Consistently respects your privacy and is committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), or when you order or use our services, and tells you about your privacy rights and how the law protects you.
We will never sell your personal data to a third party.
This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.
Consistently follows the guidelines as detailed by the Office of the Australian Information Commissioner – https://www.oaic.gov.au/agencies-and-organisations/app-guidelines/
This Policy aims to give you information on how Consistently collects and processes your personal data, including through your use of this website, and any data you may provide through this website, or when you contact us or sign up to our newsletters, commission or order a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.
Our Chief Technical Officer (CTO) is responsible for overseeing questions in relation to this Policy. If you have any questions, including any requests to exercise your legal rights please contact the CTO using the details set out below.
Our full details are: Suite 1, 51B The Corso, Manly NSW 2095
This version was created in May 2018 and may be subject to further revisions.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any Special Categories of Personal Data about you or any information about criminal convictions and offenses.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel an order or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing or third-party direct marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or by unsubscribing from any communication you receive from us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer or account holder||Identity Contact||Performance of a contract with you|
|To process and deliver a service or order including: Manage payments, fees and charges Pass your details to a customer or administrative or technology providers in order to perform our services. Collect and recover money owed to us||Identity Contact Financial Transaction Marketing and Communications||Performance of a contract with you or with a customer Necessary for our legitimate interests (for tax and legal liability purposes, or to recover debts due to us)|
|To enable you to take part in a prize draw, competition or complete a survey||Identity Contact Profile Usage Marketing and Communications||Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Contact Technical||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity Contact Profile Usage Marketing and Communications Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity Contact Technical Usage Profile||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We may send you product or service renewal reminders close to the anniversary of taking up a product or service or other communications we are obliged to send under a legal or contractual obligation.
You may receive marketing communications from us if you have expressly requested information from us about our services, or purchased goods or services, or made an inquiry, or if you provided us with your details when you entered a competition or registered for a promotion. We will not, however, send you generic marketing about Consistently unless you have expressly consented to receive it.
We will seek your express opt-in consent before we share your personal data with any company outside of the Consistently group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time or by following the opt-out or unsubscribe’ links in any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service commission or order, warranty registration, product/service experience or other transactions, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In order to perform our services, we may transfer your personal data outside of Australia.
Many of our external third parties are based outside Australia so their processing of your personal data will involve a transfer of data outside the Australia.
Whenever we transfer your personal data out of Australia, we seek to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We seek to use third-party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers and employees (including Contact, Identity, Financial and Transaction Data) for SEVEN years after they cease being customers or employees for tax and legal liability purpose, but we also keep this information to make it easier for customers to make new, follow-on or repeat service orders. We will seek to renew consent for marketing communications on a periodic basis.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data as detailed below;
If you wish to exercise any of the rights set out above, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to: