General
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Silokeeper App is managed and operated by UPL Australia Pty Ltd (“we”, “us”
or “our”), a company incorporated under the laws of Australia, having its registered
office at Level 3, 70
Hindmarsh Square, Adelaide. South Australia 5000 We are an organisation and “APP Entity” for the
purposes of the Privacy Act (“Act”) and are bound by the Australian Privacy Principles
contained in the Act.
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The Silokeeper App is the mobile application made available by us to users
("User(s)"
(“you”)
for use in connection with the fumigation process for a silo and bunker using QuickPhos®
tablets,
and blankets (“App”).
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This privacy policy (“Privacy Policy”), together with the Terms of Use, governs your use
of
the App and describes our policies and procedures on the collection, use, disclosure,
processing,
transfer, and storage of your personal information, and outlines our approach to data protection
and privacy in order to fulfil our obligations under the Act.
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Personal information is essentially information or an opinion about an identified or reasonably
identifiable individual (“Personal Information”).
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By using, browsing, accessing, or purchasing the services offered on, the App, by providing us
your Personal Information, or by consenting through the App, you agree with the practices and
policies outlined herein and explicitly consent to the collection, storage, possession, dealing,
handling, sharing, disclosure or transfer of your Personal Information in accordance with the
terms of this Privacy Policy. We shall not use the User’s information in any manner except as
provided under this Privacy Policy or as required or permitted by law. Users have the option to
not use any of our services or provide us any of their Personal Information if they do not agree
with this Privacy Policy at any time, however if Personal Information is not provided it may
restrict the User’s ability to access certain parts or functions of the App.
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This Privacy Policy sets out the types of Personal Information collected from the Users, the
purpose, means and modes of usage of such information and how and to whom we may disclose
or transfer such information. You may at any time withdraw your consent for collection and use
of your Personal Information by contacting us using the details below. However, please note that
if you withdraw your consent, we may no longer be able to provide you with the corresponding
services for which you have withdrawn your consent.
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For the avoidance of doubt, your decision to withdraw your consent will not retrospectively
affect
any previous processing of Personal Information prior to the withdrawal of consent.
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Please take a moment to familiarise yourself with our Privacy Policy. If you do not agree with
any
provisions of the Terms of Use or this Privacy Policy, we advise you to not use or access the
App.
Type of Information Collected
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We may collect your Personal Information anytime you visit, access, use or browse the App. The
Personal Information that we may collect and hold about you depends on your dealings with us.
We may combine your Personal Information with other information in order to provide and
improve our services, content and advertising. With your consent, we may have access to your
SMS, instant messages, contacts in your directory, location, camera, photo gallery and device
information.
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You agree that any Personal Information you provide will be true, correct, up to date and
accurate. You may access or seek correction of your Personal Information using the process
described below.
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We may collect a variety of Personal Information from you, including your:
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name, email address, mailing address, and personal contact details (eg, telephone
number);
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gender;
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date of birth;
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login details and password; and
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images, videos and other content in connection with Services.
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The App is not directed towards minors. We do not seek Personal Information from any User who
is under 18 (eighteen) years of age. If we are made aware that we have collected the Personal
Information of a person below the age of 18 (eighteen) years, we will take steps to delete the
information within a reasonable time frame. If a parent or guardian becomes aware that his or
her
child has provided his or her Personal Information in the App without their consent, he or she
may
contact us to request the deletion of such information. If, in contravention of the Privacy
Policy
and Terms of Use, a person below the age of 18 (eighteen) years uses the services, we shall not
be
held liable or responsible for any damage or injury suffered by such person.
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We seek to only collect information that is necessary for operation of the App and provision of
our services. We will collect your Personal Information directly from you unless it is
unreasonable or impracticable to do so. If circumstances require, we may collect Personal
Information about you from third parties (such as our agents or contractors), or
publicly-available
sources.
Use of Information Collected
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We will generally only use your Personal Information for the purpose for which we collected it,
and for related purposes we consider would be within your reasonable expectations.
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We generally use Personal Information for the following purposes (as applicable in the
circumstances):
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for creating and giving you access to your registered account on the App;
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to develop, deliver, process and improve our services and content;
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in order to personalise and improve your experience;
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to inform you about our services, offers, updates, and upcoming events, including
providing
you information in relation to order confirmations, invoices, technical notices, and
security
alerts;
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for internal analytical and research purposes such as auditing, data analysis and
research to
improve our services and customer communications;
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to meet any legal or regulatory requirement or comply with a request from any
governmental
or judicial authority;
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to resolve any request, dispute, grievance or complaint raised by you in relation to
your use of
the App; or
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to detect or monitor any fraudulent or illegal activity on the App.
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By providing us with your Personal Information, you consent to us using your Personal
Information for these purposes.
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You agree that we may send you marketing or promotional communications by post or by
electronic means (including email and SMS). You may request not to receive such material from
us by contacting the Customer Care service on [1800 078 007] or by using the opt-out function
provided for in those communications. If you do not opt-out in either of these ways you will be
taken to have consented to receiving such communications from us.
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There are no consequences of opting-out of receiving our marketing and promotional
communications except that you will no longer receive them, and you may elect to re-join our
marketing list at a later stage if you wish.
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The third party service providers with whom we may share information provided by you are not
permitted to market their own services or send promotional emails or engage in promotional
communication with you. We provide you with the opportunity to opt-out of receiving non-
essential, promotional, or marketing-related communication from any third-party service
providers.
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Where we propose to use your Personal Information for a purpose other than as outlined above,
we will seek your permission (unless we are required or permitted by law to do so without
seeking consent).
Disclosure and Transfer of Information Collected
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We may from time to time disclose the Personal Information or Sensitive Information collected
from you to our trusted third-party service providers who assist us in order to facilitate the
provision of services and purchase or use of services using the App. For instance, we may share
your information with a third-party payment gateway provider to process transactions on the App
and/or service providers that we engage to send you emails and messages to your mobile device.
By using the App, you consent to any such disclosure of your information to third party service
providers. We ensure that such third-party service providers are bound by reasonable
confidentiality obligations and/or use, maintain and follow generally accepted industry and
security standards with respect to such information.
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We may also disclose your Personal Information and Sensitive Information when such disclosure
is required by law or if we, in good faith believe that such disclosure is reasonably necessary
to
respond to summons, court orders, or other legal processes, law enforcement authorities,
Government Authorities, courts, dispute resolution bodies, our regulators, auditors and any
party
appointed or requested by our regulators to carry out investigations or audits of our
activities, or
in order to protect our rights or the rights of other Users, to prevent harm to persons or
property,
and/or to investigate and address fraud and credit risk.
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We may also disclose or transfer your Personal Information and Sensitive Information to any
third
party as a part of reorganisation or a sale of the assets, division or transfer of a part or
whole of us
if there is a process where we (and/or our assets) may merge with, or be acquired by, that third
party, or for the purposes of re-organisation, amalgamation, or restructuring of business. We
shall
ensure that the third party to which we transfer or sell our assets will have appropriate
confidentiality and security measures, at least as protective as those described in this Privacy
Policy, to handle your Personal Information and Sensitive Information.
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A third-party payment gateway provider may be required to collect certain financial information
from you including, but not restricted to, your credit/debit card number or your bank account
details (collectively referred to as “Financial Information”). All Financial Information
collected
from you by such third party payment gateway providers will be governed by the privacy policies
adopted by the respective third party gateway providers. The Financial Information collected
from
you would be transacted through secure digital platforms of approved payment gateways which
are under encryption. The verification of the Financial Information shall be accomplished only
by
you through a process of authentication in which we shall have no role to play and hence, we
shall
bear no liability in relation to the same. We shall neither be liable nor responsible for any
actions
or inactions of third-party payment gateway providers or any breach of conditions,
representations
or warranties given by them. We shall also not be obligated to mediate or resolve any dispute or
disagreement between you and such third-party payment service providers.
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While we take best efforts to ensure that your Personal Information, Sensitive Information and
Financial Information is duly protected by undertaking security measures prescribed under
applicable laws, you are strongly advised to exercise reasonable discretion while providing
Sensitive Information or Financial Information while using the services, given that the Internet
is
inherently susceptible to security breaches.
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Your Personal Information and Sensitive Information may also be transferred, stored or processed
in any country other than the one where you access the App. For the purposes of sharing or
disclosing data in accordance with the Privacy Policy, we reserve the right to transfer your
information outside of your country. For example, we may disclose your Personal Information
(including Financial Information) to:
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our related entities, who may be located in various countries including in countries in
Asia, Africa, South America, North America, and Europe; and
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our service providers who are based in various countries, including in countries in
Asia,
Africa, South America, North America, and Europe.
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By using the App, you consent to such transfer of your Personal Information and Sensitive
Information outside of your country. The information may be transferred in the event it is
necessary for the operation of the App and provision of services.
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We may disclose your information to law enforcement officers, third-party rights owners or
others
in the good faith belief that such disclosure is reasonably necessary for reasons including to
enforce this Privacy Policy, respond to claims that an advertisement, posting or other content
violates the rights of a third party, or protect the rights, property or personal safety of our
users or
the general public.
Security
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The security of your Personal Information and Sensitive Information is important to us. We have
implemented security policies, rules and technical measures such as firewalls, transport layer
security and other physical and electronic security measures to protect the Personal Information
under our control from unauthorised access, improper use or disclosure, unauthorised
modification and unlawful destruction or accidental loss. When you submit your information on
the App, your information is subject to these security systems. Please note however that we
cannot guarantee the security of information, even when it is subject to these security
measures.
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Your information is contained within secured networks and is only accessible by a limited number
of authorised persons who have access rights to such systems or otherwise require such
information for the purposes provided in this Privacy Policy. These authorised persons are also
under an obligation to keep such information confidential.
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We will take reasonable steps to destroy or permanently de-identify your Personal Information
when we no longer require it for any purpose for which it was collected. We may retain your
Personal Information for as long as necessary to comply with any applicable law, for insurance
and corporate governance purposes, for the prevention of fraud, and to resolve disputes. Your
Personal Information may also be retained in our information technology system back-up records.
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Although we make best possible efforts to transmit and store all the information provided by you
in a secure operating environment that is not accessible by the general public, you understand
and
acknowledge that there is no such thing as complete security and we do not guarantee that there
will be no unintended disclosures of any information and potential security breaches. You agree
not to hold us responsible for any breach of security or for any action of any third parties
that
receive your Personal Information or events that are beyond our reasonable control including,
acts
of government, computer hacking, unauthorized access to computer data and storage device,
computer crashes, breach of security and encryption.
Access to and correction of Personal Information
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Please notify us if your personal details change so that we may keep our records current.
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You may lodge a request to access your Personal Information or to correct Personal Information
that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or
misleading, in which case please contact us in writing using the contact details below.
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Generally, we will provide you with that access, except in limited circumstances where
applicable
law permits us to deny access. In those circumstances, we will provide you with written reasons
for refusal (unless it is unreasonable to do so).
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We will respond to a request for access within a reasonable period and we will give access to
the
information in the manner requested if it is reasonable and practicable to do so. We may require
you to comply with certain procedures before we allow access to or amendment of your Personal
Information in order to ensure the integrity and security of information that we hold (eg,
providing a form of identification).
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No fee will be incurred for requesting access, but if your request for access is accepted, we
may
apply an administrative charge for providing access to your Personal Information in response to
your request.
Automatic Server Logs
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When you use the App, we may automatically receive certain details such as:
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the uniform resource locator of the site from which such you visit, access or browse the
App;
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details of the website you visit on leaving the App;
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the internet protocol (“IP”) address of each User’s computer operating system;
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the type of web browser the User is using;
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email patterns; and
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the name of the User’s internet service provider.
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This information is used solely to analyse overall User trends and to help us improve our
services.
Please note that the link between the User’s IP address and the User’s personally identifiable
information is not shared with third parties without such User’s permission or except when
required by law or to provide or facilitate the User with the services.
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Notwithstanding the above, we may share certain aggregated data, including the Personal
Information provided by the Users in an unidentifiable, aggregate form, to advertisers,
sponsors,
investors, strategic partners, and others for purposes including business development. The
amount of information sent to us depends on the settings of the web browser used by the User to
access the App. The User may refer to the browser used, if the User wishes to learn what
information is provided to us.
Cookies
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The App uses temporary cookies to store certain data. We do not store Personal Information in
the cookies. Information collected by us, by any means whatsoever, that does not personally
identify the User as an individual (such as patterns of utilisation described above) is
exclusively
owned by us and may be used by us and third-party service providers for technical administration
of the App, user administration, research, development, and other purposes.
Emails and messages
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We may collect Personal Information from you (such as your name and email address, and any
other Personal Information you volunteer) if you send us email. We will use this to contact you
to
respond to your message, to send you information that you request, and for other related
purposes
we consider are within your reasonable expectations.
Third-party websites and services
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We may allow other companies or entities to serve advertisements to you. These companies or
entities include third party advertisement services, advertisement agencies, advertisement
technology vendors and research firms. We may target some advertisements to you that fit a
certain general profile. We do not use Personal Information to target advertisements to you
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You agree and understand that we do not exercise control over third-party websites, including
any
that may be displayed as search results or links in the App. These other sites may place their
own
cookies or other files on the Users’ device, or collect data or solicit Personal Information
from
Users, and we have no control over and will not be responsible or liable for these activities.
We
do not make any representations concerning the privacy practices or policies of such third
parties
or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the
content (including information, data, text, software, sound, photographs, graphics, videos,
messages or other materials) available on such websites. The inclusion or exclusion does not
imply any endorsement by us of such websites, the websites’ provider, or the content on the
website.
Modification
We reserve the right to amend, change, modify, add or delete portions of the terms of this Privacy
Policy at any time, at our sole discretion. The Privacy Policy, as and when modified, shall be updated
on the App. We encourage you to review this Privacy Policy whenever you use our App to understand
how your Personal Information is used.
Contact details
If you would like further information about the ways we manage your Personal Information, please
contact us at the email address admin.aus@upl-ltd.com.