privacy policy

This Policy was last reviewed and updated on: 27/02/2024

Friyay values and respects the privacy of the people we deal with. Friyay is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.

This Privacy Policy (Policy) describes how we collect, hold, use and disclose your personal information, and how we maintain the quality and security of your personal information.

What is personal information?

“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.

What personal information do we collect?

The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us.

The personal information we collect about you may include:

name
mailing or street address
date of birth
email address
phone number / mobile number

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you.

How do we collect your personal information?

We may collect your personal information directly from you when you:

interact with us over the phone
interact with us in person
interact with us online
participate in surveys or questionnaires
attend a Friyay event
subscribe to our mailing list
apply for a position with us as an employee, contractor or volunteer

Collecting personal information from third parties

We may also collect your personal information from third parties or through publicly available sources, for example from our partners such as IT providers, marketing providers. We collect your personal information from these third parties so that we can provide you with our services or products or otherwise interact with you.

How do we use your personal information?

We use personal information for many purposes in connection with our functions and activities, including the following purposes:

provide you with information or services or products that you request from us
deliver to you a more personalised experience and service offering
improve the quality of the services we offer
internal administrative purposes
marketing and research purposes

Disclosure of personal information to third parties

We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:

our third party service providers (for example, our IT providers)
our marketing providers

Transfer of personal information overseas

Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia, including in USA.

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:

you have given us your consent to disclose personal information to that third party; or
we reasonably believe that:

the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs; and
the law or binding scheme can be enforced; or

the disclosure is required or authorised by an Australian law or court / tribunal order.

How do we protect your personal information?

Friyay will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:

having a robust physical security of our premises and databases / records where relevant
taking measures to restrict access to only personnel who need that personal information to effectively provide services to you
having technological measures in place (for example, anti-virus software, fire walls)

Online activity

The Friyay website uses cookies. A cookie is a small file of letters and numbers the website puts on your device if you allow it. These cookies recognise when your device has visited our website(s) before, so we can distinguish you from other users of the website. This improves your experience and the Friyay website(s).

We do not use cookies to identify you, just to improve your experience on our website(s). If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies. However, if you remove or block cookies on your computer, please be aware that your browsing experience and our website’s functionality may be affected.

Website analytics

Our website uses [insert relevant analytics service] to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.]

Direct marketing

We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication / contacting us using the details set out in the “How to contact us” section below.

In addition, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising, including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites).

Retention of personal information

We will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.

How to access and correct your personal information

Friyay will endeavour to keep your personal information accurate, complete and up to date.

If you wish to make a request to access and / or correct the personal information we hold about you, you should make a request by contacting us and we will usually respond within 5 business days. We will deal with such a request by following the procedure outlined below:

Confirm the validity of the request by contacting you to confirm the request before we action it.
Action the request
Send confirmation to you that the request has been completed

Links to third party sites

Friyay website(s) may contain links to websites operated by third parties. If you access a third party website through our website(s), personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers / websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

OUR RESPONSIBILITIES UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the EU or UK you have certain rights and protections under the EU and UK GDPR regarding the processing of your Personal Data.

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:
– 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.
– 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. This includes where we email newsletters or send mobile phone notifications.
– 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.

Your rights as an EU or UK resident

If you are a resident of the EU or UK you have various rights including the:
– Right to be informed;
– Right of access;
– Right to rectification;
– Right to object;
– Right to restriction of processing;
– Right to erasure or to be forgotten;
– Right to data portability; and
– Right not to be subject to automated processing.

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.

Withdrawing your consent

You can withdraw your consent to our collection or processing of your Personal Data. You can do so by contacting us or by opting out of email newsletter communications by following the instructions in those emails, by clicking unsubscribe or by using the opt out option through our App. 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.

Our compliance

We comply with the GDPR protection directives set out by the EU and UK regarding the collection, use and retention of Personal Data from EU member countries and the UK. All Personal Data stored on our platform is treated as confidential. It is stored securely and is only accessed by authorized personnel. Our collection is limited in relation to what is necessary, for the purpose for which the Personal Data is processed, and kept only for so long as is necessary for the purpose for which the Personal Data was collected. We implement and maintain appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing or use, and against accidental loss, destruction, damage, theft or disclosure. We ensure the encryption and pseudonymisation of Personal Data and we have adequate cyber security measures in place.

Your acknowledgement

By providing us with your Personal Data, you consent to us disclosing it to third parties who reside outside the EU or UK. We will ensure that those third parties are GDPR compliant.

Inquiries and complaints

For complaints about how Friyay handles, processes or manages your personal information, please contact sha-mayne@friyay.ai.

Note we may require proof of your identity and full details of your request before we can process your complaint.

Please allow up to 15 business days for Friyay to respond to your complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with Friyay’s response to a complaint, you have the right to contact the Office of Australian Information Commissioner at https://www.oaic.gov.au/privacy/privacy-complaints/ to lodge a complaint.

How to contact us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows:

Email

sha-mayne@friyay.ai