Privacy Policy

SUMO is committed to managing Personal Information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

1. The Privacy Act currently defines “Personal Information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
   1. whether the information or opinion is true or not; and
   2. whether the information or opinion is recorded in a material form or not.
2. If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this Policy.

1. The Personal Information that we collect and hold about you depends on your interaction with us. When you visit the Site we will collect, use and hold your Personal Information if it is reasonably necessary for or directly related to the performance of our functions and activities. Generally, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. See the list below for more information about what Personal Information we collect and why.
   
   1. Device information:
      
      1. examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site;
      2. purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimise our Site; and
      3. source of collection: collected automatically when you access our Site using cookies.
   2. Order information:
      
      1. examples of Personal Information collected: name, billing address, shipping address, billing address, payment information (including credit card numbers and other payment details) email address, and phone number;
      2. purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services; and
      3. source of collection: collected from you.

   3. Candidate Talent Spotlight Profiles: Where you are a job candidate, SUMO may prepare an anonymized professional profile based on your recruitment assessment information, comprising your skills, work experience (by industry, role type, and years — not employer name), qualifications (without identifying institution names), preferred role type, availability, indicative salary range, and general location (city/region level). This anonymized profile may be shared with SUMO's client network and referral partners, and published via public channels including LinkedIn, SUMO's website, and newsletters, to market your availability to potential employers. 

      Your full name, current or previous employer names, and contact details will not be included in your Talent Spotlight profile unless you give separate, express consent. Before distribution, SUMO assesses re-identification risk and applies additional safeguards (generalizing, redacting, or delaying release) where needed. You may withdraw this consent at any time by contacting SUMO; your profile will be removed from active distribution within 3 business days, and SUMO will notify any client or partner who has already received it that your consent has been withdrawn.
2. We also collect your Personal information for the purposes of:
   
   1. providing you with promotional material and information about other products and services that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you;
   2. facilitating our internal business operations, including the fulfilment of any legal requirements; and
   3. analysing our products, services and customer needs with a view to developing new or improved products and services.
3. By using our Site, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information directly from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.

1. We may collect Personal Information from you whenever you input such information through our Site.
2. Personal Information will generally be collected directly from you through the use of our standard forms, over the internet via accessing our Site, via email, or through a telephone or in-person conversation with you. There may, however, be some instances where Personal Information about you will be collected indirectly because it is unreasonable or impractical to collect Personal Information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
3. If the Personal Information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the products or services you, or they, are seeking.
4. If you wish to deal with us anonymously (or by providing a pseudonym) we will be unable to provide you with the products or services you are seeking.

1. Our Site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that SUMO is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our Site, to read the privacy statements of each website that collects Personal Information.
2. Our Site may use web beacons from time to time. Web beacons or clear gifs are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. When you visit the Site, certain information may be collected such as browser type, and operating system.
3. We also collect Personal Information via cookies from your computer which enable us to identify when you use the Site and to help customise your experience. As a general rule, however, it is not possible to identify you personally from our use of cookies, but they may link back to a database record about you.
4. A cookie is a small amount of information that is downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you do not have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it is their first time visiting or if they are a frequent visitor.
5. You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
6. Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser's “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser's help file or through such sites as www.allaboutcookies.org.
7. Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners.
8. We also use Google Analytics to help us understand how our customers use the Site. Google Analytics anonymously tracks how users interact with the websites, including where they came from, what they did on the websites and whether they completed any transactions on the websites. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt- out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
9. For more information about how targeted advertising works, you can visit the Network Advertising Initiative's educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
10. You can opt out of targeted advertising through:
    1. Facebook - https://www.facebook.com/settings/?tab=ads
    2. Google - https://www.google.com/settings/ads/anonymous
11. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: http://optout.aboutads.info/

1. Upon agreeing to purchase products or services from our Site, we may offer deferred payment terms and collect and hold various types of credit related information such as:
   1. your current and prior names, date of birth, residential and business addresses, age, occupation (including the name of your employer) and your driver's license number;
   2. that you have applied for consumer or commercial credit (including the name of each relevant credit provider), the type and amount of that credit and the fact we have accessed your consumer credit information to assess a relevant application;
   3. that we are or have been a provider of credit to you and the type, characteristics and maximum amount of credit that we have provided or will provide;
   4. the date that any credit contract we or have or had with you was entered into and the date that it is terminated or otherwise ceases;
   5. your repayment history;
   6. whether in our opinion you have committed a serious credit infringement;
   7. whether you have entered into arrangements with us in connection with credit provided to you;
   8. court proceedings information, personal insolvency information and credit-related publicly available information;
   9. scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us wholly or partly on the basis of the information above; and
   10. certain administrative information relating to credit, such as account and customer numbers.
2. We will only collect Personal Information and use and disclose your credit information as reasonably necessary for our business purposes and as permitted by law, which may include:
   1. to form decisions as to whether to provide you, or an entity associated with you, with credit or to accept you as a guarantor;
   2. to derive scores, ratings, summaries and evaluations relating to your credit worthiness which are used in our decision-making processes and ongoing reviews;
   3. to assist you to avoid defaulting on your credit-related obligations;
   4. to undertake debt recovery and enforcement activities, including in relation to guarantors, and to deal with serious credit infringements; and
   5. to deal with complaints and meet legal and regulatory requirements.

1. Generally, we only use or disclose Personal Information about you for the purposes for which it was collected (as set out above) or where we are permitted or required to do so by law. We may disclose Personal Information about you to:
   1. service providers, who assist us in operating our business, and those service providers may not be required to comply with our privacy policy;
   2. our related entities and other organisations with whom we have affiliations so that those organisations may provide you with information about services and various promotions; and
   3. our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.
2. Unless otherwise provided for, Personal Information is only supplied to a third party when it is required for the delivery of our products or services, which includes offering products for sale, processing payments and fulfillment of your order, and keeping you up to date on new products, services, and offers.
3. We may from time to time need to disclose Personal Information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, during legal proceeding or in response to a law enforcement agency request.
4. We may also use your Personal Information to protect the copyright, trademarks, legal rights, property or safety of SUMO, its customers or third parties.
5. Personal Information that we collect may from time to time be stored, processed in, or transferred between parties located in countries outside of Australia. Our data hosting providers include Amazon Web Services, HubSpot and Google who have servers located around the world. Our local computers and other devices may also store Personal Information in jurisdictions outside of Australia including the Philippines. We are not otherwise likely to disclose your Personal Information overseas, except as permitted by the Privacy Act, unless we otherwise advise you in writing. If your Personal Information is transferred to an overseas recipient, the overseas recipient will not be required to comply with the APPs and we will not be liable for any mishandling of your information in such circumstances.
6. Talent Spotlight profiles may also be disclosed to SUMO's clients and referral partners located in Australia and other countries, in accordance with Australian Privacy Principle 8 (APP 8) and the Philippine Data Privacy Act of 2012 (RA 10173). SUMO remains accountable for your information after such transfer.
7. We will not sell your Personal Information in the ordinary course of business. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our user databases, together with any Personal Information and other information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
8. By providing us with Personal Information, you consent to the terms of this Policy and the types of disclosure covered by this Policy. Where we disclose your Personal Information to third parties, we will request that the third party follows this Policy regarding handling your Personal Information, but we cannot guarantee such third parties will agree to do so.

1. SUMO is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. Such measures include storing all Personal Information in an encrypted manner consistent with best industry practice.
2. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot ensure that Personal Information that we collect will not be disclosed in a manner that is inconsistent with this Policy.

1. APP 12 permits you to obtain access to the Personal Information we hold about you in certain circumstances, and APP 13 allows you to correct inaccurate Personal Information subject to certain exceptions.
2. You may access the Personal Information we hold about you, upon making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making the request for access).
3. We may decline a request for access to Personal Information in circumstances prescribed by the Privacy Act, and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
4. If, upon receiving access to your Personal Information or at any other time, you believe the Personal Information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
5. If we refuse to correct your Personal Information, we will give you a written notice that sets out our reasons for our refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.
6. If you would like to obtain such access, please contact us as set out in clause 15 below.

1. If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as set out in clause 15 below. All complaints will be considered by our privacy officer and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem.
2. If we are unable to satisfactorily resolve your concerns about our handling of your Personal Information, you can contact the Office of the Australian Information Commissioner:
   1. GPO Box 5218
   2. Sydney NSW 2001
   3. enquiries@oaic.gov.au
   4. 1300 363 992
   5. oaic.gov.au

1. If you are an individual in a country in the European Economic Area (EEA), we may be required to comply with the EU General Data Protection Regulation 2016/679 (GDPR) which applies to us when processing the Personal Information of individuals (data subjects) who are in countries in the EEA in relation to offering you our products or services or if we monitor any of your behaviour when in those countries.
2. In some circumstances, the GDPR provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your Personal Information is handled in a manner inconsistent with that law.

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The most current version of this Policy is located on our website setupmyoffshore.com.au and can also be obtained by contacting our Privacy Officer at discover@setupmyoffshore.com.au

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact our privacy officer below:

1. SUMO AUS PTY LTD
2. ACN: 647 505 486
3. Shop 4/3 Breakfast Creek Road Newstead QLD 4006
4. 1300 561 433
5. discover@setupmyoffshore.com.au