professional services as required including legal, accounting or insurance services;
• if permitted or required by law;
• otherwise with your consent; or
• for purposes directly related to any one or more of the above.
We will not send you unsolicited direct marketing emails, without your prior consent, unless we are permitted to do so by law. We will always give you the option to opt out of further communications. We may send you electronic communications for account administration purposes for so long as you are a registered user or customer of Silverth.
1.3 Disclosure of personal information
We may disclose your personal information to our:
• technology service providers, including, internet service providers, app service providers, cloud hosting service providers, software suppliers, and maintenance and support service providers;
• GenieDownUnder.com Shop Online fulfilment partners such as Australia Post, product distributors, third party suppliers, third party vendors, gift card suppliers and loyalty program suppliers;
• marketing, promotions and ratings service providers; and
• subscription service providers and their mailing houses.
These third parties may be located in Australia or outside Australia, including but not limited to USA, India, China, New Zealand and the Philippines.
Silverth Pty Ltd has a statutory obligation to take contractual measures to ensure that its contracted service providers do not do an act or engage in a practice that would breach an Australian Privacy Principle if done or engaged in by Silverth Pty Ltd.
Silverth Pty Ltd will not sell or receive payment for licensing or disclosing your personal information.
Silverth Pty Ltd may include links to third party content on its websites and in other electronic communications. Silverth Pty Ltd does not have any control over the privacy practices of those third parties. Please check the website of each relevant third party for details of their privacy policies. Silverth Pty Ltd does not control who links to any of the Silverth Pty Ltd websites.
1.4 Options to enter into additional privacy terms
We will sometimes give you an option to use products or services which are provided in conjunction with other entities such as social media networks. If we do this, you will be given privacy information before being asked to consent to the terms and conditions of that service. You should read the privacy policy and terms and conditions of each service very carefully before deciding whether to accept them. You should also be careful to ensure that you only post information online if you are happy for it to be and to remain publicly available.
1.5 Security
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
1.6 Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
2. Seeking access to, and updating information we hold about you
You may, as a visitor to our website, choose not to provide us with personal information. You have the right to request access to personal information that is held by Silverth about you. Requests for access will be dealt with by Silverth in accordance with the Freedom of Information Act 1982 (Cth).
You also have the right to request the correction of any of your personal information that Silverth holds. Silverth will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date. You also have the right to obtain from Silverth the erasure of personal data about you in accordance with applicable data privacy laws.
You may also, at any time, access your personal information to update, correct, or delete certain personal information about you by contacting Silverth Privacy Contact Officer, whose details are below or exercising your rights with the following requests:
Exercise Your rights
Request to be removed:
[gdpr_request_form type=”delete”]
Request Access to your data:
[gdpr_request_form type=”export-data”]
Request rectification:
[gdpr_request_form type=”rectify”]
Personal information that you have provided to geniedownunder.com Shop Online (such as your name, invoice and delivery addresses, phone number, or email address) is accessible by you by registering with geniedownunder.com Shop Online. If you register with geniedownunder.com Shop Online you will need to retain a username and password. Silverth recommends that you update your personal information if your details change so that our records are accurate, complete and up-to-date.
3. Making a complaint
Silverth welcomes feedback about privacy issues and will attend to all questions and complaints promptly. Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual user. Please contact our Privacy Contact Officer using the details below if you would like to make a complaint or use the following request form to submit a complaint.
Submit a complaint:
[gdpr_request_form type=”complaint”]
If Silverth takes more than 30 days to respond to your privacy complaint, or if you are dissatisfied with the outcome, you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner. The OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au
4. Updates to This Privacy Policy
We may occasionally update this privacy policy. If we do, we will change the “effective date” at the top of the privacy policy. Before making any update that would make this privacy policy materially less restrictive in our use or disclosure of personal information collected prior to the update, we will provide prior notice of the update by posting notice on our website at the top or bottom of the then-current privacy policy. We encourage you to periodically review this privacy policy to stay informed about our collection, use, and disclosure of personal information. Your continued use of our website constitutes your agreement to our then-current privacy policy.
5. Privacy contact officer contact details
If you wish to contact our privacy officer, please use the following contact details:
By email: privacy@silverth.com
By mail:
Silverth Privacy Contact Officer
Silverth Pty Ltd
17 Everest Rd,
Exeter, Tasmania
Australia 7275
Questions?
If you have any questions about this policy, please contact us.