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Privacy Policy

This is the Privacy Policy for Glow Solutions Pty Ltd ABN 94 659 218 710 dated 1 June 2023 (“Privacy Policy”).

By agreeing to this Privacy Policy pursuant to our Website Terms and Conditions (together or separately the “The Always Terms”), or as otherwise contemplated by this Privacy Policy:

  • You consent to our collection, use, storage, disclosure, sharing, and means of protecting your information, including any Personal Information, in accordance with the terms of this Privacy Policy; and
  • This Privacy Policy applies to the Glow Solutions Pty Ltd Website and all related sites, applications, Services, and tools regardless of how you access them; and
  • This Privacy Policy applies to any electronic communication that you have with Glow Solutions Pty Ltd.

This Privacy Policy is available at https://thealways.co/privacy-policy.

Definitions and interpretation

In this Privacy Policy, capitalized terms have special meanings. Please refer to the Glossary in section 11 for the meanings of these terms.

Words such as “include,” “including,” “for example,” “such as,” and similar terms are not terms of limitation and do not limit the scope of the relevant subject.

Parties bound

You accept this Privacy Policy in the ways described in The Always Terms.

In addition to clause 2.1, you accept this Privacy Policy upon the earliest occurrence of any of the following events:

  • you access the Website;
  • you submit any information to us using any feature (such as an enquiry form) on the Website;
  • you send information to us using any Electronic Communication;
  • you respond to any survey, poll, or other request for information conducted by, or on behalf of Glow Solutions Pty Ltd;
  • you upload any Content to the Website;
  • you access, use, or receive any Services from us.

We may amend this Privacy Policy at any time by posting a revised version on the Website. The revised version will be effective at the earliest occurrence of any of the events that apply to you in clause 2.2, and if none of those occur prior, then the amended version will apply 7 days after we post the revised version on the Website. For avoidance of doubt, the current version will remain in effect until the amended version takes effect.

Nothing in this Privacy Policy is to be read to impose any obligation on us beyond those required by the Australia Privacy Principles (“APPs”), or the Privacy Act 1988 (Cth).

You are responsible for the accuracy of any information that you provide to us for any purpose.

Upon accepting this Privacy Policy, its provisions apply to information about you that we hold and any information about you that we collect in the future.

What are the kinds of information that we collect

The information may include Personal Information, data on the pages you access, device identifiers, your location, standard web log data, Services related data, and other information as described in the following paragraphs of this clause 3.

Personal Information

Throughout this Privacy Policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider Personal Information to include information that has been made anonymous and does not identify a specific person (including a User). Personal Information has the meaning provided in the Privacy Act 1988 (Cth) from time to time, which at the time of writing is in the following form:

“information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not.”

Web log data

Web log data includes the browser type you’re using and traffic to and

from your browser or other access device.

In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with the Website. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity.

Services related data includes:

  • data relating to the activities relating to your use of the Website, or
  • details relating to any communication otherwise completed by, or in relation to, you through the Website or our Services.

Enquiries

If you submit a query or other information on the Website, we may collect the following types of information:

  • contact information, such as your name, address, phone, email, and other similar information;
  • detailed Personal Information, such as your date of birth or other personal identifiers.

Third-party data

We may also obtain any information about you from third parties such as credit bureaus, identity verification services, authentication services (for example, if you use Single Sign-on), inbound marketing service providers, online marketing platforms (such as Google or Facebook), social media platforms, and providers of web-tracking data.

Other information

We may also collect additional information from or about you in other ways, such as through our support team, results when you respond to a survey or poll, and from interactions with any other person through the Website, through any of our social media accounts, information that our sub-contractors collect from or about you, or in person or through Electronic Communication regarding our Services.

How do we collect and store information

Collection

We collect information that you provide to us when we communicate with you.

We collect information sent to us by your telecommunications carrier, internet provider, computer, mobile phone, or other access device when you:

  • contact us by phone;
  • receive or respond to messages from us or send messages to us using electronic systems, including without limitation Electronic Communications or others;
  • download information, scripts, code, data, images, media, tokens, and other types of Content from our servers;
  • navigate to the Website or any related pages with a web browser;
  • submit any information using an enquiry form or by any other method provided on the Website;
  • otherwise use the Website to obtain information or Services from us.

We collect web-tracking information from third parties about your information, product, and service preferences.

Storage

We store and process your Personal Information on our computers in Australia and our contract service providers’ computers in the United States of America and other foreign countries.

We may also store information on your computer or other access device using Cookies.

How do we use Cookies

When you access the Website or communicate with us electronically, we may place small data files on your computer or other device. These data files may be cookies, pixel tags, or other local storage provided by your browser or associated applications (collectively “Cookies”). We use Cookies to:

  • identify you as a User;
  • enable functionality on and customize the Website and related content;
  • measure promotional effectiveness;
  • mitigate risk and prevent fraud; and
  • promote trust and safety with our Users and the Website.

We may use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you end your session on the Website or close your browser. Persistent Cookies remain on your browser until you erase them or they expire.

We may encode our Cookies so that we can interpret the information stored in them. You are free to decline our Cookies if your browser or browser add-on permits, but doing so may interfere with your use of the Website.

We have no control over third-party Cookies

You may encounter Cookies on websites that we do not control (including those you may access from the Website), and we are not responsible for third-party

websites or Systems. For example, if you access a third-party website through a link on the Website, there may be one or more Cookies placed by the third-party web page or an application within it.

What are the purposes for which we collect, hold, use, and disclose information

Primary purpose

Our primary purpose in collecting Personal Information is to provide you with our Services and information about our Services.

Secondary purposes

We may also use your Personal Information for secondary purposes, including:

  • send direct marketing to you relating to us or our Related Entities (subject to clause 5.4);
  • provide the Website, our Services, and customer support;
  • resolve disputes, collect fees, and troubleshoot problems;
  • prevent potentially prohibited or illegal activities and enforce The Always Terms, which can be viewed at https://thealways.co/terms-and-conditions;
  • customize, measure, and improve the Website;
  • contact you:
    • at any telephone number you provide to us, by placing a voice call or through text (SMS); or
    • by email messaging at any email address that you provide to us; or
    • by any means of Electronic Communication as requested or agreed by you; or
  • compare information for accuracy and verify it with third parties;
  • any other purposes that are essential or incidental to the primary purpose and other secondary purposes set out above.

Consequences of not collecting information

If we cannot collect information from you for our primary purposes and, to the extent necessary, our secondary purposes, it will likely be impossible for us to provide you with our Services or information about our Services.

Direct marketing opt-out

If you do not wish to receive marketing communication from us, outside of the Website, then you may opt-out at any time by using the unsubscribe or opt-out feature contained in the communication that we send to you. Upon receipt of your opt-out request, we will no longer send you direct marketing information. Please note that such opt-out does not affect any direct information request that you have made or any correspondence relating to Services that we are providing to you or may provide to you as a result of communication from you.

Combined data

We may combine information that we collect from you with information we collect from third parties and use it to improve our Services and personalize your experience on the Website, personalize and optimize content served up or delivered to you, and personalize any advertising or marketing information displayed on our Website or sent to you by other means of communication. We may also use such combined data for enforcing our The Always Terms.

Aggregated data used for business development

De-identified information generated by the Website, which includes data relating to your use and use by others of the Website, is used by us for our internal business development purposes.

How and to whom do we disclose information

General

We may share (disclose or receive) your Personal Information with the following persons or classes of persons (each an “Authorized Recipient”):

  • Related Entities (as defined by the Corporations Act 2001 (Cth)).
  • Service providers under contract who help with our business operations, such as fraud prevention, bill collection, shipping and transport, marketing, analytics, tracking, and any other technology services.
  • Companies that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information could be used contrary to this policy, you will receive prior notice.
  • Law enforcement, government officials, or other third parties pursuant to subpoena, court order, or other legal process or requirements applicable to Glow Solutions Pty Ltd or any of its affiliates.
  • To law enforcement agencies or contractedinvestigators in relation to suspected fraud, intellectual property infringement, piracy, or any other unlawful activity or as otherwise required by law, in our sole discretion.
  • Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).
  • Companies that we in good faith believe are associated with you and may be of interest to you (to the extent you have not opted out of receiving such communications).

Social media

If you choose to log in to your account or access the Website using social media platforms (such as Facebook or Google), we may share your information with these third-party platforms. The treatment of your Personal Information by these third-party platforms is governed by their respective privacy policies.

How do we protect your Personal Information

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of your Personal Information. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store Personal Information. We restrict access to Personal Information to Glow Solutions Pty Ltd employees, contractors, and agents who need to know that information to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

How can you access and update your Personal Information

You can access and update your Personal Information by logging into your account on the Website. You may also request access to, or correction of, your Personal Information by contacting us at the contact details provided below. We may require you to verify your identity before providing access or making any changes to your Personal Information.

We will retain your Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Glossary

The following terms have these meanings:

  • “APPs” means the Australian Privacy Principles set out in Schedule 1 of the Privacy Act 1988 (Cth).
  • “Content” means all data, information, text, music, sound, photos, graphics, videos, advertisements, listings, and other materials on the Website.
  • “Electronic Communication” includes emails, SMS, MMS, IM, web-forms, web-chat, and any other form of Electronic Communication or electronic message.
  • “Personal Information” has the meaning provided in the Privacy Act 1988 (Cth).
  • “Privacy Act” means the Privacy Act 1988 (Cth).
  • “Related Entity” means a related entity as that term is defined in the Corporations Act 2001 (Cth).
  • “Services” means the services that we provide on or through the Website.
  • “System” means the systems (including software and hardware) used to provide, or through which are provided, the Website or Services.

For the complete Privacy Policy, please refer to https://thealways.co/privacy-policy.