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.
This Notice is intended to meet the requirements of:
- A general notice of privacy for regions and countries not covered by the GDPR regulations.
- 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 for the United Kingdom (the “UK 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 Policy which sets out how we process your data in connection with your employment and/or engagement with Propella.
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 any affiliated business, such as Gary Broadbent Art. They are collectively referred to as “Propella” for the purpose of this Privacy Notice and GDPR. Unless otherwise stated we shall be considered a data controller of your personal data in connection with the use cases identified in this Notice. Please note: In relation to Services we provide, we may carry out the activities referred to in this Notice acting on behalf of our clients, or ourselves.
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.
Data we collect
We do not collect, store, or use all the kinds of Information listed below - only one or two items 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
Gender; nationality; resumé, work experience, or any information you may have provided before or during your supply of services to us. - Image data
Photos; illustration; video recordings; portfolios; images; documentation. - Transaction data
Bank account details; payment card details; or payments made between you Propella. - Profile data
Your personal interests and preferences; contact and marketing preferences; and responses to surveys.
- Behavioural data
Browsing activity, obtained via cookies, pixel tags and other technologies; data about your current or previous session; services you viewed or purchased on the Site. - Technical data
IP address; browser type; operating system; geolocation; and unique device numbers (to ensure we’re showing you the correct information). - Publicly available data
Information and articles (or similar) you may have published; information about your interests and affiliations; publicly stated positions on political or corporate matters (or similar).
- 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 visits
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.
- 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 long do we keep data?
We retain personal data only for as long as is necessary for the purposes described in this Notice, after which it is deleted from our systems. If any data is used for a short period (such as a campaign) we will often delete it when complete.
If you have opted out of receiving communications from us, we will need to retain certain personal data on a suppression list so that we know not to send you further marketing communications in the future.
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.
Event data
We may organise and host shows or events to promote our services for Propella or our clients. We may use the resulting data to communicate about these events, or where we have another lawful reason for sending that information.
If you attend an event we may use your data to document attendance. You may feature in photos taken at events and these may appear in publications we send to clients and/or published on our website, in social media, and printed media.
Event 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 Propella (or our client) with services (e.g. IT support) we will process personal data if you are a contact within the organisation to manage our relationship (or our clients) with the organisation, to receive services from the organisation and, where relevant, 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 when we are legally permitted to do so, and only if there is a contractual arrangement and security mechanisms are in place to protect the shared data which 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:
- 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 may offer your consent for our use of your data:
- When we collect your data following your instructions; or
- Informing us by email set out in this Privacy Notice.
- Please note: If you consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.
Third parties
Web links and third party services
This Site contains links to third party websites and services. Please remember that when you use a link to leave our Site to go to another website or you request a service from a third party, this Privacy Notice no longer applies to third-party websites, products and services unless we are acting as joint controllers in respect of your personal data with such third party.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.
Social media
This Site may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.
Confidentiality
Maintaining security
We are committed to maintaining the security of your personal data. 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, our employees and those who process your data on our behalf are obliged to respect the confidentiality of the data we hold.
Data protection
You have the following rights in relation to the personal data we hold about you under certain circumstances:
- You can obtain confirmation if we process data about you, or obtain access to copies of the data, and information about the processing we do.
Should you wish to make changes to your data:
- If the data we hold is inaccurate or incomplete, you may request an amendment. It is your responsibility to provide accurate data and inform us of changes.
- If the reason for which the data is being used is no longer legal or appropriate, we will delete the data, unless we can demonstrate we are required to retain the data by an applicable law or otherwise.
- If we have shared your data with others, we will let them know about the deletion request if possible. If you ask us (and it is possible and lawful to do so), we will tell you who we have shared your data with so you can contact them directly.
Restricting data
You may request we restrict the processing of your data in some circumstances, such as when you contest the accuracy of the data, or while we investigate your concern.
- It will not prevent us from storing your personal data.
- We will tell you before we lift a restriction.
- You may withdraw your consent for our using your data at any time, if processing relies upon consent.
- If we have shared your data with others, we will let them know about the restriction, and tell you who your data has been shared with so you can contact them.
You may exercise your right in writing by emailing us. We will endeavour to respond quickly to your request. Where you ask us for a copy of your personal data, we are obliged to respond within one month of the request. If your request is denied we will inform you of the reasons.
Please note: We may need to verify your identity to confirm your right to access your data. This security measure helps protect your data. To verify your identity, we may need to gather more personal data from you.
Minors
Personal data of minors
Our Site is not intended for use by, or targeted at, minors (individuals under the age of 18). We do not knowingly collect personal data of minors or children. However, due to the nature of our organisation and the Services we provide, we may from time-to-time unwittingly collect and process personal data relating to minors. If we do, we will comply with all applicable laws and regulations relating to the processing this data.
