Privacy Policy

Our commitment to privacy

1. CodeBots Pty. Ltd., its related companies, subsidiaries, and affiliates in Australia and overseas (collectively referred to as CodeBots) are committed to managing Personal Data in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth.) and in accordance with other applicable privacy laws in Australia and elsewhere, including the General Data Protection Regulation 2018 (E.U.) (the G.D.P.R.).
2. This document sets out our policies for managing your Personal Data and is referred to as our Privacy Policy.
3. In this Privacy Policy, we and us refer to CodeBots and “you” refers to any individual about whom we collect personal information (Personal Data).
4. When we decide how and why Personal Data is processed (for example, for our websites, accounts, and marketing), we act as a “controller” or equivalent under applicable privacy laws. When we process Personal Data on behalf of our customers in connection with their use of the CodeBots platform, we generally act as a “processor” or equivalent and our customers remain responsible for providing their own privacy notices to their end users. In this processor role, we only process Personal Data on our customers' documented instructions, use appropriate technical and organisational measures to protect that Personal Data, and enter into written data processing agreements where required by law.

What Personal Data do we collect about you?

Partners, customers, and prospective partners and customers

1. When you enquire about our services or when you become a partner or customer of CodeBots, a record is made which includes your Personal Data.
2. The type of Personal Data that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
   1. your name, e-mail, postal address, and other contact details;
   2. information about your employer or an organisation who you represent;
   3. your professional details;
   4. I.P. address;
   5. blog comments, support queries, testimonials;
   6. social media handles; and
   7. any additional personal information you provide to us, or authorise us to collect, as part of your interaction with CodeBots.

Employees, prospective employees, or applicants

1. CodeBots collects Personal Data when recruiting personnel, such as your name, contact details, qualifications, and work history. Generally, we will collect this information directly from you.
2. We may also collect Personal Data from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number, superannuation information, social media handles, date of birth, and other information necessary to determine your suitability for certain positions.

Other individuals

1. CodeBots may collect Personal Data about other individuals who are not partners, customers, or employees of CodeBots. This includes customers and members of the public who participate in events we are involved with, individual service providers, and contractors to CodeBots, and other individuals who interact with CodeBots on a commercial basis. The kinds of Personal Data we collect will depend on the capacity in which you are dealing with CodeBots. Generally, it would include your name, contact details, employer name, blog comments, support queries, testimonials, social media handles, etc.
2. If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings, which may or may not identify you.
3. In limited circumstances, CodeBots may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by CodeBots, we may collect health information about you in an emergency or otherwise with your consent.
4. You can always decline to give CodeBots any Personal Data we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about Personal Data we have requested, please let us know.

Visitors to our websites

The way in which CodeBots handles the Personal Data of visitors to our websites is discussed below.

Children

1. Our services and websites are intended for use by adults and business users. They are not aimed at children.
2. We do not knowingly collect Personal Data from children under the age of 16 (or any higher age where required by local law). If you believe that a child has provided us with Personal Data, please contact us using the details below so that we can take appropriate steps.

How and why does CodeBots collect and use your Personal Data?

1. CodeBots collects Personal Data reasonably necessary to carry out our business, to assess and manage our partners’ and customers’ needs, and provide various services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties, and managing commercial relationships.
2. The purposes for which CodeBots usually collects and uses Personal Data depends on the nature of your interaction with us, but may include:
   1. providing services to you or in conjunction with you to third parties;
   2. responding to requests for information and other general inquiries;
   3. managing, planning, advertising, and administering programs, events, competitions, and performances;
   4. researching, developing, and expanding our facilities and services;
   5. informing you of our activities, events, facilities, and services;
   6. recruitment processes (including for volunteers, internships, and work experience); and
   7. responding to enquires and complaints.
3. CodeBots generally collects Personal Data directly from you. We may collect and update your Personal Data over the phone, by email, over the internet or social media, or in person. We may also collect Personal Data about you from other sources, including third party partners, suppliers, and contractors who assist us in our business.
4. CodeBots also collects and uses Personal Data for market research purposes and to innovate our delivery of products and services.

How does CodeBots interact with you online?

1. You may visit our websites without identifying yourself.
2. If you identify yourself (for example, by providing your contact details in an enquiry), any Personal Data you provide to CodeBots will be managed in accordance with this Privacy Policy.
3. CodeBots’s websites use cookies and similar technologies - a “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We use cookies that are necessary for the site to function, as well as analytics cookies provided by tools such as Google Analytics and Microsoft Clarity to help us understand how our websites are used and to gain behavioural insights (for example, page interactions, session paths, and click or scroll heatmaps). These analytics cookies collect information such as your device type, browser type, I.P. address (which may be anonymised where applicable), pages you have accessed on our websites and on third-party websites, approximate location based on I.P. address, and general usage patterns.
4. Analytics cookies like Google Analytics and Microsoft Clarity are non-essential. Where required by local law (for example in the E.U. or U.K.), we will only use these analytics cookies after you have given your consent through our cookie banner or settings tool.
5. You can use the settings in your browser to control how your browser deals with cookies. In some regions you may also be able to manage your cookie preferences through a cookie banner or settings tool on our websites. However, if you disable or reject certain cookies, you may be unable to access certain pages or content on our websites.
6. In addition to our own controls, you can learn more about and opt out of certain data collection by these providers by visiting the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout and the Microsoft Clarity information page at https://clarity.microsoft.com/terms.
7. CodeBots’s websites may contain links to third-party websites. CodeBots is not responsible for the content or privacy practices of websites that are linked to our website.

Can you deal with CodeBots anonymously?

CodeBots will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for CodeBots to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect Personal Data about you, you may be unable to utilise our services or participate in our events, programs, or activities we manage or deliver.

How does CodeBots hold information?

1. CodeBots stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and elsewhere). Personal Data may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your Personal Data from misuse, interference, and loss and from unauthorised access, modification, or disclosure.
2. CodeBots maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
3. Our websites use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending Personal Data via the internet.
4. We take steps to destroy or de-identify information that we no longer require.

How long do we keep your Personal Data?

1. We keep your Personal Data for as long as it is reasonably necessary for the purposes set out in this Privacy Policy, including to provide our services to you, to manage our relationship with you, and to comply with our legal, tax, and accounting obligations.
2. When we no longer need Personal Data for these purposes, we will take reasonable steps to delete it or de-identify it, unless we are required by law to keep it for a longer period.
3. When deciding how long to keep Personal Data, we take into account the nature of the information, the amount, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and any legal requirements that apply.
4. Analytics cookies used on our websites typically persist between 1 day and 2 years depending on the cookie type and purpose. You can delete these cookies earlier at any time using your browser settings or our cookie settings tool (where available).

Data breaches and security incidents

1. We take reasonable steps to prevent data breaches, including the security measures described above. If we become aware of a data breach involving Personal Data, we will assess the impact promptly.
2. Where required by law, we will notify the relevant privacy regulator and affected individuals of eligible or notifiable data breaches, and we will take reasonable steps to mitigate any likely risk of harm.

Does CodeBots use or disclose your Personal Data for direct marketing?

1. CodeBots may use or disclose your Personal Data for the purpose of informing you about our services, upcoming promotions, and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
2. If you opt-out of receiving marketing material from us, CodeBots may still contact you in relation to its ongoing relationship with you.

How does CodeBots use and disclose Personal Data?

Partners and customers

1. The purposes for which we may use and disclose your Personal Data will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may use and/or disclose information about you to service providers where this is relevant to our services.
2. We may also use your Personal Data to:
   1. monitor your use of our website, portals, platforms, forums;
   2. tailor our products and/or services to suit your specific needs; and
   3. contact you for sales and marketing purposes.

Participants at events

1. If you are a participant in an event, we may disclose your Personal Data to our partners and customers and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.
2. We may also use your Personal Data to:
   1. monitor your use of our website, portals, platforms, forums;
   2. tailor our products and/or services to suit your specific needs; and
   3. contact you for sales and marketing purposes.

Disclosure to contractors and other service providers

1. CodeBots may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance or development, application development, printing, archiving, mail-outs, and market research.
2. Personal Data may also be shared between related and affiliated companies of CodeBots, located in Australia and elsewhere.
3. Third parties to whom we have disclosed your Personal Data may contact you directly to let you know they have collected your Personal Data and to give you information about their privacy policies.

Use and disclosure for administration and management

CodeBots will also use and disclose Personal Data for a range of administrative, management, and operational purposes. These include:

1. administering billing and payments and debt recovery;
2. planning, managing, monitoring, and evaluating our services;
3. quality improvement activities;
4. statistical analysis and reporting;
5. training staff, contractors, and other workers;
6. risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
7. responding to enquiries and complaints regarding our services;
8. obtaining advice from consultants and other professional advisers; and
9. responding to subpoenas and other legal orders and obligations.

Other uses and disclosures

We may use and disclose your Personal Data for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

Our responsibilities under the G.D.P.R.

1. If you are a resident of the E.U. or the U.K., you have certain rights and protections under the G.D.P.R. regarding the processing of your Personal Data.
2. We collect, use and store your Personal Data to enable us to provide you with our goods or services and information about them. We rely on the following lawful means of processing your Personal Data:
   1. where it is necessary to fulfil a contract with you - this includes where we collect your Personal Data to enable us to send you our goods or provide you with our services;
   2. where you have given us valid consent to use your Personal Data - we will rely on that consent and only use the Personal Data for the specific purpose for which you have given consent, and this includes where we email newsletters or send mobile phone notifications; and
   3. we may also process your Personal Data where it is to further our legitimate interests which could include usage statistics, analytics and internal analysis so we can improve our services to you.

Additional rights for certain U.S. residents

1. If you are a resident of certain U.S. states (for example, California), local privacy laws may give you additional rights over your Personal Data, including the right to know what categories of Personal Data we collect, use, and disclose, the right to access and request deletion of certain Personal Data, and the right to correct inaccurate Personal Data.
2. Subject to applicable law and any exceptions, you may also have the right to opt out of certain types of “selling” or “sharing” of your Personal Data as those terms are defined under local law. CodeBots does not sell Personal Data in the traditional sense, but we may use cookies and similar technologies for analytics and marketing as described above.
3. You can exercise these rights, where they apply, by contacting us using the contact details below, including by email at support@codebots.com.

Your rights as an E.U. or U.K. resident

1. If you are a resident of the E.U. or the U.K., you have various rights including:
   1. right to be informed;
   2. right of access;
   3. right to rectification;
   4. right to object;
   5. right to restriction of processing;
   6. right to erasure or to be forgotten;
   7. right to data portability; and
   8. right not to be subject to automated processing.
2. If you want to access your Personal Data or ask for the information to be corrected, please contact us. In some circumstances, you also have a right to object to or ask that we restrict certain processing activities or delete your Personal Data. If you would like to limit or request deletion of your Personal Data or exercise any other rights, you can do so by contacting us.

Our compliance with the G.D.P.R.

1. We comply with the G.D.P.R. data protection principles when processing Personal Data of E.U. and U.K. residents. This includes taking steps to keep Personal Data accurate and up to date, limiting the Personal Data we collect to what is necessary for the purposes described in this Privacy Policy, and implementing appropriate technical and organisational measures to protect Personal Data.
2. Where we transfer Personal Data of E.U. or U.K. residents outside of the E.E.A. or the U.K., we will take steps to ensure an adequate level of protection, for example by relying on appropriate safeguards such as standard contractual clauses or equivalent mechanisms where required, together with technical and organisational measures designed to protect the Personal Data.
3. All Personal Data stored on our platform is treated as confidential. It is stored securely and is only accessed by authorised personnel.

International transfers of Personal Data

1. As a global business, we may transfer your Personal Data to countries other than the one in which it was originally collected, including to Australia and to other countries where our group companies, service providers, and partners are located.
2. When we transfer Personal Data to another country, we will take reasonable steps to ensure that the transfer complies with applicable privacy laws and that appropriate safeguards are in place to protect your Personal Data.

How can you access or seek correction of your Personal Data?

1. You are entitled to access your Personal Data held by CodeBots on request. To request access to your Personal Data please contact our privacy officer using the contact details set out below, including by email at support@codebots.com.
2. You will not be charged for making a request to access your Personal Data but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
3. We will take reasonable steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
4. However, if you consider any Personal Data we hold about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
5. We may decline your request to access or correct your Personal Data in certain circumstances in accordance with the Australian Privacy Principles and the G.D.P.R. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your Personal Data about the requested correction.

Withdrawing your consent

You can withdraw your consent to our collection or processing of your Personal Data. You can do so by contacting us, including by emailing support@codebots.com, or by opting out of email newsletter communications by following the instructions in those emails or by clicking unsubscribe. If you withdraw your consent to the use of your Personal Data, you may not have access to our services, and we might not be able to provide you with our services. In some circumstances, where we have a legal basis to do so, we may continue to process your information after you have withdrawn consent. For example, if it is necessary to comply with an independent legal obligation or if it is necessary to do so to protect our legitimate interest in keeping our services secure.

What should you do if you have a complaint about the handling of Personal Data?

1. You may contact CodeBots at any time if you have any questions or concerns about this Privacy Policy or about the way in which your Personal Data has been handled. You can do so using the contact details set out below, including by emailing support@codebots.com.
2. You may make a complaint about privacy to CodeBots at the contact details set out below, addressed to the Privacy Officer.
3. The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within one week.
4. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
5. In most cases, we will investigate and respond to a complaint within thirty days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
6. If you are not satisfied with our response to your complaint, or you consider that CodeBots may have breached the Australian Privacy Principles, or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

How to contact us about privacy

1. CodeBots has appointed a Privacy Officer (who also acts as our Data Protection Officer for certain regions) to oversee our handling of Personal Data.
2. You can contact our Privacy Officer by emailing support@codebots.com or by using the contact details published on our website.

How changes are made to this Privacy Policy?

CodeBots may amend this Privacy Policy from time to time. If we make material changes, we will take reasonable steps to inform you, for example by posting a notice on our website or, where appropriate, by contacting you directly. We recommend that you visit our website regularly to keep up to date with any changes.