Wilcom Privacy Policy

This website is operated and provided by Wilcom International Pty Limited having its registered office at Level 3, 1-9 Glebe Point Road, Glebe, Sydney, NSW 2037.

References to "Wilcom", "we", "us" or "our" are references to Wilcom International Pty Limited and any other company in the Wilcom group.

Wilcom is committed to protecting your privacy and handling your information in an open and transparent manner. This policy ("Privacy Policy") explains how we collect and use your personal information in connection with your relationship with us as a customer or potential customer including;

• through your use of www.wilcom.com and any mini site from time to time including the Hatch mini-site (the "Site");
• through your use of our products and services;
• by interacting with our content and/or services such as online training; or
• by contacting our Support team.

This Privacy Policy also sets out your rights and whom you may contact for more information. If you are resident in the EU, please see the EU User section for additional information that is relevant to you.

In this Privacy Policy, your information is sometimes called "personal data". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data.

From time to time, we may need to change this Privacy Policy. If we do so, we will post the updated version on the Site and within our products where applicable and it will apply to all your information held by us at the time. All amended terms will automatically take effect immediately on posting. Please check this Privacy Policy periodically to inform yourself of any changes. If you do not accept the changes made to this Privacy Policy you should immediately stop using the Site and our products and services.

The kind of information we collect and hold about you

Depending on the particular circumstances, we may collect and hold different information about you. For example, this may include:

• your name;
• your occupation;
• your contact information such as your home or work address, telephone and email contact details;
• your payment details/financial information, such as your bank account or credit card details;
• your postings on any social media applications and services that we provide;
• your Wilcom account security credentials, such as username and passwords;
• information about how you use our products and services;
• information in connection with communications you send us, for example to report a problem; and
• where necessary, additional information as part of our user authentication process.

Each time you use the Site and our products, we may automatically collect the following types of information:

• Technical information: For example, the type of internet browser and the operating system. We use this information to help provide a good user experience on the Site.
• Log information: For example, the details of the use of the Site by you, the visits to the Site and traffic data. We use this information to help us understand how users use the Site and to improve user experience.

If you fail to provide us with this information, or you object to us processing such information the consequences are that we may be unable to provide our products and services to you or be prevented from continuing to manage your account(s) with us.

How we collect your information

• Information you give to us when you purchase our products. If you purchase one of our products you will need to provide certain information including your name, address and card number in relation to the purchase and in order to receive the benefit of any product warranty.
• Other information you give to us. This is information about you that you give us by filling in forms on the Site (e.g. when you register for an account with us) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register on the site for free trials or request for us to contact you or provide support. The information you give us may include your name and contact details.
• Social Media. Depending on your settings or the privacy policies for social media and messaging services such as Facebook, Twitter and Instagram you might give us permission to access information from those accounts or services.

Information we collect about you

• We may also collect information from you online using cookies and other analytical tools when you visit the Site, including when you use our products and services. Like most websites, we use "cookies" to help us make our Site – and the way you use it – better. Cookies mean that a website will remember you. They're small text files that sites transfer to your computer (or phone / tablet). They improve website use and speed – for example by automatically filling your name and address in text fields. There are more details in our section on Cookies below.
• In addition, with regard to each of your visits to our Site we will automatically collect certain information e.g. Your IP address used to connect your computer to the Internet.

How we hold your information

We take reasonable steps to maintain the security of your information and to protect it from unauthorized disclosure. When your financial details (such as a credit card number) are transmitted from our website to a third party website, they are protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

However, as the internet is not always secure and although we will do our best to protect your information we cannot be responsible for the security of information you transmit over the internet or for any unauthorized access or use of that information. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

You should also be aware that any personal information you disclose when using our online forums will be available to the public. You should take appropriate care to safeguard your information by not disclosing your security credentials (such as your username and password).

Links to Other Sites

Our Site may contain links to other sites, including via our social media buttons. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites and a link does not constitute an endorsement of that website. Once you link to another website from our Site you are subject to the terms and conditions of that website, including, but not limited to, its internet privacy policy and practices. Please check these policies before you submit any data to these websites.

How we use your information

Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customized experience and to provide the products and services that you have requested. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your computer. We may use and disclose your information for the following specific purposes:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the products, services and information that you request from us;
• to assist you with enquiries, or to improve our customer service;
• to communicate with you;
• to send you marketing (where we have the right to do so – see marketing section below);
• for our billing and account purposes;
• to maintain our business relationships where you are a business partner, a user of our website and services, or a customer;
• to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our Site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our Site about services that may interest you or them;
• to develop and improve our products and services;
• to update our records;
• to allow you to participate in interactive features of the Site, when you choose to do so;
• to enforce the terms of any license agreement that you enter into relating to our products and services; and
• comply with legal and regulatory obligations.

Sharing your information

Except as expressly set out in this Privacy Policy we do not share, sell, or lease personal information about you to any third parties for their marketing use.

The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:

• We may disclose data to provide our products and services, to respond to legal requirements, enforce our policies, and protect our rights and property. The personal information you provide to us may also be shared with our group companies if this is necessary to provide you with our products and services, respond to your inquiries or for any other related purposes.
• The personal information you provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including payment processors and our network of distributors) if this is necessary to provide you with our products and services, respond to your inquiries or for any other related purposes. We will ensure that if we share information with, or provide access to, third party service providers or related companies, any such disclosure or access is at all times in compliance with applicable data protection legislation.
• We may also share your personal information with:


• third parties who support our information technology or handle mailings on our behalf;
• law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our products or our technology assets or the rights, property or personal safety of any person);
• other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organization with that entity;
• any successor in interest, in the event of a liquidation or administration of Wilcom; and
• our professional advisers

Some our distributors and our service providers are located outside of Australia. For example, we may disclose your information to our related companies and business partners in the countries listed at http://www.wilcom.com/en-us/contact/wilcomdistributors.aspx.

How long we keep your information

We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

If you close an account you have with us or you decide not to go ahead with purchasing a product following a free trial for which you have registered, we may still keep your information.

Marketing

You may receive marketing messages from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. This marketing may be carried out in a variety of ways including by email, SMS/MMS, social media, telephone, direct mail or via our website.

We may also market to you if we have received your express consent to do so including where we have collected your details in connection with a competition or other promotion and you have agreed to receive marketing from us.

You can stop receiving marketing messages from us at any time. You can do this:

• By updating your preferences within your Wilcom account;
• By clicking on the ‘unsubscribe’ link in any email; and
• By go to Wilcom Support.

Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Stopping marketing messages will not stop service communications (such as order updates).

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Wilcom group for marketing purposes.

Cookies

Wilcom sets and accesses cookies and similar technology on your device to obtain information about how you access and use the Site. This helps us to provide you with a good experience and allows us to improve the Site. Unless you have adjusted your browser settings so that it will refuse cookies, the Site will set cookies when you load and navigate them.

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Site. Cookies are then sent back to the originating Site during your browsing session or on each subsequent visit, or to another Site that recognises that cookie. The cookies we set do lots of different jobs, such as to help us to improve the Site and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.

Cookies can be categorized in accordance with the following categories:

• Strictly necessary cookies – these cookies are essential in order to enable you to move around a Site and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
• Performance cookies – these cookies collect information about how visitors use a Site (for example, by recording which pages or features visitors use most often (usually on an anonymous basis)).
• Functionality cookies - these cookies allow a Site to remember the choices a user makes, such as a user name or language preference.
• Targeting or advertising cookies - these cookies collect information about a user's browsing habits and are usually placed by advertising networks with the Site operator’s permission.

Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the Site, whereas "persistent cookies" remain saved in the device's memory for a set period of time, even after the browser session has ended.

Refusing or restricting cookies

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. The "Help" or "Internet Settings" functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.

Please be aware that if you select to refuse or restrict cookies you may be unable to access certain parts of the Site.

How to assess or correct your personal information

If you wish to access any of your personal information that we hold or would like to correct any errors in that personal information, please contact us using the contact details set out below. We may charge you an administrative fee for providing access to your personal information in response to a request. If you are based in the EU, you have additional rights concerning the way that we use your information as set out in the EU Users section below.

How to contact us or make a privacy complaint

If you have any questions in relation to this Privacy Policy or how we manage your information, you can contact us on +61 2 9578 5100 or go to Wilcom Support

If we are unable to resolve any complaints you may have, you may wish to contact the Office of the Australian Information Commissioner by calling 1300 363 992 or visiting www.oaic.gov.au.

EU Users

This section applies to users resident in the European Union in addition to the terms set out above. In this section "Data Protection Legislation" means the EU General Data Protection Regulation 2016/679, together with all other applicable legislation relating to privacy or data protection, and where we use the terms "personal data", "data subject", "controller", “processor” and "process" (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

Wilcom International Pty acts as data controller for the purpose of Data Protection Legislation and is responsible for processing your personal data under this Privacy Policy unless otherwise notified to you in connection with a particular product or service.

Legal grounds for using your personal information

Our processing of your personal information is necessary:

• for the performance of contracts to which you will be a party to and in order to take steps at your request prior to you entering into those contracts;
• for the purposes of legitimate interests pursued by us; or
• in order to comply with a legal obligation to which we are subject.

Legitimate interests

Where our processing is based on the legitimate interest grounds described above, those legitimate interests are: (i) collecting personal information to provide you with a smooth and efficient customer experience; (ii) running our business; (iii) to provide the products and services you have requested; (iv) to prevent fraud; (v) to update you and keep you informed about relevant products and services, unless you indicate at any time that you do not wish us to do so; and (vi) for our own marketing, research and product development.

Your rights

At any time, you have the right:

• to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
• to request access to or a copy of any personal data which we hold about you;
• to rectification of your personal data, if you consider that it is inaccurate;
• to ask us to delete your personal data, if you consider that we do not have the right to hold it;
• to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
• to restrict processing of your personal data;
• to data portability (moving some of your personal data elsewhere) in certain circumstances;
• to object to your personal data being processed in certain circumstances; and
• to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Overseas Transfers

You acknowledge and agree any personal data that you provide to Wilcom will be transferred to and stored in Australia in accordance with this Privacy Policy.

Where we share data with group companies and other third parties as described here, your information may also be sent to and stored at, a destination outside the European Economic Area ("EEA") and may be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, distributors, agents or contractors.

Where recipients are outside the EEA, we ensure that the recipient provides an adequate level of protection for your personal data or the transfer is otherwise permitted under applicable Data Protection Legislation.

Contact us

If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about data protection, or you wish to raise a complaint about how we are using your information you can contact us using the following details, or any other details notified to you from time to time:

Write to the registered head office of Wilcom at Wilcom Support

Call +61 2 9578 5100. Please note calls may be recorded or monitored for training purposes.

If you have any concerns about our use of your information, you also have the right to make a complaint to the relevant Data Protection Authority who regulate and supervise the use of personal data in the EEA.