SHARPER CLEANING PTY LTD Privacy Policy

SHARPER CLEANING PTY LTD (ACN 128 544 847) (“we”, “us”, “our”, “Sharper Cleaning” or the

“Company”) is committed to privacy protection. We understand the importance of keeping per-
sonal information private and secure. This privacy policy (“Privacy Policy”) describes generally how

we manage personal information and safeguard privacy. If you would like more information, please
don’t hesitate to contact us.

The Australian Privacy Principles

We will treat all personal information in accordance with any and all obligations that are bind-
ing upon us under the Privacy Act 1988 (Cth) (“Privacy Act”). The Privacy Act lays down 13 key

principles in relation to the collection and treatment of personal information, which are called the
“Australian Privacy Principles”.

What is “personal information”?

Personal information held by the Company may include your:
name and date of birth;
residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
bank account and/or credit card details for agreed billing purposes;
any information that you provided to us by you during your account creation process or added to
your user profile;
preferences and password for using this site and your computer and connection information; and
any information that you otherwise share with us.

How we may collect your personal information

At this site, we only collect personal information that is necessary for us to conduct our business as
a law firm that provides general information in summary form on legal and other topics, current at
the time of first publication or in providing a link or portal enabling users to create and purchase
thier own legal documents from a 3rd Party provider, which includes (without limitation) enabling
users to access a third party website where users can create and purchase legal documents based on
information that they provide.

Information that you provide to us

We may collect personal information that you provide to us about yourself when you:
use this site, including (without limitation) when you:
create a user account;
add information to your user profile;
purchase any products and/or services through this site;
add reviews, forum or chat room messages or comments in any elements of this site that permit
user-generated content;
register for access to premium content or request certain premium features; or
complete an online contact form to contact us;
provide information to us by telephone or through marketing or competition application forms; or
send us an email or other communication.
IP addresses
This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on

the internet to uniquely identify them within the global network. The Company collects and man-
ages IP addresses as part of the service of providing internet session management and for security

purposes. The Company may also collect and use web log, computer and connection information for
security purposes and to help prevent and detect any misuse of, or fraudulent activities involving,
this site.

Cookies

This site uses “cookies” to help personalise your online experience. A cookie is a text file or a packet

of information that is placed on your hard disk by a web page server to identify and interact more ef-
fectively with your computer. There are two types of cookies that may be used at this site: a persistent

cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies”
folder on your computer and remains in that folder after you close your browser, and may be used

by your browser on subsequent visits to this site. A session cookie is held temporarily in your com-
puter’s memory and disappears after you close your browser or shut down your computer. Cookies

cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a
web server in the domain that issued the cookie to you. In some cases, cookies may collect and store

personal information about you. The Company extends the same privacy protection to your person-
al information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when

a cookie is sent. Please refer to your internet browser’s instructions to learn more about these func-
tions. Most web browsers automatically accept cookies, but you can usually modify your browser

settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to
fully experience the interactive features of this site.

Why we use cookies

This site uses cookies in order to:
remember your preferences for using this site;
manage the signup process when you create an account with us;
recognise you as logged in while you remain so. This avoids your having to log in again every time
you visit a new page;
facilitate e-commerce transactions, to ensure that your order is remembered between pages during
the checkout process;
show relevant notifications to you (eg, notifications that are relevant only to users who have, or have
not, created an account or subscribed to newsletters or email or other subscription services); and
remember details of data that you choose to submit to us (eg, through online contact forms or by
way of comments, forum posts, chat room messages, reviews, ratings, etc).
Many of these cookies are removed or cleared when you log out but some may remain so that your
preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through this site. For example:

Google Analytics, one of the most widespread and trusted website analytics solutions, may use cook-
ies de-identified data about how long users spend on this site and the pages that they visit;

Google AdSense, one of the most widespread and trusted website advertising solutions, may use
cookies to serve more relevant advertisements across the web and limit the number of times that a
particular advertisement is shown to you; and

third party social media applications (eg, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Insta-
gram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this

site.

How we may use your personal information

Your personal information may be used in order to:
verify your identity;
assist you to place orders through this site;
process any purchases of products and/or services that you may make through this site, including
charging, billing and collecting debts;
make changes to your account;
respond to any queries or feedback that you may have;
conduct appropriate checks for credit-worthiness and for fraud;
prevent and detect any misuse of, or fraudulent activities involving, this site;
conduct research and development in respect of our products and/or services;
gain an understanding of your information and communication needs or obtain your feedback or
views about our products and/or services in order for us to improve them; and/or
maintain and develop our business systems and infrastructure, including testing and upgrading of
these systems,

and for any other purpose reasonably considered necessary or desirable by the Company in relation
to the operation of our business.
From time to time we may email our customers with news, information and offers relating to our

own products/services or those of selected partners. Your personal information may also be col-
lected so that the Company can promote and market products and services to you. This is to keep

you informed of products, services, and special offers we believe you will find valuable and may
continue after you cease acquiring products and services from us. If you would prefer not to receive
promotional or other material from us, please let us know and we will respect your request. You can
unsubscribe from such communications at any time if you choose.

When we may disclose your personal information

In order to deliver the products/services you require or for the purposes set out above, the Compa-
ny may disclose your personal information to organisations outside the Company. Your personal

information may be disclosed to these organisations only in relation to this site, and the Company
takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy
obligations in relation to the protection of your personal information. These organisations may carry
out or provide:
customer enquiries;
mailing systems;
billing and debt-recovery functions;
information technology services;
marketing, telemarketing and sales services;
market research;
document creation; and/or
website usage analysis.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold
about you, would like to opt out of any marketing communications or are concerned that we may
have breached your privacy, please contact us by email to [email protected] or by post.

Access to your personal information

In most cases, you may have access to personal information that we hold about you. We will handle

requests for access to your personal information in accordance with our obligations under the Aus-
tralian Privacy Principles. All requests for access to your personal information must be directed to

the Privacy Officer by email using the email address provided above or by writing to us at our postal
address. We will deal with all requests for access to personal information as quickly as possible.
Requests for a large amount of information, or information that is not currently in use, may require
further time before a response can be given. We may charge you a fee for access if a cost is incurred

by us in order to retrieve your information, but in no case will we charge you a fee for your applica-
tion for access.

In some cases, we may refuse to give you access to personal information that we hold about you.
This may include circumstances where giving you access would:
be unlawful (eg, where a record that contains personal information about you is subject to a claim
for legal professional privilege by one of our contractual counterparties);
have an unreasonable impact on another person’s privacy; or
prejudice an investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal
proceedings, and the information would not be accessible by the process of discovery in those
proceedings.
If we refuse to give you access, we will provide you with reasons for our refusal.

Correcting your personal information

We will amend any personal information about you that is held by us and that is inaccurate, in-

complete or out of date if you request us to do so. If we disagree with your view about the accuracy,
completeness or currency of a record of your personal information that is held by us, and you ask us
to associate with that record a statement that you have a contrary view, we will take reasonable steps
to do so.

Storage and security of your personal information

We are committed to maintaining the confidentiality of the information that you provide us and
we will take reasonable precautions to protect your personal information from unauthorised use or

alteration. In our business, personal information may be stored both electronically (on our com-
puter systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus

software and email filters, as well as passwords, protect most of our electronic information. Likewise,
we take reasonable measures to ensure the security of hard-copy information.

Third party websites

You may click-through or use third party websites from this site, in which case we recommend that
you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site
only and the Company assumes no responsibility for the content of any third party websites.

Re-marketing

We may use the Google AdWords and/or Facebook re-marketing services to advertise on third
party websites to previous visitors to this site based upon their activity on this site. This allows us to
tailor our marketing to better suit your needs and to only display advertisements that are relevant to
you. Such advertising may be displayed on a Google search results page or a website in the Google
Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to
achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their
own respective privacy policies. None of your personal Google and/or Facebook information is
reported to us.
You can set preferences for how Google advertises to you using the Google Ads Settings page
(https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you

to opt out of targeted advertising. You may also opt out of any marketing or promotional commu-
nication that we send you, simply by contacting us by email to [email protected] or

clicking on the opt out link on any communication we send to you.

GDPR

The Company welcomes the General Data Protection Regulation (“GDPR”) of the European Union
(“EU”) as an important step forward in streamlining data protection globally. Although we do not

operate an establishment within the EU and do not target any offering of services towards custom-
ers/clients in the EU specifically, we intend to comply with the data handling regime laid out in the

GDPR in respect of any personal information of data subjects in the EU that we may obtain.

GDPR rights

The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include
the following rights:
you are entitled to request details of the information that we hold about you and how we process it.
For EU residents, we will provide this information for no fee;
you may also have a right to:
have that information rectified or deleted;
restrict our processing of that information;
stop unauthorised transfers of your personal information to a third party;
in some circumstances, have that information transferred to another organisation; and

lodge a complaint in relation to our processing of your personal information with a local superviso-
ry authority; and

where we rely upon your consent as our legal basis for collecting and processing your data, you may
withdraw that consent at any time.
If you object to the processing of your personal information, or if you have provided your consent
to processing and you later choose to withdraw it, we will respect that choice in accordance with our
legal obligations. However, please be aware that:

such objection or withdrawal of consent could mean that we are unable to provide our services to

you, and could unduly prevent us from legitimately providing our services to other customers/cli-
ents subject to appropriate confidentiality protections; and

even after you have chosen to withdraw your consent, we may be able to continue to keep and pro-
cess your personal information to the extent required or otherwise permitted by law, in particular:

to pursue our legitimate interests in a way that might reasonably be expected as part of running our
business and which does not materially impact on your rights, freedoms or interests; and
in exercising and defending our legal rights and meeting our legal and regulatory obligations.
Storage and processing by third parties
Data that we collect about you may be stored or otherwise processed by third party services with
data centres based outside the EU, such as Google Analytics, Dropbox, Amazon Web Services,
Apple, etc and others providing, enabling or relating to the provision of online software/s for the
DIYL document creation and also relationship management tools. We consider that the collection
and such processing of this information is necessary to pursue our legitimate interests in a way that
might reasonably be expected (eg, to analyse how our customers/clients use our services, develop
our services and grow our business) and which does not materially impact your rights, freedom or
interests.
The Company requires that all third parties that act as “data processors” for us provide sufficient
guarantees and implement appropriate technical and organisational measures to secure your data,
only process personal data for specified purposes and have committed themselves to confidentiality.

Duration of retention of your data

We will only keep your data for as long as is necessary for the purpose for which it was collected,
subject to satisfying any legal, accounting or reporting requirements. At the end of any retention
period, your data will either be deleted completely or anonymised (for example, by aggregation with

other data so that it can be used in a non-identifiable way for statistical analysis and business plan-
ning). In some circumstances, you can ask us to delete your data.

Keeping your information up-to-date

To ensure that your personal information is accurate and up to date, please promptly advise us
of any changes to your information by contacting our data protection officer by email at admin@
sharper.com.au or by post.

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in
accordance with any applicable requirements under the Privacy Act and the Australian Privacy
Principles. We may notify you about changes to this Privacy Policy by posting an updated version on
this site.
* * * *
If you require any further information about the Privacy Act and the Australian Privacy Principles,
you can visit the Federal Privacy Commissioner’s website (see www.privacy.gov.au).
Melbourne Office:
13/21 Sabre Drive,
Port Melbourne, Victoria 3207
Tel: 1300 309 338
Email: [email protected]
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