This document declares the undertakings by Expertunity in relation to its handling of Your Data.

Data Collection
Expertunity undertakes to collect Your Data by means that are:
• fair;
• legal; and
• transparent.

If you visit a Expertunity’ website, your web-browser automatically discloses, and Expertunity’ web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful.

This data may or may not be sufficient to identify you. Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in ‘cookies’ and submits them each time you request a web-page within a particular domain (such as expertunity.global).

If you disclose personal data to Expertunity in conjunction with an identifier such as your name or your credit-card details, Expertunity will collect Your Data. Moreover, any data that becomes available to Expertunity through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.

Subject to the qualifications immediately below, Expertunity undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:
• where Expertunity reasonably considers that the protection of its financial interests requires that it gather Your Data from other sources, or from additional sources.

This applies in particular where Expertunity has a lending exposure to you, and seeks information about your credit worthiness:
• where Expertunity reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering Your Data from other sources. This applies in particular to consumer profile data.

Where Expertunity collects Your Data from sources other than you, it undertakes:
• to do so only by legal means;
• to do so only with your consent; and
• to declare to you what sources it uses, and under what circumstances.

Expertunity undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as ‘to support our operations’.

Data Security
Expertunity undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

Expertunity undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.

Expertunity undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

Expertunity undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by Expertunity’ staff-members and contractors.

These include:
• training for staff in relation to privacy;
• access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
• particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
• reminders to staff and contractors from time-to-time about the importance of data privacy, and the consequences of inappropriate behaviour;
• declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
• clear communication of policies and sanctions; and
• processes to audit, to investigate and to impose sanctions.

Data Use
Use refers to the application of Your Data by any part of Expertunity, or any staff-member or contractor of Expertunity in the course of their work.
Expertunity undertakes to use Your Data only for:
• the purposes for which it was collected;
• such other purposes as are subsequently agreed between Expertunity and You;
• such additional purposes as may be required by law. In these circumstances, Expertunity will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
• such additional purposes as are authorised by law (in particular to protect Expertunity’ interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Expertunity or have committed a breach of the criminal law).

Expertunity undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.

Expertunity undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure
Disclosure refers to making Your Data available to any party other than Expertunity and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Expertunity undertakes to disclose Your Data only under the following circumstances:
• in the course of business being conducted between You and Expertunity, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, Expertunity undertakes to exercise control over Expertunity’ contractors to ensure that their actions are compliant with these Terms:
• in other circumstances that are directly implied by the purpose agreed between You and Expertunity at the time of data collection or subsequently. Where Your Data is disclosed in this way, Expertunity undertakes to exercise control over Expertunity’ contractors to ensure that their actions are compliant with these Terms:
• with your consent, or at your request;
• where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, Expertunity will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
• where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Expertunity believes on reasonable grounds that the disclosure of Your Data will materially assist in the protection of the life of health of some person), provided that Expertunity will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, Expertunity undertakes to disclose only such of Your Data as is necessary in the particular circumstances.

Data Retention and Destruction
Subject to the qualifications immediately below, Expertunity undertakes:
• to retain Your Data only as long as is consistent with its purpose; and
• to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:
• Your Data may be retained in Expertunity’ logs, backups and audit trails within short-term retention cycles that are devised to protect the company’s operations. In such cases, Your Data will be destroyed in accordance with those cycles;
• Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Expertunity:
– will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
– will only retain Your Data while that provision is current, and will then destroy Your Data;
• Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Expertunity’ interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Expertunity or have committed a breach of the criminal law). In these circumstances, Expertunity will only retain Your Data while that situation is current, and will then destroy Your Data.

Access by You to Your Personal Data
Expertunity undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Expertunity undertakes to enable access:
• conveniently;
• without unreasonable delay; and
• without cost.

Expertunity undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Expertunity (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, Expertunity undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.

You undertake:
• not to seek access for frivolous purposes, or unreasonably frequently;
• to accept that deletion of some data may not be consistent with the provision of particular services by Expertunity to you.

Information about Data-Handling Practices
Expertunity undertakes to make information available to you about the manner in which Expertunity handles your data:
• in general terms, in a readily accessible manner; and
• in more specific terms, on request.

Where Your Data is disclosed to a contractor, Expertunity undertakes to make information available to you on request about the manner in which Expertunity’ contractors handle your data.

Expertunity undertakes to ensure that the information provided is meaningful, and addresses your concerns.

You undertake:
• not to seek such information for frivolous purposes, or unreasonably frequently; and
• to accept that the disclosure of excessive detail may harm the security of Your Data and Expertunity’ business processes, and may harm Expertunity’ commercial interests.

Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Expertunity’ behaviour in relation to these Terms, you undertake:

• to communicate them in the first instance:
to Expertunity only; in sufficient detail; through a channel made available by Expertunity for that purpose;

Expertunity undertakes:
• to provide one or more channels for communications to Expertunity, which are convenient to users;
• to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Expertunity’ reference-code for the communication;
• to promptly provide a response to the communication, in an appropriate and meaningful manner.

You further undertake to not pursue Expertunity through any Regulator or the media:
• until and unless Expertunity has had a reasonable opportunity to respond to the initial communication; and
• while Expertunity and you remain are conducting a meaningful dialogue about the matter.

Changes to These Privacy Undertakings

Expertunity undertakes:
• not to materially change these Terms in a manner that reduces the protections for Your Data;
• to take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data;
• where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
• where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
• to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.

Definitions
Expertunity means Expertunity Pty Ltd

Your Data means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that Expertunity is capable of correlating with you, using such means as server-logs and cookie-contents.

Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.

Consent means your concurrence with an action to be taken by Expertunity. Consent may be express or implicit, but in either case must be informed and freely-given.

Comments
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Analytics
Who we share your data with
How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data
Visitor comments may be checked through an automated spam detection service.