1.1 This Privacy Policy (Policy) sets out, in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) and where relevant, the General Data Protection Regulation (GDPR), the way in which Fed Global Pty Ltd ACN 631 333 205 (Fed Global, our, us, or we) may collect, store, use, disclose, manage and protect your Personal Information.

1.2 Fed Global own and operate a lifestyle and organisation website located at fromgreatbeginnings.com (Website) and a mobile application called ‘Picket’ (App) that provides home budgeting and organising solutions including meal planning and sharing, as well as Do It Yourself project ideas (services).

1.3 By:

(a) accessing, subscribing to, downloading or using the services;
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(b) purchasing products or services from us;
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(c) requesting information on, enquiring about, or providing feedback in relation to, our services (online, in writing, by telephone or in person);
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(d) otherwise providing, or consenting to the collection of, Personal Information by Fed Global, its officers, agents or employees, after this Policy has been brought to your attention, you acknowledge and consent to the use, collection, storage or disclosure of your Personal Information by us in accordance with this Policy and the Privacy Act.

1.4 If you do not agree to us handling your Personal Information in the manner set out in this Policy we will not be able to provide our services to you and you should not provide us with any Personal Information.

1.5 Our Data Breach Policy forms part of this Policy and sets out our approach to any data breach.

2.1 We follow the definition of Personal Information given in the Privacy Act:“Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

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

3.1 The Personal Information we may collect, hold and process about you depends upon how you interact with us. This information may vary depending on the specific needs of Fed Global, however, it may include your:

(a) name and date of birth;
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(b) your contact details (e.g. address, email address, telephone number and other contact information);
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(c) your iTunes of Play Store identification details;
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(d) your financial details;
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(e) Sensitive Information (as that term is defined in the Privacy Act);
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(f) content and information you enter into or upload to our Website or App;
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(g) business or associated companies or entities;
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(h) messages, emails, voicemail and other correspondence and frequency of enquiries;
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(i) comments and feedback and responses to surveys;
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(j) interaction with websites, including our Website and App;
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(k) information about how you use our Website and App;
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(l) what computer and mobile phone configurations and software you use;
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(m) your IP address and / or other device identifying data;
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(n) general preferences and interests;
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(o) billing and credit card information;
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(p) other information required to provide a service or information you have requested from us;
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(q) information collected by Cookies, Web Beacons and other technologies; and
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(r) any additional information relating to you that you provide to us directly.

4.1 We collect Personal Information:

(a) directly from you, for example when you provide that information to us, we contact you or when you contact us;
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(b) when providing our services;
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(c) when you participate in our services, including marketing or promotional activities;
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(d) from publicly available sources such as the internet and social media.

5.1 We store your Personal Information digitally (unless legally required to retain in hard copy format).

5.2 All digital material is secured using password protected computers and databases. All financial information (such as credit card details, account details) are encrypted. Any digital transfer of Personal Information is via secure channels such as HTTPS where possible and user passwords are encrypted using a one-way hash.

5.3 Any database we manage is appropriately secured behind firewalls.

5.4 We primarily use data storage providers located inside Australia. However some data may potentially be stored overseas, most likely the United States, due to the use of third party services from businesses that originate in the United States. Where appropriate, Fed Global has agreements with its storage providers to keep all Personal Information they store secure, using reasonable and appropriate security methods.

5.5 We conduct regular audits of our compliance with this Policy and the Act to ensure that our privacy framework is in line with industry best-practice.

5.6 The Data Breach Policy is a component of, and supports, our Privacy Policy. Refer to our Data Breach Policy at Data Breach Policy on how we will manage any loss or unauthorised access or disclosure of your personal information should it ever occur.

6.1 We collect Personal Information for a number of reasons, including:

(a) providing you with our services or information about our services and activities;

(b) to promote and drive engagement with our services, including the use of targeted online advertising (see clause 8);

(c) to send push notifications to your mobile device. You can use the settings on your mobile device to enable or turn off mobile push notifications from the “Picket” App;

(d) sending communications you request or contacting you and responding to your enquiries;

(e) providing third parties with information about you and your activities to assist us in providing the services;

(f) cooperating with law enforcement bodies and government agencies where required by law or the terms of any relevant licence or industry code of practice;

(g) communicating with you and providing you with information about your use of the services;

(h) ensuring consistency of service across our business and other internal business purposes;

(i) developing or refining our services and activities as well as tailoring our services;

(j) notifying you about changes to our website, App, services, or activities we offer or provide via our website and App;

(k) internal business purposes;

(l) providing you with marketing material or contacting you in relation to our business, networking or promotional activities;

(m) publishing testimonials you provide us;

(n) for payment processing; and(o) internal corporate purposes, corporate governance, auditing and record keeping.

6.2 Our use of Personal Information may extend beyond the uses described above in clause 6.1, but will be restricted to purposes that we consider to be related to our functions and activities.

7.1 If we collect Personal Information, we may:(a) use that information for the purposes stated in this Policy and directly related purposes;

(b) store that information in accordance with this Policy;

(c) pass that information amongst entities we work with, associated organisations, business partners or affiliates;

(d) pass that information to third parties who provide products or services to us (including our accountants, auditors, lawyers, IT contractors, and other service providers); and

(e) provide that information to third parties as required or allowed by law;

(f) we may also disclose your de-identified information to third parties for analysis, research and quality assurance purposes.

8.1 We may use your Personal Information to communicate directly with you to promote our services.

8.2 We use direct marketing to provide you with information about our services.

8.3 If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable.

8.4 Please be aware that unsubscribing from one part of our services (for example, a newsletter) will not automatically remove you from all other services.

8.1 We may use your Personal Information to communicate directly with you to promote our services.

8.2 We use direct marketing to provide you with information about our services.

8.3 If you receive direct marketing material from us, and do not wish to continue receiving it, please contact us by any of the methods stated in this Policy, asking to be removed from all future direct marketing programs. Once we have received your opt-out request, we will remove you from our direct marketing programs as soon as reasonably practicable.

8.4 Please be aware that unsubscribing from one part of our services (for example, a newsletter) will not automatically remove you from all other services.

10.1 Fed Global is a South Australian based organisation however our data may be stored in cloud back up software (such as Office 365, MailChimp, Dropbox, Firebase, Google Cloud Platform, Zero and Salesforce) which may be potentially be stored overseas, most likely in the United States of America. For more details, please refer to paragraph 5.4.

10.2 We may upload images and / or footage to our App, social media accounts or website from time to time. The App, social media accounts and website may be hosted on an overseas server. Where applicable, in the event that your information is sent overseas, we will use our best endeavours to ensure that any overseas supplier will keep all Personal Information secure.

11.1 You may request access to the Personal Information that we hold about you by contacting us. Upon receiving an access request we may request further details from you to verify your identity.

11.2 We reserve the right not to provide you with access to Personal Information if we cannot verify your identity to our reasonable satisfaction. An administrative fee may be charged to cover our costs in providing you with access to your Personal Information. This fee will be explained to you before it has been incurred.

11.3 We will respond to your access request within a reasonable period of time by:

(a) providing you with access to your Personal Information;
(b) rejecting your access request, and providing you reasons for this rejection.

11.4 Access requests may be denied where:

(a) we believe your request is frivolous or vexatious;
(b) we are entitled to reject a request by law;
(c) we are unable to verify your identity; or(d) you have not paid the administrative fee (if any).

11.5 If you believe that the Personal Information that we hold is inaccurate or otherwise requires correction, you may send us a correction request by contacting us. We will review your Personal Information and respond to the request within a reasonable period of time.

12.1 Health information, information about your race, gender, sexuality or political opinions and affiliations are a special type of Personal Information under the Privacy Act called ‘Sensitive Information’. You have additional rights in relation to Sensitive Information.

12.2 For the purpose of this paragraph 12 and paragraph 3.1(e) ‘Sensitive Information’ includes information about your prescription medication or medically diagnosed dietary requirements. We will only keep your Sensitive Information whilst you consent to us doing so, or if we are required to by law or to protect a legal right. If you want us to delete your Sensitive Information you may request we do so in writing.

When contacting us, you can do so either anonymously or by using a pseudonym. If you do so, we may not be able to provide you with accurate or useful information, and you may not be able to access a full range of our services. Further, we may not be able to investigate incidents or complaints you have made.

From time to time we may make changes to this Policy. When we do, we will highlight those changes in yellow highlight for a period of 14 days. Please make sure you review the Privacy Policy each time you visit our App or website to keep up to date on any changes.

15.1 The GDPR is the European Union (EU) data protection law. Australian-based organisations that offer goods or services to persons in the EU or target or monitor the behaviour of persons in the EU may be required to comply with the GDPR regulatory regime.

15.2 We are an Australian based organisation providing products and services within Australia. From time to time, we may capture or collect Personal Information that passes through the EU. This might occur, for example, if a person in the EU accesses our website and we collect analytical data about them, if a person in the EU subscribes to our App, enquiries about our services from the EU, or if one of our customers gives us information about a person in the EU. If this occurs, we will treat the Personal Information received in accordance with this Policy.

15.3 Where data is processed or monitored in the EU, you may have additional rights, such as:

(a) The right to request that we delete your Personal Information (unless we require that information to comply with a legal obligation, or need it to bring or defend a legal claim); and

(b) The right to restrict our processing of your Personal Information (where it is inaccurate, would be unlawful to process, or where it has not been deleted due to us needing it to meet a legal obligation).

16.1 If you have a question or complaint, you can raise it with us by:

Email: privacy@picketfeds.com; or
Post: Privacy Officer
PO BOX 220
SURREY DOWNS SA 5025

16.2 We take all complaints seriously and will respond to you within a reasonable period of time, usually 30 days, unless we consider your complaint to be frivolous or vexatious or if we are unable to verify your identity.

16.3 If you are not satisfied with the way we have handled your complaint, you can make a complaint to the Office of the Australian Information Commissioner at http://oaic.gov.au.