PRIVACY STATEMENT

Welcome! 24/7 Billing Co. provides software and services for small business operators to accept payments and manage their businesses online. 24/7 Billing Co. cares about the security and privacy of the personal information that is entrusted to us.

In this Privacy Statement, ‘us’ ‘we’ or ‘our’ means 24/7 Billing Co. Pty Ltd ABN 53 649 657 750. We are committed to respecting your privacy. Our Privacy Statement sets outs out how we collect, use, store and disclose your personal information. This Statement also includes a section on how we deal with privacy, and your rights, under the data protection laws in Europe, the United Kingdom and California.

24/7 Billing Co. (“24/7”, “we”, “our” or “us”) provides its services globally and the 24/7 entity responsible for the collection and use of personal data under this Privacy Policy may vary by region.

24/7 Billing Co. obtains personal information about you from various sources. “You” may be a visitor to one of our sites, a user of one or more of our services, or a direct or indirect customer of someone using our sites.

We may change our Privacy Statement from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Statement.

1. The personal information that we collect

1.1 Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information and tax information.

1.2 We may collect the following types of personal information:

(a) name;

(b) mailing or street address;

(d) telephone number and other contact details including social media handles and website URLs;

(e) age or date of birth;

(f) credit card information;

(g) professional information about you including experience, education, work history and portfolio information;

(h) your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

(i) details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;

(j) any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information this may include gender information;

(k) information you provide to us through customer surveys; or

(l) any other personal information that may be required in order to facilitate your dealings with us.

1.3 We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

(a) register on our website or app;

(b) communicate with us through correspondence, telephone calls, chats, email, or when you share information with us from other social applications, services or websites;

(d) when you make payments to, or transact via our services;

(e) provide personal information or biometric information for verification purpose; or

(f) invest in our business or enquire as to a potential purchase in our business.

1.4 In addition, when you apply for a job or position or membership with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.

2. Why we collect, use and disclose personal information

2.1 We may collect, hold, use and disclose your personal information for the following purposes:

(a) to enable you to access and use our website, services and app;

(b) to process payments via our services;

(c) to operate, protect, improve and optimise our website, services and app, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;

(d) to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;

(e) to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

(f) to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

(g) to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

(h) in connection with fraud monitoring, prevention, detection, and compliance activities

(i) to consider your employment application.

2.2 We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

3. How use your personal information for direct marketing

3.1 We and/or our carefully selected business partners may send you direct marketing communications and information about our website, services and app. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

4. How we disclose your personal information

4.1 We may disclose personal information for the purposes described in this privacy statement to:

(a) our employees and related bodies corporate;

(b) third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);

(c) professional advisers, dealers and agents, customers, clients and other participants or members of the website, services and app;

(d) payment systems operators (eg merchants receiving card payments or payment processors);

(e) our existing or potential agents, business partners or partners;

(f) our sponsors or promoters of any competition that we conduct via our services;

(g) anyone to whom our assets or businesses (or any part of them) are transferred;

(h) fraud detection and identity verification service providers;

(i) specific third parties authorised by you to receive information held by us; and/or

(j) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

5. Disclosure of personal information outside Australia

5.1 We may disclose personal information outside of Australia to some of the parties described including the United States of America and the United Kingdom.

5.2 When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law.

6. Using our website and cookies

6.1 We may collect personal information about you when you use and access our website.

6.2 We may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

6.3 We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

6.4 We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Statement.

7. Security

7.1 We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal information.

8. Links

8.1 Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.

9. Accessing or correcting your personal information

9.1 You can access the personal information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

9.2 If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

10. Retention

10.1 We retain your personal information as long as we are providing the services to you. After we stop providing services to you, and even if you close your account or complete a transaction, we keep your personal information in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection and prevention activities. We also keep personal information to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used.

11. Making a complaint

11.1 If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us at the details at the bottom of this privacy Statement. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

12. Contact Us

12.1 For further information about our Privacy Statement or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Marketing team

marketing@247billing.co

Effective: December 1, 2021

GDPR SECTION

13. European grounds for processing personal information

13.1 This section applies if you are based in the European Economic Area (EEA) during your interactions with us and sets out the additional information that we are required to provide to you under the GDPR.

13.2 Under European data protection law, use of personal information must be based on one of a number of legal grounds and we are required to set out the grounds in respect of each use. We can only process personal information when the processing is permitted by the specific legal ground set out in the law.

13.3 In the table below, we have set out the relevant grounds that apply to each purpose of data processing that is mentioned in this Privacy Statement.

[Client to review table and ensure all purposes are covered and accurate]

Purposes of the data processing	Use bases
to enable you to access and use our website, service or app.	§ contract performance§ legitimate interests (to allow us to perform our obligations and provide services to you)
to provide you with information about the website, service or app.	§ contract performance§ legitimate interests (to allow us to perform our obligations and provide services to you)
to operate, protect, improve and optimise our website, service or app, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;	§ contract performance§ legitimate interests (to allow us to maintain and improve the quality of our services and products)
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.	§ contract performance§ legal obligation§ legitimate interests (to allow us to correspond with you in connection with our services)
To ensure website content is relevant, including ensuring that content from our websites is presented in the most effective manner for you and for your device.	§ contract performance§ legitimate interests (to allow us to provide and improve our services)
to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting.	§ consent (which can be withdrawn at any time)
to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners.	§ consent (which can be withdrawn at any time)
We may also combine the information that we collect and hold about you for the purposes of creating insights about you and customer segmentation.	§ contract performance§ legitimate interests (to allow us to perform our obligations and provide services to you)
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.	§ contract performance§ legal obligation§ legal claims§ legitimate interest (to allow us to guard against fraud and other unlawful activity)

14. Sensitive personal information

14.1 Under the GDPR, certain categories of personal information are considered particularly sensitive and need higher protection. These categories include information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership or your sexual orientation and genetic and biometric data. Information concerning criminal convictions and offences is also viewed as sensitive under the GDPR.

14.2 We will typically ask you for your consent when collecting and handling this type of personal information, unless we are otherwise permitted to process such personal information under the GDPR or the laws of the EU member state in which you are based.

15. Other rights available under European Law

15.1 If you are based in the EEA during your interactions with us in addition to the rights outlined above, under certain conditions, you may have the right under the GDPR to ask us to:

(a) provide you with further details on how we use and process your personal information;

(b) delete personal information we no longer have grounds to process; and

15.2 In addition, under certain conditions, you have the right to:

(a) where processing is based on consent, withdraw the consent;

(b) lodge a complaint with a supervisory authority;

(c) object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms; and

(d) object to direct marketing (including any profiling for such purposes) at any time.

15.3 You can exercise these rights by contacting us.

15.4 These rights are subject to certain exemptions to safeguard the public interest and our interests. We will respond to most requests within 30 days.

16. Retention period under GDPR

16.1 Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When personal information is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.

17. Disclosure of information outside the EEA

17.1 Where we transfer personal information from inside the EEA to outside the EEA, we may be required by law to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will use appropriate safeguards to protect any personal information being transferred, such as EU Commission-approved model contractual clauses or binding corporate rules permitted by applicable legal requirements.

United States – California – Section

18. Introduction

18.1 If you are a consumer located in California, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This section provides additional details about the personal information we collect and use for purposes of CCPA.

19. Information we collect

19.1 This section describes the personal information we may have collected about you, including the categories of sources of that information. We collect this information for the purposes described in the Privacy Statement. We share this information as described in the Privacy Statement.

20. Rights

20.1 As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

(a) Exercising the right to know: You may request the following information about the personal information we have collected about you:

(i) the categories and specific pieces of personal information we have collected about you;

(ii) the categories of sources from which we collected the personal information;

(iii) the business or commercial purpose for which we collected the personal information;

(iv) the categories of third parties with whom we shared the personal information; and

(v) the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

(b) Exercising the right to delete: You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.

(c) Exercising the right to opt-out from a sale: You may request to opt out of any “sale” of your personal information that may take place. We do not use, share, rent or sell the personal information for interest-based advertising. We do not sell or rent the personal information of users and visitors of our site.

(d) Non-discrimination: The CCPA provides that you may not be discriminated against for exercising these rights.

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