DisplaySweet provides presentation tools for new property developments through our software applications and Platform which we make available online via websites specified by us from time to time, including at the displaysweet.com websites and via app versions that may be downloaded to tablets (“Platform”) and also supplies other products and services, including project services, DisplaySweet is based in Australia but offers its products and services to users all over the world.
For the purposes of the GDPR, DisplaySweet is both the “data controller” and a “data processor” of Personal Information and is responsible for how Personal Information is collected and used. This policy sets out how we collect, hold, protect, use or disclose your Personal Information when you use our Platform or Services, including when you access our content or engage with us via third party social media applications, and how you may access, change or request that we amend your Personal Information.
What information do we collect?
We may collect and hold your Personal Information such as:
- your name,
- location information,
- email address,
- telephone number,
- mailing address,
- company name,
- job title
- the type of property you are searching for,
- your reasons for purchasing,
- time frame for purchasing a property, and
- Information you may provide when interacting with us via our website, app, webform, over the phone or in person.
We collect information about your interaction with our Platform and Services, your usage preferences, and your communications with us. This is information we receive from devices you use when you access our Platform, including from third party providers such as Google Analytics. This information could include the following:
- Location information, including from your mobile device (if applicable).
- Computer and connection information such as statistics on your page views, traffic to and from sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
We collect the following information about you from third parties:
- We supplement the personal information we collect directly from you with information collected from third parties. For example, we also collect information from and share information with our partners and (including third party support service providers and payment providers, website hosting, analytics providers and cloud service providers). We may also receive personal information from social networks when we integrate them with our authentication processes.
If you use our Platform or otherwise engage our Services, we may also collect information that does not identify an individual (such as anonymous usage data and aggregated information.
Why do we need your Personal Information?
We only collect or hold your Personal Information for legitimate purposes where it is reasonably necessary for our business functions or activities.
In particular, we need your Personal Information to:
- provide you with the Services we offer which includes communicating with you (such as via direct marketing) about our products and/or services;
- maintain our business relationship with you by answering your questions or queries about DisplaySweet or the Services we provide, communicating with you about our Services, creating and updating our database(s) and other records, internal record-keeping, providing sales and support services to you and otherwise responding to your enquiries;
- market and advertise to you including by sending you newsletters, alerts, special offers, and promotions, engaging third party service providers (such as marketing automation Platform, and email marketing service providers) or otherwise contacting you about our Services or information we think may interest you. You can opt-out from being contacted for direct marketing purposes by contacting using the details at the end of this policy or by using the unsubscribe facility included in each direct marketing communication we send. Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time;
- improve the quality and design of our Services by storing, tracking, analysing and processing user preferences and trends as well as user activity on our Platform to create new features, functionality and services in relation to the Websites and Platform and to communicate these to you;
- comply with the law including any contractual obligations we may have with you; and
- exercise our legal rights including exercising rights we may have under law or a contract between us and you, or between us and a third party,
(together “Primary Purposes”)
If you do not provide us with your Personal Information, we may not be able to carry out some or all of our Primary Purposes.
For individuals in the UK or the EU, we will seek your consent to send you marketing communications. You may opt-out from any of our communications at any time.
How do we collect Personal Information?
You give it to us
We collect personal information directly from you when you:
(a) use our services;
(b) set up an account or profile with us;
(c) interact or share personal information with us via our website and social media;
(d) if you complete a survey or test sent to you by (or on behalf of) us;
(e) register your interest in hearing more about DisplaySweet; or
(f) communicate with us.
We collect it
We may also collect your personal information from third parties including:
(a) from publicly available sources;
(b) your employer if you are the contact for the employer’s account;
(c) service providers;
(d) referrals who may have referred you to us; and
(e) organisations with whom we have an agreement to share information with.
We endeavour to only ask for your personal information if it is reasonably necessary for us to carry out our business activities and will generally obtain consent from the owner of the personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct. We endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.
Who we disclose your Personal Information to
We may disclose your personal information to the following third parties:
(a) our business or commercial partners;
(b) our professional advisers, dealers and agents;
(c) third parties and contractors who provide services to us, including support services, IT service providers, distributors, marketing and advertising organisations and payment processing service providers;
(d) payment system operators and debt-recovery functions;
(e) third parties that collect and process data, which are available in our list of sub-processors [Aircall, Atlassian, AWS, DocuSign, Firebase, PipeDrive and Sendgrid] (Sub-processor List); and
(f) any third parties authorised by you to receive information held by us.
We may also disclose your personal information if we are required, authorised or permitted by law.
We may send information to third parties that are located outside of Australia. These third parties are located in the locations set out in our Sub-processor List, although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities.
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to remain anonymous (unless this is impractical or against the law).
In some instances, if you do not provide us with certain Personal Information we may not be able to provide you with the relevant product, service or information. This may have an effect on whether we can begin or continue a relationship with you, and whether you can use or access the Platform or the full range of our Services.
Personal Information of minors
We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use our Services (including by registering an account on our Platform). If we become aware that we have collected personal information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.
Do we use “cookies”?
We may use knowledge of your user experience collected through the cookies and web beacons on the Platform to better understand what Services may be of interest to you and to collect statistical information, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services.
Using other sites
Is your Personal Information confidential and secure?
We take all reasonable steps to keep your Personal Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may keep your Personal Information in both hard copy and electronic forms, and will securely delete it or de-identify it as legally required.
We also urge you to take steps to keep your Personal Information safe, such as choosing a strong password and keeping it private, as well as logging out of your account on our Platform, and closing your web browser or application when you are finished using our Platform on a shared or unsecured device.
Your choices and rights
We welcome your enquires and comments and encourage you to contact us to update your Personal Information if it changes. For your protection, however, we may require that you confirm your identity before we provide a copy of your Personal Information to you.
You are able to request access to personal information we hold about you. If you would like to access your personal information, please contact us using the details below. In certain circumstances, we may not be able to give you access to your personal information in which case we will write to you to explain why we cannot comply with your request.
We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant. If you believe the personal information we hold about you should be updated, please contact us using the details below and we will take reasonable steps to ensure it is corrected if appropriate.
Destroying an de-identifying Personal Information
We destroy or de-identify personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.
Queries and complaints
If you have a question, concern or complaint about how we handle your Personal Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint).
Contact us by:
Email: [email protected]
Mail: Display Sweet Pty Ltd, Level 1, 257 Chapel Street, Prahran 3181, Australia
For more information about privacy in Australia and protecting your privacy, please visit the Office of the Australian Information Commissioner (OAIC) website at www.oaic.gov.au or write to the OAIC at GPO Box 5218, Sydney NSW 2001.
For more information about the GDPR, please visit the website of the European Data Protection Supervisor, the European Union’s independent data protection authority at: https://edps.europa.eu/ or the relevant Data Protection Authority in your country.
Last updated: May 2022
Users based in the UK and the EU
If you access our Platform from the UK or the EU, you may have additional rights under the GDPR in relation to the handling of your Personal Information. The EU GDPR and UK GDPR provide you with eight key rights, being the right to:
- Be informed: anyone processing your data must make clear what they are processing, why and who else the data may be passed to.
- Access: the right to access what data is held about you.
- Rectification: the right to have your data corrected or amended if what is held is incorrect.
- Erasure: the right to ask for your personal data to be deleted, also known as the right to be forgotten, if permitted under applicable laws.
- Restrict processing: the right to require a temporary halt to the processing of personal data.
- Data portability: the right to request for any data supplied by you to us to be provided in a structured, commonly used and machine-readable format.
- Object: the right to object to further processing of your data which is inconsistent with the primary purpose for which it was collected.
- Consider automated decision making and profiling: the right not to be subject to a decision based solely on automated processing.
This Privacy Notice sets out, among other things, how you can exercise these rights when dealing with DisplaySweet.
Where we rely on your consent as the lawful basis to process your data under the GDPR regime applicable to you we will always ask for you to positively affirm your acceptance. By clicking to accept this Privacy Notice, you acknowledge and agree to be bound by this Privacy Notice.
We note that all contact or other data forms where consent is required to be given by you include no pre-checked checkboxes so that you are able to freely, affirmatively opt-in. We will also provide you with notice on the Services specifically detailing what it is that you are consenting to in clear and plain language as well ensuring that each matter that requires consent is clearly distinguishable.
For all areas of the Services where consent is given it is just as easily able to be withdrawn through the appropriate account settings on the Services or by contacting us at the details provided below.
If you believe that consent has not been given freely or in breach of the terms of this Privacy Notice, please contact us.
Managing your Personal Information
Subject to the EU GDPR or UK GDPR, you may request to access the Personal Information we hold about you by contacting us. All requests for access will be processed within a reasonable time.
(a) Accessing or rectifying your Personal Information
We may, if required, provide you with tools and account settings to access, correct, delete, or modify the Personal Information you provided to us. You can find out more about how to do this by contacting us. In the event that you are unable to access your Account to access or rectify your Personal Information, you may submit a request to us to correct, delete or modify your Personal Information and download the data for you.
We keep data for as long as it is needed for our operations. If you deactivate and delete your Account, your data will no longer be visible on your Account. Please keep in mind that third parties may still retain copies of information you have made public through our Services.
If you wish to have us delete your data, please contact us.
(c) Object, restrict or withdraw consent
You may submit a request to us if you object to any Personal Information being stored, or if you wish to restrict or withdraw any consent given for the collection of your Personal Information.
You may withdraw your consent to the processing of all your Personal Information at any time. If you wish to exercise this right, you may do so by contacting us.
You may withdraw your consent or manage your opt-ins by either viewing your account on the Services or clicking the unsubscribe link at the bottom of any marketing materials we send you.
We may, if required and possible, provide you with the means to download the information you have shared or generated through our services. Please contact us for further information on how this can be arranged.
In certain instances, we may not be required or able to provide you with access to your Personal Information. If this occurs, we will give you reasons for our decision not to provide you with such access to your Personal Information in accordance with the requirements of the EU GDPR or UK GDPR.
There is no application fee for making a request to access your personal information. However, we may charge an administrative fee for the provision of information in certain circumstances, such as if you make repeated requests for information or where the information is held by a third-party provider.
Where we act as a data processor, we do so on behalf of our customer and in accordance with their instructions. This means that should you wish to access, review, correct, transfer, modify or delete any Personal Information we process on behalf of a customer you should contact the customer with your request.
Notifiable Data Breaches
We take data breaches very seriously.
We will endeavour to meet the 72-hour deadline as imposed by the EU GDPR and UK GDPR, to report any data breach to the supervisory authority or to the Information Commissioner’s Office where a data breach occurs that will likely be a risk to you.
Further, where there is likely to be a high risk to your rights, we will endeavour to contact you without undue delay. We will review every incident and take action to prevent future breaches.
Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision is not necessary for entering into, or the performance of, a contract between us, or is not authorised by Union or Member State law or UK law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or is not based on your explicit consent. If you wish to exercise your rights, please contact us.
Integrity and Retention of Data
We take all reasonable steps to ensure that the Personal Information we collect about you is accurate, up to date and complete. Where we collect that information from you directly, we rely on you to supply accurate information. DisplaySweet makes it easy for you to keep your Personal Information accurate, complete, and up to date. Where we use or disclose your Personal Information, we will also ensure that your Personal Information is relevant.
We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law. We may retain your information for fraud prevention or similar purposes.
If you reside in the EU, EFTA States, or the UK, the data controller that is responsible for your Personal Information is:
Display Sweet Pty Ltd
ACN 613 256 054
Email: [email protected]
Address: Level 1, 257 Chapel Street, Prahran 3181, Australia
If you wish to raise a concern about our use of your information you have the right to do so with your local supervisory authority for individuals based in the EU or with the Information Commissioner’s Office for individuals based in the UK.