Last Updated on August 29, 2023

1. About this policy

World Manager Pty Ltd ABN 091 177 034 (herein referred to as ‘World Manager’, ‘we’, ‘us’ or ‘our’) is committed to protecting the privacy of your personal information in accordance with relevant privacy laws in Australia and those countries in which we operate.

Our Privacy Policy sets out how we, and our related entities, collect, use, disclose and manage your personal information and complies with the Australian Privacy Principles set out in the Privacy Act 1988 (Privacy Act) and the regulations set out in the General Data Protection Regulation 2016/679 (EU) (GDPR). Where applicable, World Manager complies with the Privacy Act, as well as the GDPR in relation to the collection, use, disclosure and management of your personal information.

We may from time-to-time review and update this Privacy Policy. If we update our Privacy Policy in any way, we will notify you and direct you to review the latest version of our Privacy Policy on this website (https://www.worldmanager.com/en-au/).  All personal information collected and held by us will be governed by the most recently updated Privacy Policy available on our website.

2. Consent

When you engage us to provide you with any goods or services, communicate with us through email, by telephone, in writing, participate in any of our promotional activities, or use any of our other services, including our website(s), you agree to the use and disclosure of your personal information in the manner described in this Privacy Policy. Where applicable, we may require you to confirm your express, explicit consent when collecting your personal information for the purposes of compliance with the Privacy Act and GDPR.

3. Types of personal information we directly collect

The kinds of personal information we may collect from you will depend on what type of interaction you have with us.  Information we may collect includes, among other things:

• personal identity particulars – such as your name, address, date of birth, occupation, telephone number(s) and e-mail address;
• personal information you provide to us when you:
  • participate in a promotion, competition, promotional activity, survey, market research or when you subscribe to our mailing list; and/or
  • install and use a World Manager App from the Google Play Store;
• your records of communication with us;
• your website usage information when you visit our website, such as your IP address which is collected through our use of Cookies;
• The Android Advertising Identifier for notifications (when available on a device); and
• Your location information based on GPS or WIFI for geotagging (when enabled).

4. The purpose for collecting your personal information

You agree that we may collect and use your personal information for the primary purposes of:

• our general business operations;
• effectively providing you with our goods and services;
• communicating with you;
• sending notifications to your device;
• responding to your inquiries or complaints;
• meeting our legal and regulatory obligations;
• conducting, improving and developing a relationship with you;
• direct marketing (such as providing you with information about our products and promotional notices and offers); and
• improving our websites and World Manager

Your personal information is only collected by lawful and fair means and where practicable, only from you or from a person acting, or authorised to act, on your behalf.

We will take reasonable steps to ensure that you are aware of:

• the likely use of the information;
• the right of access to the information;
• the identity and contact details of our employee/representative collecting your personal information;
• any law requiring collection of the information; and
• the main consequences of failure to provide your personal

5. How we may use and disclose your personal information

We may use your personal information for:

• the primary purposes for which it was collected, such as those described in paragraph 4 above;
• administering and responding to your enquiry or feedback about our products and/or services;
• conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity survey;
• promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing); and
• improving the operation of our website(s).

We may disclose personal information we collect from you:

• to our related companies, suppliers, consultants, contractors or agents for the primary proposes for which it was collected or for other ancillary purposes directly related to the purpose for which the personal information is collected. For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product;
• for direct marketing by us but giving you the opportunity to opt out of such direct marketing;
• to relevant Federal, State and Territory medical, health and safety authorities (as reasonably required);
• where the law otherwise requires or authorises us to do so;
• to others that you have been informed of at the time any personal information is collected from you;
• to third parties with your consent (express or implied).

We do not disclose your personal information for any secondary purposes unless your consent has been given or as required by law, and we will not sell or license any personal information that we collect from you.

6. How your personal information is stored and secured

We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.

In the event of a data breach, such as the unauthorised loss, use or disclosure of personal information, we will assess and respond in line with our applicable policies and procedures, which incorporate the requirements contained in the Privacy Amendment (Notifiable Data Breaches) Act 2017. Pursuant to our obligations under the Privacy Act, we will notify you where your personal information is involved in an eligible data breach as defined in the NDB scheme laid down in the Privacy Amendment (Notifiable Data Breaches) Act 2017 that is likely to result in serious harm. Such notification will also include making recommendations about the steps you should take in response to the breach. The Australian Information Commissioner (Commissioner) will also be notified of any eligible data breach where we have an obligation to inform the Commissioner.

We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identify your personal information if the primary purpose is not applicable anymore and/or we no longer need to retain it for business purposes. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.

7. Using our Website and Cookies

As with the vast majority of websites, when you visit our website or use an application on our website, we record anonymous information such as IP address, time, date, referring URL, pages accessed and documents downloaded type of browser and operating system.

Our website uses “Cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal information. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use our website, but the website may be limited in the use of some of the features.

Our website may also contain links to or from other websites. We are not responsible for, and have no control over, the privacy practices of other websites. This privacy policy applies only to the information we collect from you on our website. We encourage you to read the privacy policies of other websites you link to from our website.

8. Marketing and Opting-Out

We will only send out marketing and communications to those persons registered as “Administrators” on an Account.

We may send out communications to Administrators for the purposes of:

• promoting and marketing our current and future products and services;
• informing you of upcoming events and special promotions and offers; and
• asking that you participate in analysing our products and services so as to improve and develop new products and services.

We may disclose Administrator’s personal information to our related entities so our related entities can assist in the marketing of our products and services to you.

We will only offer Administrators products or services where we reasonably believe that they could be of interest or benefit.

At the point we collect information from you, you may be asked to “opt in” in order to consent to us using or disclosing your personal information. You will be given the opportunity to “opt out” from receiving marketing communications from us. You may also “opt out” from receiving these communications by clicking on an unsubscribe link at the end of any marketing email you receive from us or by contacting us with this request at any time.

9. Cross border disclosure

Your personal information may also be processed by, or disclosed to, employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us in connection with the primary purposes in paragraph 4 above, in other countries, including:

1. United States of America; and/or
2. Canada (approved by the European Commission).

For example, we may use a server hosted overseas in the abovementioned countries to store our data, which may include but not be limited to your personal information.

We will take reasonable steps, in these circumstances, before your personal information is disclosed to any entity operating overseas, to ensure that the overseas recipient observes and complies with the Australian Privacy Principles and does not knowingly breach any privacy laws to which they are bound in relation to your personal information which includes the Privacy Act and GDPR (‘the Reasonable Steps’).

The Reasonable Steps may not apply if you consent to the disclosure of your personal information to an overseas recipient and we reasonably believe that the overseas recipient is subject to laws that are suitability similar to privacy laws in Australia.

If you expressly consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under the Privacy Act, and you may not be able to seek redress for breaches under the Privacy Act.

10. Accurate and up-to-date information

We will ensure that every reasonable step is taken to ensure your personal information is accurate, up- to-date and not misleading by updating our records whenever true and correct changes to the data come to our attention.

If you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting our Privacy Officer. To contact our Privacy Officer please see contact details below in paragraph 20.

We will rectify without delay any information we hold about you if we discover, or you are able to show to a reasonable standard, the information is incorrect. If you seek correction and we disagree that the information is incorrect, we will provide you with our reasons for taking that view.

We disregard information that seems likely to be inaccurate or out-of-date by reason of the time that has elapsed since it was collected or by reason of any other information in our possession.

11. Access to your personal information

We acknowledge that you have a general right of access to information concerning you, and to have inaccurate information corrected. Where your information is governed by the GDPR you may also request information about the collection and envisaged use of the information that we hold. You are able to access the personal information we hold about you and request this information by contacting our Privacy Officer. If access is refused to your personal information for reasons permitted by the Privacy Act and/or GDPR, we will give you a notice explaining our decision to the extent practicable and your options.

To contact our Privacy Officer please see contact details below. If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons. We may charge a reasonable administration fee to cover the costs of meeting your request. We will reply to your request for access within 30 days of receiving such a request from you.

12. Data Subject Rights

Where applicable under the GDPR, and in addition to the rights set out above, you have the following rights regarding your personal information stored with us:

1. The right to object to your personal information being processed;
2. The right to data portability of your personal information;
3. The right to complain or query how we process your personal information;
4. The right to object to automated decision making using your personal information; and
5. The right to have your personal information forgotten by us.

13. Data Controller and Data Processor

You acknowledge that when using our software applications:

• you will be deemed to be the data controller in relation to any personal information collected and stored and as such will be responsible for how that personal information has been collected. You must ensure that you obtain consent and provide notice to any persons as required under the Privacy Act and/or GDPR in relation to the collection, storage and use of such personal information; and
• we act as a data processor only in relation to personal information and data entered, collected and stored on our software applications by you. We will only access such data in accordance with written instructions given by you, or unless required to do so by the Privacy Act and/or the GDPR.

14. Dealing with unsolicited information

We take all reasonable steps to ensure that all unsolicited information is destroyed or de-identified immediately or as soon as is reasonably practicable.

15. Anonymity when dealing with us

Only where it is practicable to do so, we may allow you the option not to identify yourself when dealing with us. However, if you refuse to provide us with certain information, this may limit or hinder our ability to interact or transact with you.

16. Collecting sensitive information as defined under the Privacy Act

World Manager does not collect sensitive information, unless it is specifically relevant and necessary for the primary purpose of our business activities and functions, and your consent is first obtained. Any and all sensitive information that may be collected is collected, disclosed and stored in accordance with this Privacy Policy and at all times in accordance with the Australian Privacy Principles.

17. Government identifiers

We do not use government identifiers (e.g., tax file numbers or Medicare numbers) to identify individuals.

18. Users of our website

Nothing on our website is targeted at or intended for use by any person under the age of 13. The use of our website and products and services advertised on our website are directed at, and relevant for, businesses and individuals above the age of 18.

19. Complaints and disputes

If you have reason to believe that we have not complied with our obligations relating to your personal information under this Privacy Policy, the Privacy Act or GDPR, please refer any complaint or queries to our Privacy Officer (details of which you can find in paragraph 20 below).

We will ensure your complaint is handled by our Privacy Officer in an appropriate and reasonable manner and in accordance with the Privacy Act (where applicable). Where necessary, we may consult with our related entities and partners in order to deal with your complaint. A written notice of our decision regarding your complaint will be provided to you within a reasonable timeframe.

If you are not satisfied with the outcome, and where your complaint relates to personal information governed under the Privacy Act, you may contact the Office of the Australian Privacy Commissioner details as follows:

Office of the Australian Information Commissioner

Website: www.oaic.gov.au

Phone: 1300 363 992

If you are not satisfied with the outcome, and where your complaint relates to personal information governed under the GDPR, you may contact the supervisory authority in the particular Member State of your residence, place of work or place of infringement.

20. Who should you contact for further information?

Please refer any queries or complaints about our Privacy Policy or privacy issues to our Privacy Officer who may be contacted at the following address or by phone or email as follows:

Privacy Officer

World Manager Pty Ltd
Level 14, Suite 3, 383 Kent Street
Sydney NSW 2000
Australia

P (Australia): +61 2 8005 4271
P (North America): +1 (214) 297 0006 ext. 1
Email: privacy@worldmanager.com

Our Privacy Officer will consider your question or complaint and respond to you in a reasonable timeframe.