ConversionCow Privacy Policy

Who are we?

ConversionCow Pty Ltd (ABN 86 661 960 961) (we, us or our) is a provider of an on-line software tool which creates and manages various widgets on our customers’ websites (the Service), for the purpose of assisting our customers to increase their conversion rate and maximise the efficiency of their marketing efforts through such websites (the Purpose). ConversionCow’s online software tool is made available through our websites located at https://www.conversioncow.com or https://www.conversioncow.io, including sub-domains of those websites (each and together Our Website). In order for our Service to serve the Purpose it is intended to serve, we will need to collect, use, process, store, disclose and/or transfer data (including personal information) about any users (each an End User) who have accessed and/or used Our Website, or any of our customer’s websites on which ConversionCow has been installed and/or operates (Our Customer Websites).

Where we provide the Service to you, then this policy should be read with the “ConversionCow Terms of Use” available at Terms of Use (Terms of Use).

In this privacy policy where we use the word “you” or “your” we mean a visitor to Our Website or one of Our Customer Websites (including any End User), or a recipient of the Service.

Purpose of this policy

We are committed to respecting your privacy and protecting your personal information. We handle personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth, Australia) (Privacy Act) and privacy laws of other jurisdictions, as applicable to our collection and processing of the particular personal information (Privacy Laws). In this policy, “personal information” has the meaning given in the Privacy Laws that apply to your information that is collected. In basic terms, it is information or an opinion about an identifiable individual.

By implementing privacy processes and standards based on the most robust of these Privacy Laws, we comply with Privacy Laws in the country where personal information is collected from you.

This privacy policy sets out, among other things:

The types of personal information we collect or receive about you;
Why and how we collect or receive it;
What we do with it and where we process it;
With whom we may share it and why we do so;
How we store and secure it;
How long we keep it; and
How you can access and update it, or complain about our handling of it.

Updates to this policy

We may change this policy at any time by posting the amended policy on Our Website. We will make every effort to notify you by email, or notice on Our Website, if the changes are significant, but you should also check Our Website regularly to ensure that you are aware of any such changes. This policy was last updated on 9th March 2023.

What personal information do we collect?

So as to provide the Service to you, and so to ensure that the Service continues to serve the Purpose, we may collect or receive the following types of personal information about you:

your first and last name
the initials of your first and/or last name
your personal address
your billing information
your device identifier / serial number
your personal email address
your financial account numbers (eg. bank account, credit card), although this may only be collected or received from you where you have a subscription to the Service, which is then only stored in the payments gateway (and not on our systems)
your IP (Internet Protocol) address
your location data (eg. GPS coordinates)
your password / pin number
your personal phone number
photos of your face (i.e., an avatar image)
your text message content, and
your trace logs.

We will only collect, receive or hold sensitive information (for example, information about your health or disabilities, ethnic or religious background, gender identity, political memberships, trade union memberships and the like) if you choose to include such information or provide it to us.

How do we collect or receive personal information?

We may collect or receive personal information directly from you, or from third parties. We may collect this information when you:

visit Our Website and / or any of Our Customer Websites;
enquire about using, register to use, or in fact use or interact with, the Service;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
you enter it into a web form on Our Website and / or Our Customer Websites; or
you contact, and / or engage with, our support team.

If, in using the Service, you provide personal information to us about another person, you must:

ensure that they have authorised you to provide that information to us, so that we can use and disclose it for the Purpose (and in accordance with this policy and applicable Privacy Laws);
take reasonable steps to ensure they are aware of and consent to the matters set out in this policy, including that their personal information is being collected, the purpose of collection, the intended recipients of that information and where it may be processed, their right to access and correct that information, our identity, and how to contact us;
you have provided them with a copy of (or have otherwise sufficiently drawn their notice to) this policy; and
if we request, help us with any requests by that person to access or update their personal information provided to us, or with any complaints they may make in respect of the collection, disclosure and handling of their personal information.

What about information collected or tracked through cookies and similar mechanisms?

Information may also be collected and stored when you interact with Our Website and Our Customer Websites. In particular, we may use cookies, web beacons and other mechanisms to monitor usage of Our Website and / or Our Customer Websites so as to improve content and usability.
A cookie is a packet of information sent by a server to an Internet browser and then returned by the browser each time it accesses the server. Cookies are used to remember visitors within a session and to facilitate transaction functions. If you do not wish to receive cookies, you can configure your browser or Internet access to ask you if you want to accept cookies on a particular website, or to reject all cookies on all websites. Rejecting cookies may mean that some or all of Our Website’s and / or Our Customer Website’s features and functionality will not be available to you.

By visiting Our Website and / or any of Our Customer Websites and not opting out of use of cookies, you consent to our use of such cookies.

Web beacons (also known as web bugs, pixel tags or clear GIFs) are transparent graphic images on a web site. They are typically used by a third party to monitor the activity of a site. Information collected by web beacons may include the IP address of the computer that retrieved the image or the time the web beacon was viewed and for how long. We do not tie the information gathered by such mechanisms to any users’ personal information.

Why do we collect, use and disclose personal information?

We may collect, store, use, process, disclose and transfer your personal information to:

enable you to access and use Our Website, Our Customer Websites and the Service;
provide you with the Service, including to identify your location/region so we can best tailor the Service to you;
maintain the security and integrity of the Service and the data held within it;
send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you, and to otherwise allow our customer service/support team to resolve queries quickly and efficiently;
set-up and operate billing and payment processing;
operate, protect, improve and optimise Our Website, Our Customer Websites and the Service, together with our business and our users’ experience, such as to perform analytics, generate reports, conduct research and for advertising and marketing;
send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners (including our customers) that we think you may find interesting;
provide the relevant End User data to our customers (that operate Our Customer Websites) so that they can interact directly with you (including for marketing and promotional purposes);
administer promotional activities or events sponsored or managed by us or our business partners (including our customers); and
comply with applicable laws, regulatory requests and legal notices – for example, court orders, subpoenas, other legal process or investigation if required by law, and to enforce our agreements with third parties

We may also disclose your personal information to a trusted third party (including our customers) who also hold other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

If you have consented to us processing your personal information, you can withdraw that consent at any time, but this will not impact the lawfulness of our past processing of that information, before such withdrawal.

To whom do we disclose your personal information?

We may disclose your personal information for the purposes described in this privacy policy (including for the Purpose), to:

our personnel and related bodies corporate involved in the provision of the Service;
third party suppliers and service providers who help us to run and maintain our systems and business so that we can operate Our Website, Our Customer Websites and provide the Service (but solely as necessary for that purpose) – for example, financial Service companies such as Stripe who facilitate our payment and billing processes;
our professional advisers and agents; and/or
other persons (including government agencies, regulatory bodies and law enforcement agencies) as required or allowed by law – for example, to comply with court orders, subpoenas, or other legal process or investigation if such disclosure is required by law.

Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

If personal information is provided to any third party service providers of ours, the handling of such personal information will be in accordance with the privacy policy of that third party.

Except as described above, we will only disclose your personal information when you direct or provide us with consent, or if we suspect fraudulent or criminal activities.

Security and storage of your personal information

We hold your personal information in electronic form and store it using Amazon Web Service (AWS) hosting service. The storage and handling of such personal information is governed by AWS’s privacy policy. AWS provides a network of secure data centres and takes very seriously the confidentiality, integrity and availability of data and maintenance of customer trust and confidence. The IT infrastructure used by AWS is designed and managed in alignment with security best practices as further detailed at https://docs.aws.amazon.com/whitepapers/latest/aws-overview/security-and-compliance.html#compliance.

Otherwise, we are committed to protecting the security of your information and we take all reasonable steps in accordance with accepted industry practice to protect it from misuse, interference and loss and unauthorised access, modification or disclosure. We apply safeguards at a physical, administrative, personnel and technical level to protect your information, including using strong encryption.

We cannot, however, guarantee that your information will be secure at all times, as the Internet is not a secure environment. You therefore transmit information (including personal information) over the Internet at your own risk and should only upload information to Our Website, Our Customer Websites and/or the Service from within a secure environment. You must also ensure that you keep your log-in credentials for the Service (including username and password) safe and secure. You must notify us as soon as possible if you become aware of any misuse of those credentials, and immediately change them (which you may do by logging a support ticket or emailing support@conversioncow.com).

We will notify you as soon as reasonably possible if we discover a security breach which causes your personal information to be lost or stolen, or accessed, used, disclosed, copied, modified, or disposed of by any unauthorised person or in any unauthorised way.

Transfer of personal information offshore

If you are outside Australia, your personal information collected or received by us will be transferred to Australia (where we will process and store it in accordance with the Privacy Laws that apply to your personal information, ensuring the security and integrity of that information).

We do not ourselves transfer your personal information outside Australia. However, third party service providers such as AWS may transfer your information to locations outside Australia or the jurisdiction where you are located (eg. to a secure AWS server in another jurisdiction) – and Privacy Laws in those jurisdictions may not offer the same level of data protection as those of your home country. The handling of your personal information by a third party service provider (including AWS) is governed by that third party’s privacy policy.

For how long do we retain your personal information?

We retain your personal data for as long as necessary to provide the Service you have requested and to manage your relationship with us. Generally, this will be only for so long as we continue to have a contractual relationship with you. We regularly remove suspended/deleted account data. In addition, customers of the Service may lodge a support ticket to terminate their account, and /or to remove their personal information.

We may also need to keep some of your personal information for such period as may be required by law or in accordance with our back-up and archival policy (so long as that policy does not breach applicable Privacy Laws). When we no longer require your information, we will use our best endeavours to destroy it securely and in a reasonable time frame.

Links to other websites

Our Website and / or Our Customer Websites may contain links to other websites, which are provided for your convenience only. We do not endorse (and are not responsible or liable for) the operation of, or security measures applied to, those websites. If you choose to access them, you do so at your own risk and subject to the relevant third party’s terms and conditions and privacy policies.

Accessing and correcting your personal information

You can access the personal information we hold about you by lodging a support ticket through our help desk. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

Customers of the Service can also access and update their personal information by logging into the ConversionCow administration portal. End Users can contact their associated customer to update or retrieve their personal information.

In addition, any inquiries and complaints can be made via lodging a support ticket through our help desk.

Opting out of mailing lists

We may send you notices, alerts, service updates, administrative messages, and other information from time to time in relation to the Service. You can opt out of communications (that are not critical to our ability to provide the Service), by following the instructions in the communication, or contacting us (see our contact details below).

Notifying us of a Privacy Breach

To report an actual or suspected privacy breach, or to lodge a complaint about our handling of your personal information, please provide full details (along with any supporting documentation and your full contact details) in the form of a support ticket through the help desk. We will take all reasonable steps to:

respond to your issue within 10 business days, and
investigate and try to resolve your issue within 30 business days or such longer period as is necessary and notified to you.

If you believe we have not resolved your issue satisfactorily, we will inform you of further steps you may take.

Privacy policy enquires

For more information about your privacy rights, or protecting / making a complaint regarding your privacy, visit:

if you are based in Australia, the Office of the Australian Information Commissioner website at https://www.oaic.gov.au/;
if you are based in the UK, the Information Commissioner’s Office which can be contacted by:
- Post to:
  Information Commissioner’s Office
  Wycliffe House, Water Lane
  Wilmslow, Cheshire
  United Kingdom
  SK9 5AF
- Phone: 0303 123 1113 from the UK or +44 1625 545700 from elsewhere
- Email: casework@ico.org.uk
- Website: https://www.ico.org.uk;
If you are based elsewhere in the European Union, your local data protection supervisory authority, a current list of which can be accessed here; or
If you are based elsewhere, the corresponding website of your local privacy regulator.