Welcome to Cecil. We value the trust you place in us when providing us with your Personal Information, and we aim to protect your information to the highest of standards as we provide our products and services to you and in accordance with the Australian Privacy Principles ("APPs"), which are set out in the Privacy Act 1988 (Cth).
2. What is Personal Information
The term “Personal Information” means any information, opinion, or data that we collect about an individual where that individual is identified or where that individual is reasonably identifiable. It also includes “personal data”, or similar terms as defined in any applicable privacy or data protection laws.
“Personal Information” is information or opinions about you which:
can be used to identify, contact, or locate you; or
can be combined with other information that is linked to you.
If you can’t be identified (for example, when Personal Information has been aggregated and anonymised) then this notice doesn’t apply.
A subset of Personal Information is “Sensitive Information”. Sensitive information includes information or an opinion about a person’s race, gender diversity, sexual orientation, disability, ethnic origin, political opinions, membership of a political association, membership of a professional or trade association, heath, religious or philosophical beliefs, and criminal history.
At Cecil Earth Pty Ltd ACN 647 150 972 (collectively with any subsidiaries and affiliates, “Cecil”, “Company”, “we”, “us” or “our”), we are committed to safeguarding the privacy of our customers and end-users (“you” or “your”) who visit our websites, use our Services, or engage with us in any way.
offline communications such as phone calls or site visits (“Offline Communications”); and
our social media, online products, tools, and services,
(together, the “Services”).
The Cecil Platform
For much of the Personal Information processed through the Cecil Platform, we act as a processor/service provider and will only process such information on behalf of and in accordance with the instructions of our customers.
Use of the Cecil Platform is governed by the Terms of Service and a separate agreement, if applicable (“Agreement”), that covers the use and processing of data provided by users, which may include Personal Information, as well as other information or documents uploaded into the Platform.
4. How is your Personal Information collected and what do we collect?
The types of Personal Information we may collect, and hold will vary depending on your dealings with us through your use of our Services. We may collect Personal Information in several ways, including from you directly, automatically when using our Services, or through third parties.
a) Information You Provide to Us Directly
We may collect Personal Information from you as a customer or end-user of our Services and/or interact with our websites and platforms, dealing with you in person or over the phone, subscribing to our newsletters or mailing lists, virtually through electronic communications including emails, SMS or video conference and when you will out and submit registration forms, and customer feedback or survey forms. The information we may collect includes, without limitation:
your name, phone number, and other contact details, including the company you work for;
your username, password, and email when you register for an account to interact with portions of the Site;
the profile information you provide us when you create your account profile to use certain areas of the Sites or Cecil Platform;
information you provide for technical support or customer service requests including via chat, email or Offline Communications;
site tools such as cookies;
any information that you upload to the Sites and/or input into your account; and
any other information you may provide to us voluntarily through your use of our Sites.
We may also collect Personal Information when you interact with us, such as when you use our websites or through other people when you use services associated with our Sites, communicate with us via email, telephone, social media or chatbots, make enquiries regarding demos, or when we collect feedback from you on the Services we provide. The Personal Information we may collect in these circumstances include individual or business name, address, email, phone number, company/employer, job function, team size, the date, time, and reason for contacting us, survey and research responses, social media information, and call recordings.
b) Information We Collect Automatically
We automatically collect usage information when you browse our websites or use our Services to improve our Services and enhance your user experience.
This information includes:
use names, member names, email addresses and other contact details;
your actions on our Sites (including any selections or inputs into items);
digital interactions data, i.e., how you use our digital properties (including our websites);
financial and/or transaction details from payment providers located in Australia, New Zealand and the UK in order to process a transaction tax information;
support queries and forum comments (if applicable);
social media sites;
apps and electronic communications;
metadata (collected on an anonymous basis);
consumer analytic data (collected on an anonymous basis but which can be attributed to you based on other information we have about you);
log file information;
information about the type of device and operating system used by you;
computer IP addresses; and
marketing and cookie preferences, including any consent you have given us.
We may share this usage data with third parties for legitimate business purposes, including to help us better understand our customers’ needs and improve the Sites and Cecil Platform to enhance our Services.
c) Information from third parties
We collect certain categories of Personal Information about you from other sources including without limitation:
financial and/or transaction details from payment providers located in multiple jurisdictions, including Australia, New Zealand and UK in order to process a transaction;
third party service providers (like Google, Facebook) which may provide information about you when you link, connect, or login to your account with the third party provider and they send us information such as your registration and profile from that service;
other third party sources/and or partners from multiple jurisdictions, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive information about you and your activities on and off the Cecil platform through partnerships, or about your experiences and interactions from our partner ad networks.
If someone has entered your Personal Information onto our platforms or apps on your behalf, you’ll need to contact that user for any questions you have about your Personal Information (including when you want to access, correct, amend, the information, or request that the user delete your Personal Information).
5. How we use your Personal Information
The primary purpose for which we collect Personal Information about you is to enable us to perform our business activities and provide our Services to you.
We collect, hold, use, and disclose your Personal Information for the following purposes:
to provide our Services to you, including our Cecil Platform;
to manage and enhance our Services, to personalise and customise your experience with our Services, and to provide you with any necessary support to receive our Services;
to provide you with information about our existing and new products and services (including for direct marketing purposes as described below);
research, and data analysis;
in an ongoing effort to better understand and serve the users of the Sites and Cecil Platform, Cecil may conduct research on its Customers’ and users’ demographics, interests, and behaviour based on usage data and other information provided to us;
surveys and other special offers from time to time;
Cecil Stories (Customer highlighted stories and imagery);
to fulfill any orders or request for Services you may place as offered by Cecil Sites and the Cecil Platform;
testimonials (we display personal testimonials of satisfied customers on our Sites in addition to other endorsements;
providing customer service;
to verify your identity and enable us to monitor suspicious or fraudulent activity;
to investigate any complaints made by you, or made about you;
to investigate any fraudulent activity or suspected breach of any of our terms and conditions or unlawful activity engaged in by you;
updating you with operational news and information about our Sites and services e.g. to notify you about changes to our Sites including the Cecil Platform;
providing general administrative and performance functions and activities;
disruptions or security updates; for any other purpose we reveal to you at the time of collection; and
to meet our obligations and exercise our rights under applicable laws.
We may use Personal Information for the purpose of allowing third parties to provide additional products and services to you where you made such a request or have given us consent to do so.
If you do not provide us with the Personal Information described in this policy:
we may not be able to provide you with information about our Services that you requested;
we may not be able to provide you with a subscription and access to our Services that you requested; and
we may not be unable to tailor the content of our Services to your preferences and your experience of our Services may not meet your desired needs.
6. How can we share your Personal Information
our employees, Related Bodies Corporate, contractors for the purposes of the delivery and operation of our Services, and fulfilling requests by you;
our Related Bodies Corporate for the purposes of the delivery of their services to you where you have subscribed to their services, or where they integrate with us to provide our Services;
web hosting providers and technical customer support services;
our professional advisers (lawyers, accountants, financial advisers etc);
regulators and government authorities in connection with our compliance procedures and obligations;
our existing or potential agents, business partners or joint venture entities or partners to enable us to perform our business activities and provide our products and services to you;
relevant third parties in connection with or contemplation of (including as part of due diligence process) any merger, acquisition, reorganisation, financing, sale of assets or insolvency event involving us or our affiliates;
your employer, if you use our Services in connection with your employment and your employer has established an account on your behalf;
sharing aggregated data or data that has been stripped of personally identifying characteristics with third parties; and
the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator if required by law or we consider it necessary for the protection of our systems or for the prevention or detection of illegal activity.
In addition to the above, we may disclose your Personal Information to specific third-party service providers who facilitate the delivery of our Services and operation of our business activities. We disclose your Personal Information to such third parties as doing so may be necessary to adequately provide our Services to you, or to assist us in analysing how our Services are used and ensure they are provided to you at the highest quality. These third parties are given access to your Personal Information only to perform these tasks on our behalf or for our benefit and are required not to disclose or use it for any other purpose.
7. Overseas disclosure
Your Personal Information may be transferred to and processed in countries other than the country in which you are a resident. These countries may have data protection laws that are different from the laws of your country.
8. Do we use your Personal Information for direct marketing?
We may use Personal Information for direct marketing reasons by providing you news or information about our Services that you either request from us, or we believe may interest you. These communications may be sent in various forms, including mail, social media, or email.
You can opt out of receiving our direct marketing communications at any time by using any of our unsubscribe or opt-out mechanisms provided within our method of communication to you, or by contacting firstname.lastname@example.org.
We may still send you transactional or administrative communications related to our Services even after you have opted out of receiving marketing communications.
9. Storage & Security
At Cecil, we’re serious about information security, and maintain administrative, physical and technical safeguards for protection of the security, confidentiality and integrity of your data. Our managed services within our AWS infrastructure supports encrypted and automated back up of data stored in our cloud platform. We also conduct an annual Well Architected Review with an accredited AWS partner to ensure compliance with best practices of the Well Architected Framework. Further details on our third-party storage provider’s location and security can be found here. We also contractually require that our Service Providers protect such information from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
You should be aware that no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Sites, we cannot and do not guarantee the security of any information you transmit on or through the Sites. Accordingly, you disclose Personal Information to us at your own risk, and we will not be liable for any unauthorised access, modification or disclosure, or misuse of your personal information.
You can also play an important role in keeping your Personal Information secure, by maintaining the confidentiality of any password and accounts used on the Services. Please notify us immediately if there is any unauthorised use of your account by any other Internet user, or any other breach of security relating to your account via email at email@example.com.
10. GDPR Compliance
11. Cookies and statistical analysis
IP address or server address;
date and time of visit;
length of your session;
the pages which you have accessed;
the number of times you access our Sites within a period of time;
the file URL you look at and information relating to it;
the website which referred you to our Sites;
the operating system which your computer uses; and
previous websites visited; and
You can remove persistent cookies and change your privacy preferences provided in your Internet browser. However, certain features of the Sites or Cecil Platform may not work if you delete or disable cookies. Some of our service providers may use their own cookies and web beacons in connection with the services they perform on our behalf, as further explained below.
12. Third-Party Links
The Services may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website. Third-party websites are responsible for informing you about their own privacy practices and policies.
13. Access to, and correction or deletion of your Personal Information
We will endeavour at all times to maintain an accurate record of your Personal information. To assist us in keeping our records up to date, you should ensure all Personal Information provided to us is accurate and up to date, and to notify us of changes where appropriate.
You have the right to request access the Personal Information which we hold about you and for corrections to be made to this information. If you wish to verify or correct any of the details you have submitted to us, you may do so by contacting us via email at firstname.lastname@example.org. There are some circumstances in which we are not required to give you access to your Personal Information. Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.
We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database. We will not charge you for making the request.
If you are an employee whose Personal Information has been uploaded to our platforms or apps by your employer, you may need to ask your employer to delete the Personal Information on your behalf. Your employer will then request us to delete it from our systems.
Our security procedures mean that we may request proof of identity before we reveal Personal Information. This proof of identity will take the form of your e-mail address and password submitted upon registration. You must therefore keep this information safe as you will be responsible for any action which we take in response to a request from someone using your email and password.
We’ll retain your Personal Information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policy and practices. Following that period, we’ll make sure it’s deleted or anonymised.
15. Your Rights
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to use some of our features. If we have collected and processed your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
Please note that we may still use any aggregated and de-identified Personal Information that does not identify any individual, and may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
We will respond promptly to all requests we receive from individuals wishing to exercise their data protection rights.
Cookies: You can accept or reject cookies for our websites by adjusting your web browser controls.
Marketing Communications: You can opt out of receiving promotional or marketing communications from us at any time by using the unsubscribe link in the email communications we send. To opt out of non-email forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided in the How to Contact Us section below. If you set up an account on our Sites, we will still send you non-promotional communications like service-related emails.
Upon request, Cecil will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. You can always review, correct, delete, or update your Personal Information by emailing us at email@example.com.
Exercise your Rights
To exercise any of the rights as described in this section, please submit a verifiable request to us by emailing us at firstname.lastname@example.org. Only you or someone legally authorised to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable request on behalf of your minor child.
16. Enforcement and complaints
Once we receive a complaint, we will commence an investigation as soon as practicable. We may contact you during the process to seek any further clarification if necessary. We will also contact you to inform you of the outcome of the investigation and if appropriate to confirm how we will comply with our obligations under the Privacy laws in relation to a notifiable data breach.
We will aim to ensure that all questions and concerns are resolved in a timely and appropriate manner. If you are not satisfied with the outcome of your complaint, or require further information on privacy, you are entitled to contact your local data protection supervisory authority.
18. Contact us
If you have questions or concerns about our use of your Personal Information, please contact us by email at email@example.com.
19. Our other Privacy Policies