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Purpose of this Privacy Notice

About this Notice

This Privacy Notice (“Notice”) sets out how Propella Pty Ltd  (“Propella”, “we”, “us” or “our”) use any Personal Information (“Information”) or data that we collect in connection with our business, or when people use our Website (“Site”) or Services (“Services”), or during any interaction with us.
This Notice explains the kind of data we collect, why we collected it, and your rights in respect of our processing of your Information. This Notice is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand this Privacy Notice. It is intended to be read in conjunction with our Cookie Policy.
Finally, this Privacy Notice is only intended to meet the requirements of:
  • Regulation (EU) 2016/79 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”).
  • Equivalent data protection laws in the United Kingdom (the “UK GDPR”).
  • A general notice of privacy (other than the GDPR).

Scope of this Notice

This Notice only applies to the use of your Information obtained by us, from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their websites, products, or services.
This Notice is not intended to cover the processing of workplace personal data. If you are engaged as a worker for us, please contact us to see our Workplace Privacy Notice which sets out how we may process your data in connection with your employment and/or engagement.

Changes to this Notice

We update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Notice, but we encourage you to review this Notice periodically to keep up to date on how we use your personal data. The date of the ‘Last Update’ of this Notice is displayed at the top of this web page.

About Propella

Business details

Propella is an Australian business (ACN: 138649046 / ABN: 73138649046) with the registered company name of Propella Pty Ltd. with its registered office at Suite 3.09, 56 Delhi Road, North Ryde, NSW2113, Australia.

Application of policy

This Privacy Notice  applies to Propella Pty Ltd and affiliated businesses such as Gary Broadbent Art, collectively referred to as “Propella”. For the purpose of this Privacy Notice and the GDPR, unless we state otherwise we shall be considered a data controller of your personal data in connection with use cases identified in this Privacy Notice. Please note, that in relation to Services we provide, we may carry out the activities referred to in this Privacy Notice in our capacity as a data processor acting on behalf of our clients.

Contact us

If you have any questions about this Notice or want to exercise your rights set out in this Notice, contact us via email:

hello@propella.agency

Data

Type of data we collect/process

When Personal Information is mentioned, it refers to information, or opinions about (or from) a person who is identified, or who may be reasonably identified by reference to a name, an ID number, location data, an online identifier (such as an IP address), or other factors specific to them, such as their physical appearance. Please Note: We do not collect, store, or use all the kinds of Information listed below - only one or two items of relating to an individual may be collected and stored. This can include:
  • Names
    First name; last name.
  • Contact data
    Delivery, billing, or home address; email address; mobile and/or phone number; social media handle.
  • Applicant data
    Date of birth; gender; country; nationality; resumés and work experience or any other information you may provide in advance of/during your supply of services to us.
  • Image data
    Photos; illustration; video recordings; portfolios; images; documents.
  • Transaction data
    Bank account and payment card details; payments made between you and; or services purchased from us.
  • Profile data
    Your interests and preferences; contact and marketing preferences; feedback and responses to surveys; date of birth or other occasions.
  • Behavioural data
    This is data relating to your browsing activity, obtained through the use of cookies, pixel tags and other technologies; information about when your current or previous sessions started; details about services you viewed or purchased through the Site.
  • Technical data
    Includes your IP address; browser type; operating system; geolocation; and to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
  • Publicly available data
    Information about articles (or similar) you may have published; information about your interests, or affiliations, or publicly stated positions on political or corporate matters and similar.

How we collect data

We may collect data using different methods and sources:
  • From you
    You may supply your information and data directly to us when you obtain our services via our website, contact us with enquiries, complete forms on our website, or subscribe to receive marketing.
  • Cookies
    We may collect Behavioural or Technical Data using cookies or other technologies via our website.
  • Third parties
    We may receive personal data about you from third parties; such as analytics providers, data brokers, third party directories, and technical services.
  • Publicly available
    We may collect publicly available information about you (such as identity or contact data) from open source data sets, media reports, publications, news stories, speeches, or social media posts, and websites.

Where do we collect data from

We collect information from the following sources:
  • Site visitors
    When you interact with our website.
  • Direct enquiries
    Via our website; submit a complaint; write to us; or offer feedback on surveys or forms.
  • Suppliers and talent
    When you supply products, services, or material to us, or work with us to provide services to clients, or the work we produce.
  • Clients
    We may collect and process your data with regard to the supply of services to you and/or your organisation.
  • Visitors: If we meet with you (in-person or via video) we may process information you volunteer in connection with your meeting and enquiry.
  • Events
    If you attend an event, we will process information about your attendance and registration at the event.
  • Job applicants: If you apply for a job with us.

How we use personal data

Operation of our website

When you browse our Site
When you browse our website, we may collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our website. We do this to understand which parts of our Site are more or less popular and improve our Site.
Our legal basis for processing
We use your data to perform our obligations in accordance with any contract we may have with you for Services, or it is in our legitimate interest to use personal data to provide access to our Site in a secure and effective way, and so that we can make improvements to our Site.
Website insight and analysis
We and our third-party partners might use cookies, web beacons, pixel tags, and similar technologies (often referred to as “Cookies”) to collect data from devices you use to access our Site. The data we collect can include Behavioural Data and Technical Data, and Profile Data. Please see our Cookie Notice for further information, including details of our third-party partners. We and our third-party partners use this data to analyse how you use our Site and our Services and the effectiveness of our Site and Services, including:
  • Analyse the effectiveness of our website and services.
  • Track the number of visitors to our Site and other types of information; including visitor browsing insights.
  • Measure effectiveness of content; including what parts of our Site are most interesting, and what features and functionalities our visitors like to see.
  • Understand the type of marketing content that appeals most to our visitors.
Our legal basis for processing
Where data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
We may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through performance cookies to analyse how you use our Site, it is in our legitimate interest to use your personal data in such a way to improve our Site and Services.
Using interactive features on our Site
We will collect and use personal data when you use certain features on our Site. For example, depending on your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use forms or chat functions to get in touch with us or other account holders.
Our legal basis for processing
It is necessary for us to use your data to perform our obligations in accordance with any contract we may have with you for the Services, or it is in our legitimate interest to use data to ensure we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.
Social media interactions
If you click on one of the social media links on our Site, or interact with our social media pages (such as Facebook or Instagram) or interact with any ‘like’ or similar embedded features on our Site or social media accounts, we and the relevant social media platform may receive information relating to such interaction and may share your data in connection with this purpose, such as certain Behavioural Data and Technical Data. For information about how we use this data, please see the Website insight and analysis section.
The relevant social platform may be a controller of the collected data via your use of our social media pages and may use that data for additional purposes. For details of how the relevant social media platform uses your data, please see the privacy notice of the social media platform.
Our legal basis for processing
It is in our legitimate interest to use personal data in the ways described above to ensure we provide the Site in an effective way and to promote our Site via social media.

Provision of services and marketing

Client facing services
We may act on our own behalf, or on behalf of our clients, collect data about you with the provision of our Services.
It is in our interests to process personal data to enable us to provide enhanced services. When we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing. Where your data is collected through the use of cookies that are not strictly necessary, we rely on consent to collect your personal data and for the processing purpose. See our Cookie Notice for more.
Social media
We may collect or process individuals’ data who engage with us through our social media channels (including visiting our social media pages or communicating with us via social media). We may also operate our client’s social media pages, accounts or channels acting on their behalf.
It is in our interests to process personal data in this way so that we can market ourselves and engage with the public. Where we carry out this activity on behalf of our clients as a data processor we do not require a legal basis for such processing.
Marketing and media enquiries
We may use your Identity Data, Contact Data and Profile Data to send you (or the organisation you represent) marketing communications by email or via phone. Our marketing may include press releases and information about us.
It is in our legitimate interest to use your data in this way to ensure the promotion of our services is customised and/or appealing to you and/or the organisation you work for although sometimes we may also obtain your consent.
Media and information enquiries
We may collect Identity Data, Contact Data and Publicly Available Data about journalists, client or industry contacts for interviews requests, for media questions, or requests for information about Propella. We may provide individuals with the opportunity to sign up for newsletters or receive copies of blogs and other information we make available. Where an individual signs up to receive this information, Contact Data may be requested, together with other personal data relevant to these inquiries. This information is used to enable us to respond to individual or media requests.
It is in our legitimate interests (and those of our clients) to process personal data in this way to ensure we provide the services requested by our clients in an effective and efficient way and that we provide the right information to those who request it.
Events
We may organise and host shows or industry events to promote our services, or on behalf of clients. We may process this data including to communicate about these events when requested, or where we have another lawful basis for sending that information.
If you attend an event, we may use your data to record attendance, and record-keeping purposes. You may feature in photographs at events and these may appear in publications we send to clients and/or published on our Site, in print, or other media.
We use this data to perform our obligations in accordance with any contract we may have, or it is in our, or our client’s interest to use this data to provide our services in an effective and efficient way. If we ask your permission to use your photographs, quotes, testimonials or other content, then processing of data will be based on consent. Where we put on events at the request of clients we do so as our client’s data processor and therefore do not require a legal basis to process personal data.

Business administration, financial and legal

Receipt of services
If we have engaged an organisation to provide us or our client with services (for example, IT support or financial advice), we will collect and process your personal data (including Contact and Identity Data) if you are a contact within the relevant organisation in order to manage our relationship, or our clients with the organisation, to receive services from the organisation and, where relevant, to provide our services to others including our clients.
We use this data to perform our obligations in accordance with any contract that we may have with the organisation, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with the organisation and are able to provide our services to others in an effective way. Where we do this on behalf of our clients as a data processor, we do not require a legal basis for such processing.
Compliance
We may use an individual’s personal data for the following business administration, finance, and legal compliance purposes:
  • Facilitate effective management of our businesses.
  • Financial, accounting and tax purposes.
  • Comply with our legal obligations.
  • Enforce or protect our legal rights.
  • Manage complaints and enquiries.
  • Protect the rights of third parties.
Where we use data in connection with a business transition, to enforce our legal rights, or protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we will rely on our obligation to comply with law (including any court order) to process such data.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with the individual’s explicit consent.

Sharing Data

Failing to provide your data

Where we are required by law to collect your personal data, or we need to collect your data under the terms of a contract we have with you, and you fail to provide that data when we request it, we may not be able to perform the contract we have, or are trying to enter into with you. This may apply where you do not provide the data we need to provide the requested Services from us or to process an employment application with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

Sharing your data

We only share data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the shared data and to comply with our data protection, confidentiality and security standards and obligations. We may share data (subject to the above) with Propella owned businesses, partner agencies, and third parties as set out below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties, including:
  • Clients
    For the purposes of providing clients with our Services.
  • Suppliers
    We use specialist suppliers and external experts and partners for services including communications, promotions, and events.
  • IT partners
    Third parties who help run, and manage our systems and digital platforms, including; providers of IT, cloud-based SaaS providers, identity management, website design, hosting and management, data analysis, data back-up, security, and storage services. The servers and cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may share your data with third-party service providers to assist with insight analytics. These providers are described in our Cookie Notice.
  • Payment providers
    Third parties who assist with financial consulting, invoicing, or making and receiving payments.
  • Marketing and CRM
    Suppliers who assist in managing our marketing database and sending out email marketing communications.
  • Recuitment agencies
    External recruiters and third-party providers who undertake background checks on our behalf and other entities for recruitment purposes.
  • Professional advisors
    Professional services firms including auditors, lawyers, accountants, and professional advisers who assist us for the lawful and effective management of our organisation or any disputes we may become involved in.
  • Government
    We may share data with government or regulatory agencies, or other third parties as required by, and in accordance with applicable law or regulation.
  • Law enforcement
    We may receive requests from law enforcement agencies with authority to obtain data to comply with law and regulation, investigate an alleged crime, or to establish, exercise or defend legal rights. We only fulfil requests where we are permitted to do so in accordance with applicable law or regulation.

Data transfers

Transfers outside Australia
Our operations are primarily managed within Australia, however we work in countries around the world including the UK and the EEA. Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not offer the same degree of protection, or rights for personal data, and may not have a data protection supervisory authority to help you if you have any concerns about the processing of personal data. You acknowledge and agree that any data provided directly to us may be stored in these countries.
To the extent our processing of your data is caught by the requirements of the UK GDPR and/or GDPR, when transferring your data to territories outside the UK or the EEA, we ensure, where required by applicable law, at least one of the following safeguards is implemented: (1) we only transfer your data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission; or (2) where we use certain service providers, we may use specific contracts approved by the UK Government or the European Commission referred to as the “Standard Contractual Clauses” or “SSCs” which give personal data the same protection it has in the UK and EU.
To find out more about the SCCs we use, please see: Standard contractual clauses for international transfers | European Commission or send us an email.

Obtaining consent

You can provide your consent for our use of data if required:
  • When we collect your data following your instructions; or
  • Informing us by email set out in this Privacy Notice.
  • Please note: that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

Confidentiality

Maintaining security

We are committed to maintaining the security of the personal data you provide. We have implemented information security policies, rules and technical measures to protect the data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services.

Data protection

You have the following rights in relation to the personal data we hold about you under certain circumstances:
  • To obtain the confirmation that we process personal data about you, to access and obtain copies of the information, as well as information relating to the processing we carry out.
  • To request your personal data be corrected where appropriate.
Should you wish to make changes to your data:
  • If the personal data we hold about you is inaccurate or incomplete, you may request the data be amended. Please be aware it is your responsibility to provide us with accurate data and inform us of any changes.
  • If you demonstrate the purpose for which the data is being processed is no longer legal or appropriate, the data will be deleted, unless we can demonstrate we are required to retain the personal data by applicable law or otherwise.
  • If we have shared your data with others, we will let them know about the deletion where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your data with so you can contact them directly.

Restricting data

To request we restrict the processing of your data in some circumstances, such as where you contest the accuracy of the data, while we investigate your concern.
  • It will not prevent us from storing your personal data.
  • We will tell you before we lift any restriction.
  • If we have shared your data with others, we will let them know about the restriction where possible, and tell you who we have shared your data with so you can contact them directly.
Where processing is based on your consent, to receive your personal data in a commonly used electronic format or ask that we move your personal data in that format to another provider, where your request relates to the personal data you gave us directly and where technically possible.
  • To object to your personal data being processed where we are relying on ours or a third party’s legitimate interest to do so or for the purpose of direct marketing.
  • To withdraw your consent at any time when processing relies upon consent.
  • If we have shared your data with others, we will let them know about the restriction where possible, and tell you who we have shared your data with so you can contact them directly.
Data subjects may exercise these rights in writing by emailing us. We will endeavour to promptly respond to your requests. Where you ask us to provide a copy of your personal data, we are legally obliged to respond within one month of such request. If your request is denied, we will inform you about the reasons for denial.
Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your data. This is a security measure to ensure your data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.