We recognise that your privacy is very important and that you have a right to control personal information. Personal information is information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained. It includes all personal information regardless of its source. We know that providing personal information is an act of trust and we take that seriously. The following sections set out how we handle and protect your personal information and safeguard your privacy.
Who Are We?
Padlifter (ABN 45 738 323 711) trading as Ringcommend (“Ringcommend”) is an information service that provides you with the tools and information you need to source a diamond engagement ring.
Introduction & General Terms
In this Policy, the following terms shall have the following meanings:
- “Account” means an account required to access and/or use certain areas and features of Our Site;
- “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Web browser cookies section below;
- “personal data” information or an opinion about an identified individual, or an individual who is reasonably identifiable. In this case, it means personal data that you give to Us via Our Site;
- “We/Us/Our” means Ringcommend and our Services.
In order to provide you with information, tools and other services we may collect and retain “Personal Information” that may identify you or contribute to identifying you. “Personal Information” can include information such as your name, email address, contact details and, in some cases, general financial information. We will not collect your personal information unless it’s necessary to provide the information, advice or service you’ve requested and, where possible, you’ll be able to use our services anonymously.
We will generally only collect your personal information from you or from someone you’ve authorised to provide it to us. We will also only collect information by lawful and fair means and not in an unreasonably intrusive way.
Collection of Information
When you use our service (or while you’re accessing our services) we may collect personal information about you. Because we take your privacy seriously we will take reasonable steps to ensure that you are aware of:
- who we are and how you can contact us; and
- how you can gain access to the information we have collected about you; and
- the purposes for which the personal information is collected; and
- the organisations (or the types of organisations) to which we may disclose your personal information; and
- the laws that require us to collect this information; and
- the main consequences (if any) for you if you choose not to provide us with personal information about you.
We provide general advice and comparative information about a range of diamond engagement rings and can help you connect with businesses that provide relevant products and services.
We prefer to collect personal information about an individual only from that individual but when you use our services you may provide us with personal information about someone else. We won’t ask you for personal information about someone else unless it’s needed to provide you with the service, advice or information you’ve requested but if you provide us with information about another person, you need to ensure that you are authorised to disclose that information to us on their behalf. It’s your responsibility to ensure that they understand how we will collect, use or disclose the information you provide. You need to take reasonable steps to ensure that they understand that we will not take any additional steps to confirm their understanding of these issues.
User-provided Information.When you use the Service, as a User or as a Visitor, you may provide, and we may collect Personal Data. Examples of Personal Data include name, email address, mobile phone number. Personal Data also includes other information, such as geographic area or preferences, when any such information is linked to information that identifies a specific individual. You may provide us with Personal Data in various ways on the Service. For example, when you register for an Account, use the Service, post Client Data, interact with the Service through communication or messaging capabilities, or send us customer service related requests;
Automatically Collected Information.When a User or Visitor uses the Service, we may automatically record certain information from the User’s or Visitor’s device (such as your computer, phone, tablet or voice-enabled device) by using various types of technology, including cookies, pixels or web beacons. This “automatically collected” information may include IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content the User or Visitor views or interacts with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding a Visitor or User’s interaction with our service, e.g., such as whether the Visitor or User opens, clicks on, or forwards an email message. We may also use these technologies to collect data on how successful our advertising is and the performance of our advertising partners (conversion data). This information is gathered from all Users and Visitors
Information from Other Sources.We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our partners, advertisers, credit rating agencies, and Integrated Services. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Policy;
Content Measurement data.Digital measurement software may collect data about the content on our website that a User or Visitor has viewed, and when it was viewed, and general information about the device on which the content was viewed.
Use of Personal Information
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the applicable legal requirements at all times. For more details on security see section “Will Ringcommend share my personal information with anyone else?” below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
answering your general queries about financial products, credit products and related matters;
confirming your identity;
communicating with you;
administering our services;
notifying you of the services we offer;
carrying out marketing, training or promotional activities;
responding to feedback, comments, or any other contact;
sending you email(s) or newsletters to which you have subscribed;
carrying out competitions;
enhancing our Site or Services;
helping you to resolve technical issues with our site;
helping you to identify products and product providers appropriate for your needs and circumstances;
referring you to product suppliers;
in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or
in marketing, to provide educational, relevant and promotional material;
where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so that we can offer a more relevant, tailored experience;
providing and managing your account.
By using our services, you consent to us collecting, holding and using your personal information in this way.
We may also access, hold and use aggregated information about the people that use our services. Aggregated information will not identify you or any other individual but simply provides us with non-personally identifiable data that we’ll use to improve our services, understand our users’ needs and develop tailored content. Although you would have provided us with the information we aggregate for these purposes, it won’t identify you or enable you to be personally identified.
We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with Ringcommend. If you delete your Ringcommend account then your personal information is deleted immediately, and the remaining information is anonymised for analytical purposes. For further information about deleting your Ringcommend data, please see section ”Can I find out what personal information Ringcommend keeps about me?” below.
Usage of Data for Marketing Purposes
We may disclose your personal information to:
jewellery suppliers and diamond distributors
our external service providers for the purposes of our business, for example IT service providers. Information is only disclosed in accordance with Australian Privacy Principles.
product and services providers for operational purposes, and also because from time to time they may choose to provide you with information about their products and services by ordinary post or email. You may opt-out of receipt of such marketing at any time by contacting directly those organisations which have obtained your information. If you do not have their details, you can request them from us on the details below;
any organisation which you request us to, including a financial adviser, broker, solicitor, or accountant;
our related companies and other organisations;
if we consider it necessary to do so in order to enforce or apply the terms of any of our agreements with you;
if we sell our business or part of it to a third party;
in extreme circumstances to protect the personal safety of our customers, website users, staff or the public; and
law enforcement, regulatory and government bodies, government agencies and courts, if we are required to by law to do so.
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure.
Sharing of Personal Information
As a general principle, we won’t disclose your personal information without your express permission unless:
we are required to do so by the law, to comply with our obligations or exercise our rights;
it’s necessary to lessen or prevent a serious and imminent threat to a person’s health, life or safety;
it’s required to facilitate a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy; or
it’s necessary to lessen or prevent a threat to public health or public safety.
Generally, we will use your information within Ringcommend and will only share it outside Ringcommend where you have requested it or given your consent. However, we may share with the following entities:
Third-party vendors who provide services or functions on our behalf, including business analytics, customer service, marketing, distribution of surveys, and fraud prevention. We may also authorise third-party partners to gather information on our behalf, including as necessary to operate features of our website. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
Advertising partners. We share personal data with advertising partners, as part of the marketing of our services via third parties (to ensure that relevant advertisements are shown to the right audience).
Protecting the Privacy of Children
We do not allow children under 18 years of age to become registered users nor will we knowingly collect or maintain information from them. If you identify or suspect that we have acted contrary to this policy, please alert us at [email protected] and ask for that information to either be deleted or secured.
How We Maintain Accurate Information
Although we will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date, it is your responsibility to ensure that the information you provide to us is accurate, complete and current. You control the information you provide to us and you can correct or update any information you choose to provide to us. If you want us to correct our records simply tell us what needs to be changed and why.
How & Where Does Ringcommend Keep My Data?
To offer our services, we will process and store your data in Australia, we also require all our partners to ensure that your data is kept securely at all times.
The information we collect is entered into our site by you, imported on your instruction and transmitted across the Internet to our servers. By using our service, you are consenting to this process. The service providers who host our servers are not permitted to access your personal information except for the purposes of storing it. Although we will take reasonable steps to protect the information you provide to us, you should appreciate that the Internet itself is not secure and take care about the personal information that you transfer over the internet or by email.
In a limited number of circumstances, we may use third-party providers to facilitate surveys or mail outs on our behalf. Should this occur, we will only do so where the Service Provider:
has committed to securing your personal information in a manner consistent with our policy; or
neither holds, accesses, uses or retains the personal information other than as we have engaged them.
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. We use industry-standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information.
How Can I Control Information About Me?
When you submit personal data via Ringcommend, you may be given options to restrict Our use of your data. In particular, we aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).
The Right to Withhold Information
You may access some areas of the site without providing any data at all. However, to use all the features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
Can I Find Out What Personal Information Ringcommend Keeps About Me?
This document sets out our approach to the management of personal information and we make this available to anyone who asks for it. If you need to know more, we are more than happy to explain to you what sort of personal information we hold, for what purposes, and how we collect, use and disclose that information.
If you need additional information about the Australian Privacy Principles, the Privacy Law or our obligations you can also access the website of The Office of the Australian Information Commissioner (http://www.oaic.gov.au).
You have the right to request access to the personal information Ringcommend holds about you (where such data is held) and to have any inaccuracies corrected. We will not restrict your access to the information unless:
providing access would pose a serious threat to someone’s life or health; or
providing access would have an unreasonable impact upon someone else’s privacy; or
the request for access is frivolous or vexatious; or
the information relates to existing or anticipated legal proceedings between you and us;
providing access would prejudice our negotiations; or
providing access would be unlawful; or
denying access is required or authorized by or under law; or
providing access would be prejudicial or commercially sensitive.
If we can’t provide you with access to the information because of one or more of these reasons (which we will confirm in writing) we will consider reasonable alternatives that may satisfy all parties. You’ll generally be able to access your personal information without cost but, if we think a charge is reasonable it will not be excessive and will not apply to lodging a request for access. We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files.
We will need two copies of forms of identification, which can be:
Utility bill (from last 3 months)
Current vehicle registration document
Bank statement (from last 3 months)
Rent book (from last 3 months)
Where My Personal Information May End Up
Unless you choose to provide your personal information or instruct us to do so, the personal information we hold will be secured on our servers and not be transferred elsewhere. There are some exceptions, but we won’t transfer personal information to a foreign country unless:
We believe that the recipient of the information is subject to a law or arrangements that are substantially similar to our commitment; or
you consent to the transfer; or
the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to your request; or
the transfer is necessary for the conclusion or performance of a contract concluded by you;
We will not transfer information contrary to this policy, without your consent or in a manner inconsistent with this policy.
Use of Web Beacons
Our websites may contain electronic images known as “web beacons” – sometimes called single-pixel gifs – that may be used to assist in delivering cookies on our sites and allow us to count users who have visited those pages and to deliver other services.
How We Use Web Beacons
We may include web beacons on all webpages on Ringcommend in order to determine whether messages have been opened and acted upon. We may also employ web beacons from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our websites.
Finally, we may work with other companies that advertise on our website to place their web beacons on our sites in order to allow us to gather statistics and better target advertisements on our website that may result in a purchase or other action on the advertiser’s site.
We use different types of cookies for different things, such as:
Analysing how you use Ringcommend;
Giving you a better, more personalised experience;
Recognising when you’ve signed in.
First Party Cookies
Third Party Cookies
By using Our Site you may also receive certain third party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Ringcommend for advertising services or social media.
How We Use Your Data
In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
Other Information Collected From Web Browsers
Your web browser may also provide Ringcommend with information about your device, such as an IP address and details about the browser that you are using. We use information provided by your browser or by the link that you have clicked to understand the webpage that directed you to Ringcommend and this may be captured by performance cookies.
DNT (Do Not Track) Browser Setting
DNT is a feature offered by some browsers, which, when enabled, a sends a signal to websites to request that your browsing is not tracked, such as by third-party ad providers, social networks and analytics companies. This website does not currently respond to DNT requests.
Contacting Ringcommend About this Privacy & Cookies Policy
We believe in openness and we are committed to ensuring that we respect the privacy of those using the exceptional services we provide. If you want to arrange access to your information or have questions about privacy or the use of this site, please email [email protected]
Please note that if the responding officer determines with good reason that your message is spam within the meaning of the Spam Act 2003 (Cth), Ringcommend reserves the right not to respond to any message you send and to block your use of this website from the IP address where the spam originates and reserves the right to claim compensation under the appropriate legislation.
Changes to Ringcommend’s Privacy & Cookies Policy
Use of Your Personal Information
The primary purpose of collecting this information is to provide you with the services you request.
If you have provided express consent for us to contact you with information about other offers we may send marketing and promotional material that we believe may be relevant to you. Any marketing offers will provide a facility that allows you to easily opt-out of any further such communications.
If you do not provide us with all of the information we ask for, or the information is incorrect, we may not be able to fulfil your request.
Disclosure of Your Personal Information to Third Parties
From time to time we use third party service providers in order to provide the Services to you and in doing so may make your information available to certain third party service providers. These services include website hosting, mailing list providers, CRM software, accounting software, web analytics software, ad serving and online marketing software.
If you choose to use the referral form, the information in that form, will be passed to the third party shown.
Version Date: 14 Nov 2019