COVENTURED PTY LTD
(ACN 619 157 729)
Your privacy is important to us.
In this privacy notice we explain our information practices, describe the way your information is collected and used by us and provide other information to show how we comply with the:
In this privacy notice, personal information and personal data are used interchangeably, unless otherwise specifically mentioned.
In this privacy notice, sensitive information and sensitive personal data are used interchangeably, unless otherwise specifically mentioned.
Consent is required for Coventured to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
By consenting to this privacy notice you are giving us permission to process your personal and sensitive data specifically for the purposes identified.
You may withdraw consent at any time by contacting us directly using the contact details below.
Who are We?
Coventured Pty Ltd (ACN 619 157 729) (Coventured) is an Australian-based company that was incorporated to help corporations and startup companies connect so they can find opportunities for pilots, partnerships, co-creation, vendor relationships, and investment.
Company and websites within scope
The following company and website is within scope for this privacy notice:
|Coventured Pty Ltd||www.coventured.com|
Unless specifically stated, we consider this website to be Australian-based website.
If you are at least 16 years of age, we will presume that you have the capacity to consent to:
If you are under the age of 16 years, we require written parental consent in order for you to use our websites and applications.
Personal data - GDPR
The GDPR defines personal data as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Sensitive Personal Data – GDPR
The following personal data is considered ‘sensitive’ and is subject to specific processing conditions:
Personal Information – APP
The APP defines personal information as any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses). If the information we collect personally identifies you, or you are reasonably identifiable from it, the information is taken to be personal information.
Sensitive Information – APP
The APP defines sensitive information as information relating to details about your race, ethnicity, politics, religious or philosophical beliefs, sexual preferences, health, genetics or criminal record.
Why does Coventured need to collect and store personal data?
We need to collect your personal data in order for us to provide you with a service, such as:
In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Also, in order to ensure that anyone who accesses our websites or applications can use and navigate them effectively, we collect the following website-related information:
In terms of being contacted for marketing purposes, Coventured will contact you for additional consent.
Will Coventured share my personal data with anyone else?
We may share your personal data with third-party service providers contracted to Coventured as well as Coventured corporate clients for the purpose of assisting us to provide to you the services available through our websites and applications. We will make the information we collect from you available to third parties:
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to you on our behalf or to us. When they no longer need your data to fulfil this service, they will dispose of your personal data in line with Coventured’s procedures.
How will Coventured use the personal data it collects about me?
Coventured will process (collect, store and use) the information you provide in a manner compatible with the GDPR and APP. We will endeavour to keep your information accurate and up-to-date, and not keep it for longer than is necessary. Coventured is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Coventured contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
What is the lawful basis for the processing of my personal data?
The table below describes the various forms of personal data we collect and the lawful basis for processing this data. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.
|Purpose of collection||Information category||Data collected||Purpose for collection||Lawful basis for processing||Data shared with?|
|To provide you with information||Subject matter information||Name, geographic location, email address, postal address.||To provide appropriate online or email information about products and services that you have requested.||Contractual fulfilment||Internally only|
|To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest.||Legitimate interest||Internally only|
|Telephone number||Follow-up to ensure requested information meets needs and identify further requirements||Legitimate interest||Internally only|
|Personal contact information as provided through website forms or any other means.||General mailing list subscription||Consent||Internally only|
|Use of our website||Subject matter information||Profile information, such as your username and password, picture/avatar, industry, interests and preferences.||To provide you with our services||Legitimate interest
|Transactional information||Transaction details – For Corporate Customers only. No transaction Information is collected or stored for Startups or general users of the Site||Name, physical or registered address, email address, telephone number, bank account details (for credit accounts), other medium of content delivery||To process purchase transactions for products and services with customers, and to ensure any transaction issues can be dealt with.
Documentation should any contractual legal claim arise
For accounting and taxation purposes
Internally and professional advisers
Internally and professional advisers
|Payment card data For Corporate Customers only. No Payment card data is collected or stored for Startups or general users of the Site||Cardholder name, credit card number, authorisation code, expiration date||To fulfil purchase requests using payment cards||Contractual performance||Credit card companies|
|Fulfilment information||Fulfilment data||Name, address(es), email address, contact details||Actual delivery of products or services, in physical or digital form, that you may have purchased from us.||Contractual performance||Internally and any third party logistics or supplier companies with whom we contract in order to fulfil these requirements.|
|Security||Security information||Website-related information, as described above, plus any other information that may be required for this purpose||To protect our websites and infrastructure from cyberattack or other threats and to report and deal with any illegal acts.||Legitimate interest||Internally, forensic and other organisations with whom we might contract for this purpose.|
|Communications||Contact information||Name, contact details, identification details||To communicate with you about any issue that you raise with us or that follows from an interaction between us.||Legitimate interest||Internally and, as necessary, with professional advisers.|
Storage of personal data
All of our websites and applications are hosted and accessed by our staff in Australia. In all these instances, we have appropriate contractual and security measures in place to ensure that personal and sensitive data is protected.
We use a wide range of Cloud Service Providers (CSP) as part of our processing environment. Unless we specifically state otherwise, we are, in respect of all the CSPs, the data controller.
Unless we specifically state otherwise, all of the CSPs that we use utilise Australian-located processing facilities.
We operate a data retention policy in respect of all data, whether paper-based or digital and those aspects of it relating to personal data are contained in the table above.
How long we keep your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or statutory 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 or 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.
We may retain certain information subsequent to the closing of your account, for example if it is necessary to fulfil our legal obligations or to exercise, to maintain security, to prevent fraud and abuse and to defend or enforce our rights. If you choose to close your account, your personal data will generally stop being visible to others on our Website within 30 days.
We will take reasonable steps to protect your information from loss, misuse, unauthorised disclosure or destruction, including by means of firewalls, password access, secure servers and encryption of your information.
In order to enable us to meet our obligations under the APP and GDPR and to ensure the operation of the websites and applications, we may need to allow our authorised staff and contractors access to your information. The staff and contractors are required by contract and policies to maintain the confidentiality of your information.
If you suspect any misuse or loss of, or unauthorised access to, your information, please let us know immediately.
We have what we believe are appropriate security controls in place to protect personal and sensitive personal data. Risk assessment, including assessing risks to the rights and freedoms of data subjects, is at the heart of our ISMS. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.
Your rights as a data subject
At any point while we are in possession of or processing your personal and/or sensitive personal data, you have the following rights:
All of the above requests will be forwarded on should there be a third-party involved (as stated above) in the processing of your personal data.
Can I find out the personal data that the organisation holds about me?
Coventured at your request, can confirm what information we hold about you and how it is processed. If Coventured does hold personal data about you, you can request the following information:
Will my personal data be disclosed overseas?
Your personal data may be disclosed to overseas recipients without first obtaining your written consent.
How may I update my information?
You may access and update or correct the information we hold about you whenever you choose to do so by using our contact details below.
Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information. If you make an access request, we will ask you to verify your identity.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
Users will generally be able to access and update their account details online. We request that you keep your information as current as possible so that we may continue to improve our services to you.
How may I contact Coventured?
You may want to contact us about the information we hold about you (including to correct any information) or to ask a question about our privacy notice or to make a complaint related to a breach by us of the APP or GDPR.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
You may do so by:
Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.
Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint.
If you are in the EU, you may contact the European Data Protection Supervisor (https://edps.europa.eu/) or your National Data Protection Authority.
If you are in Australia, you may contact the Office of the Australian Information Commissioner (http://www.oaic.gov.au/).
Last Updated: 25 May 2018