Privacy Policy

1. Who are we?

(a) Mapulus Pty Ltd ACN 672 974 239 (Mapulus) is a data management (mapping) service and operates in Australia. It is bound by the Privacy Act and the APPs and is an APP entity as defined in s 6(1) of the Act.
(b) For the purposes of this Privacy Policy, “Mapulus”, “we”, “us” and “our” refers to Mapulus and “you” and “your” refers to any individual about whom we collect personal information.

(a) This Privacy Policy describes our Personal Information handling practices and applies to each and every individual who uses our Website or Services. In the course of our business we may need to gather and use certain Personal Information about you. This Privacy Policy tells you how we will use and process your Personal Information and the measures we have put in place to ensure its adequate protection. In addition, it explains how you can opt out of certain uses of your Personal Information and what rights and options you have in relation to how we use your Personal Information.
(b) By accepting the terms and conditions when using our Website or Services, or providing us with Personal Information, you will be deemed to have consented to us collecting, using, and disclosing your Personal Information (within and outside Australia) in accordance with this Privacy Policy.
(c) If this Privacy Policy is not acceptable to you, please do not use our Website or Services.

3. Definitions

For the purposes of our Privacy Policy:

APP	means the Australian Privacy Principles set out in Schedule 1 of the Privacy Act.
Device Data	means device data and information from your computer, phone, tablet, or other devices you use to access the Services.
Location Data	means data such as information about your device’s location through GPS and other technologies to collect geolocation data.
Log and Usage Data	means service-related, diagnostic, usage, and performance information our servicers automatically collect when you access or use our Services and which we record in log files.
Personal Information	has the meaning given under the Privacy Act, but generally includes information or an opinion about an identified individual, or an individual who is reasonably identifiable.
Privacy Act	means the Privacy Act 1988 (Cth) including the APPs and any amendments to the Privacy Act or APPs from time to time.
Privacy Policy	means this document as amended from time to time.
Services	means the services provided by us, including data management (mapping) services.
Social Networking Sites	means the social networking sites operated or utilised by us, including Facebook, Instagram, LinkedIn, YouTube and Twitter.
Spam Act	means the Spam Act 2003 (Cth).
Third Parties	means Mapulus business transfers, Google Maps APIs or other users of our Services that may view information shared by you.
Website	means all websites operated and utilised by us, including (without limitation), https://www.mapulus.com/.

4. What Personal Information we collect and why do we need it?

(a) To provide you with our Services, we need to collect Personal Information. We only collect Personal Information to the extent that it is reasonably necessary for one or more of our functions or activities and in accordance with this Privacy Policy. We regularly review our data collection, storage, and processing practices to ensure that we only collect, store, and process the Personal Information needed in connection with the uses set out in this Privacy Policy.
(b) All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
(c) If you do not provide us with your Personal Information as requested, or if the information is incomplete or inaccurate, we may not be able to provide our Services to you or the standard and quality of those Services may be compromised.
(d) Depending on the nature of the Services we provide to you, the Personal Information we collect may include, without limitation:
- (i) your name;
- (ii) job title;
- (iii) email addresses;
- (iv) telephone numbers;
- (v) mailing addresses;
- (vi) billing addresses;
- (vii) contact or authentication data;
- (viii) contact preferences;
- (ix) debit/credit card numbers;
- (x) social media details;
- (xi) occupations;
- (xii) payment details;
- (xiii) Log and Usage Data;
- (xiv) Device Data;
- (xv) Location Data;
- (xvi) your username and password if you register an account on our Website; and
- (xvii) information associated with your internet protocol address.
(e) We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLS, device name, country, location, information about how and when you use our Services, and other technical information. We primarily collect this information for the purpose of maintaining the security and operation of our Services, and for our internal analytics and reporting purposes.
(f) The information we automatically collect includes:
- (i) Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
- (ii) Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- (iii) Location Data: We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
(g) We may also collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/en-au/privacy.

5. How do we collect the Personal Information?

5.1 Directly from you

(a) We aim to collect Personal Information directly from you unless it is unreasonable or impracticable to do so. Generally, we collect your Personal Information when you complete and submit a form, make inquiries, or use our Services. We may also collect Personal Information, without limitation:
- (i) from your computer, phone, tablet or other devices you use to access the Services;
- (ii) through GPS and other technologies to collect geolocation data;
- (iii) from debt collection agencies if you default in a payment to us;
- (iv) through our Website and other Social Networking Sites;
- (v) from Third Parties;
- (vi) from publicly available sources of information;
- (vii) when we are required to do so by law; or
- (viii) when you enter a competition or promotion with us, participate in a survey, or register to receive information on us or any of our Services.
(b) If at any time you supply Personal Information to us about any other person, you represent (and we accept that information on the basis) that:
- (i) without us taking any further steps as required by the Privacy Act, we may collect, use and disclose such Personal Information for the purposes set out in this Privacy Policy; and
- (ii) you are authorised to provide us with such Personal Information and that the relevant person has consented to the disclosure to us.

5.2 Our website

(a) We collect aggregate information about you and your use of our Website whenever you visit us online. This includes various forms of ‘click stream’ information, e.g. entry and exit points for our Website, your Internet Protocol (IP) address, site traffic statistics, page views, impressions, operating system and browser type.
(b) We also use third-party software that tracks access to our Website from affiliated websites and purchases that result from this access. This aggregate information generally will not identify you.
(c) We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregated or de-identified information that does not contain Personal Information.

6. How do we hold Personal Information?

(a) We store information in paper-based files or other electronic record keeping methods in secure databases. Personal Information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your Personal Information from misuse, interference, and loss and from unauthorised access, modification or disclosure.
(b) We maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

7. How do we use your Personal Information?

The purposes for which we may use and disclose your personal information will depend on the Services we are providing you. All data is processed by the business on a lawful basis. In addition to any other purposes set out in this Privacy Policy, we may use the Personal Information we collect to:

(a) process your inquiries;
(b) provide our Services and other services, including the use of a third party service provider;
(c) comply with our contractual and other legal obligations;
(d) process payments;
(e) develop and improve our Services;
(f) better understand the people that have an interest in our products and services so that we can identify others that might have similar interests;
(g) share your information with vendors, and others who help us operate our business or provide services on our behalf, including the production or transmission of marketing materials;
(h) comply with our contractual and legal obligations and to protect and enforce our legal rights;

(i) verify your identify and respond to your correspondence when you submit comments, questions or suggestions to our customer service department;
(j) protect and defend our, or our employees’, users’ and clients’ rights or property including against fraudulent or unlawful use of our Website or Social Networking Sites;
(k) to create a convenient and easy-to-use online reservation service or shopping process including an online “shopping cart” that allows you to track selected services or products and proceed through purchase; and
(l) advise you of additional services, offers, or information which may be of interest to you.

8. When we may disclose your Personal Information?

We will not disclose your Personal Information for a purpose other than those connected with the primary purpose of collection, as set out in this Privacy Policy. Such purposes may include disclosing your Personal Information to third parties in certain circumstances as follows:

(a) if you agree to the disclosure;
(b) for the purpose for which it was collected, e.g. to provide you with Services; where you would reasonably be expected to consent to information of that kind being passed to a third party;
(c) where disclosure is required or permitted by law, by court order or to investigate suspected fraud or other unlawful activity;
(d) where it is required to be disclosed for audit purposes;
(e) as is necessary to process credit card payments or other purchasing or delivery systems;
(f) if disclosure will prevent or lessen a serious or imminent threat to someone’s life or health; or
(g) where we believe disclosure is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

9. Your Personal Information and marketing

9.1 General

(a) We may use and disclose your Personal Information to provide you with information on offers, products and services offered by Mapulus and you expressly consent to us doing so. We may also provide you with information on other products and services offered by Mapulus, its partners or affiliates.
(b) You may elect not to receive direct marketing communications from us by following the opt out instructions below. Please note that even if you have requested not to receive further direct marketing communications, we may nevertheless continue to provide you with information about changes to our terms and conditions for the supply of goods or services, questionnaires, and other factual information, as permitted under the Privacy Act and Spam Act.

9.2 Tracking tools

(a) ‘Cookies’ are pieces of information stored within your computer’s or device’s internet browser that automatically identify your browser to our server whenever you interact with our Website. We use cookies to help us understand the content that you are shown while visiting our Website. We may combine information which we obtain through the use of cookies with other information, including a unique identifier we have assigned to you, with information we obtain from third party sources.
(b) We use browser-based cookies, users’ IP addresses and other technologies such as ‘pixel tags’, ‘web beacons,’ ‘clear GIFs’ or similar technologies to help us and third parties obtain information about your visits to our Website, deliver online and mobile ads and content for us and others specific to your interests, process your purchases or requests, or to analyse your visiting patterns, measure the effectiveness of our and others’ advertising, monitor traffic patterns on our Website, and to optimise and enhance your online experience on our Website.
(c) You may customise your browser settings to notify you when a cookie is sent or to disable cookies altogether. The ‘Help’ feature on your browser should include instructions on how to make these adjustments.
(d) If you block or otherwise disable cookies, certain features on our Website may not function properly and you will not be able to hold selections in a shopping cart when you leave our Website without checking out, or use any of our Services that require you to sign in. Some of the tracking we have described may continue even if you disable or block cookies.

9.3 Internet-based online ads

(a) From time to time we may engage in interest-based advertising provided by third party vendors to deliver advertisements and personalised content that may be of interest to you. Ads may be delivered to you based on your online or mobile behaviour (on our Website and other websites), your search activity, your geographic location or other information, not on the basis of the Personal Information you have provided to us. For example, if you make a reservation on our Website, you may later see our ad on another website or on mobile platforms. You may also see third-party ads on our Website, other websites, or mobile apps, based on your visits to and activities on our Website, other websites and mobile apps.
(b) More information on interest-based advertising and opting out is available at https://www.aboutads.info.

9.4 Opting out

If at any time you no longer wish to receive any additional marketing or survey material from us or do not want your information disclosed for direct marketing or survey purposes, contact our Privacy Officer using the details in paragraph 15 below and we will remove your details from our marketing database.

10. How can you access or seek correction of your Personal Information?

(a) You are entitled to access your personal information held by us and seek correction of it at any time by request to our Privacy Officer using the details in paragraph 15 below. We will require formal identification by you before release or amendment of any Personal Information.
(b) You will not be charged for making a request to access your Personal Information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
(c) We will take reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
(d) However, if you consider any Personal Information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
(e) We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your Personal Information about the requested correction.

11. Is your Personal Information disclosed outside of Australia?

(a) We work with clients, service providers, sponsors, and commercial interests across the globe. It is likely that your Personal Information will be disclosed to overseas recipients.
(b) Unless we have your consent, or an exception under the APPs applies, we will only disclose your Personal Information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.
(c) Entities which are related entities of Mapulus, or are otherwise affiliated Mapulus, have operations in United States, Canada, United Kingdom, and European Economic Area. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be in in the regions in which we operate.

12. Relevant considerations when you send information to us electronically

(a) While we take such steps as are reasonable in the circumstances to protect your Personal Information from misuse, loss, unauthorised access, modification, or disclosure, including investing in security software, no data transfer over the internet is 100% secure.
(b) The open nature of the internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, it is sent at your own risk.
(c) Please be aware that we provide links to third-party websites as a service to our users, and that we are not responsible for the content or information collection practices of those pages. Please note that these websites’ privacy policies may differ from our Privacy Policy. We encourage you to review and understand their privacy practices before providing them with information.
(d) In the event of a security breach leading to accidental loss, disclosure or access to your Personal Information, we will comply with all our Privacy Act obligations including notifying you of such breach where required by law to do so.

13. What are your rights regarding your Personal Information?

(a) You may:
- (i) withdraw any consents given in relation to the handling by us of your Personal Information;
- (ii) request access to your Personal Information;
- (iii) request that we correct Personal Information that is inaccurate or out of date; or
- (iv) request that we delete certain Personal Information,
(b) By contacting our Privacy Officer using the details in paragraph 15 below. We will take reasonable steps, consistent with our obligations under the Privacy Act, to correct or delete that information if you so request. For security purposes, before we provide you with any Personal Information, we will ask you to provide evidence of your identity.
(c) You may request the source of any Personal Information we collect from a third party. We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld.
(d) If there is a reason under the Privacy Act or other law for us not to provide you with any of your Personal Information, we will give you a written notice of refusal setting out the reasons for the refusal (except to the extent it would be unreasonable or unlawful to do so) and advise you of the mechanisms available to you to complain about the refusal.
(e) You may request the source of any Personal Information we collect from a third party. We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld.
(f) You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
(g) You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
(h) The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
(i) If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
(j) In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
(k) If you are not satisfied with our response to your complaint, or you consider that we may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

14. How will we keep up to date with handling your Personal Information?

We may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

15. How may you contact us regarding any queries or concerns?

If you would like further information on our Privacy Policy or if you have any concerns or complaints over the protection of the Personal Information you have given to us or that we have collected from others, please contact us by contacting our Privacy Officer at:

Attention:	The Privacy Officer
Email:	[email protected]