Privacy

1. INTRODUCTION

This policy applies to our websites (including www.ruminati.com.au and vision.ruminati.com.au), our platform and all services we provide, including any other apps or services we may offer (for example, events or training). For the purpose of this policy, these are referred to as our services.

In this policy the term personal data means all information which reasonably identifies you (as an individual), including (but not limited to) your name, email, address, telephone number, bank account details, payment information. If you can’t be reasonably identified from certain data (for example, where data has been aggregated and anonymised), then this policy doesn’t apply to that data.

We may update this privacy policy from time to time. Typically we will provide a minimum of 7 days' notice before the changes take effect.

2. WHO WE ARE

When we refer to ‘we’ (or ‘our’ or ‘us’), that means Ruminati Technology Pty Ltd ACN 665 392 781 of 82 Glenmore Road, Paddington NSW 2021 and all of its subsidiaries. We provide an easy-to-use online platform for farmers and other organisations to measure, track, manage, share, analyse, report and validate on-farm climate information.

3. HOW WE COLLECT YOUR DATA

When you visit our websites or use our services, we collect personal data, including:

• names;

• your role/occupation within an organisation;

• email and postal addresses;

• telephone numbers;

• bank account details and other payment information; and

• certain information relating to usage and access of our websites and services (e.g. IP addresses, device types, pages/locations of websites accessed and duration of access). 

The ways we collect such personal data can be broadly categorised into the following:

• Information you provide to us directly: When you visit or use some parts of our websites and/or services we might ask you to provide personal data to us. If you don’t want to provide us with personal data you will not be able to use some parts of our websites or services.

• Information we collect automatically: We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at, what links you clicked on and the duration of access/use. Some of this information is collected using cookies, clickstream, data analytics and similar tracking technologies.

• Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials, persons you have authorised (e.g. your authorised accountants, agronomists or other consultants) or other trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.

4. CAN I REMAIN ANONYMOUS?

You can choose to deal with us anonymously or by using a pseudonym.  However, please note that if you choose to remain anonymous or use a pseudonym, this may affect your ability to access or use certain functions of our websites or services.

If you wish to remain anonymous or use a pseudonym when dealing with us via a telephone call, please advise the call operator assisting you. We note that providing your personal details enables us to provide you with a contact record reference number which allows you, and other authorised persons, to retrieve information about that call at a later date.

5. HOW WE USE YOUR DATA

Where we collect personal data, we’ll only hold, disclose, use and otherwise handle it for the purposes set out in this policy, including: 

• operating our websites and providing you with any services you’ve requested;

• managing our relationship with you;

• providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you;

• operational communications, like changes to our websites and services, security updates, or assistance with using our websites and services;

• marketing communications;

• asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with);

• assisting with the resolution of technical support issues or other issues relating to our websites or services, whether by email, in-app support or otherwise;

• tracking and monitoring your use of our websites and services so we can keep improving them;

• carrying out technical analysis of our websites and services so that we can provide you, and other users, a better experience and more efficient tools;

• detecting and preventing any fraudulent or malicious activity;

• making sure that everyone is using our websites and services fairly and in accordance with the applicable terms of use; 

• producing aggregated and anonymised analytics and reports, and other derivative data sets which we may share publicly or with third parties (in anonymised form);

• performing any contract we have with, or a service we provide to, you;

• complying with our legal obligations;

• establishing, exercising, or defending our legal rights;

• any purchase, merger or acquisition of our business.

We may also use your personal data where we are permitted or required by law to do so or where we otherwise have your consent. 

If we don’t collect your personal data, we may be unable to provide you with all our services, and various functions and features on our website may not be available to you.

6. HOW WE CAN SHARE YOUR DATA

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

• third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the websites or services, or to market or promote our goods and services to you;

• regulators, law enforcement bodies, government agencies, courts or other third parties to the extent reasonably necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;

• an actual or potential buyer (and its agents and advisors) in connection with an actual or proposed purchase, merger or acquisition of our business;

• third parties where you have requested, or consented to, your data being shared from your account on the third parties’ own platforms or services (and while you will be able to manually revoke this request or consent within the Ruminati platform, we will only stop sharing your personal data on a prospective basis and will not be able to necessarily call back any personal data previously shared at your request or with your consent);

• other parties where we have your express consent.

7. DISCLOSURE OF PERSONAL INFORMATION OUTSIDE AUSTRALIA

We may disclose your personal information to recipients located outside Australia. The countries in which those third party recipients may be located are New Zealand.

Where we disclose information outside of Australia, we will take reasonable steps to ensure that any such person to whom personal data is disclosed will deal with that information in a way that is consistent with the Australian Privacy Principles (as under the Privacy Act 1988 (Cth)).

8. MARKETING

We will use your personal information to offer you products and services we believe may interest you, if you have agreed to receiving such marketing. 

When you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

9. THIRD PARTY WEBSITES

Our websites may link to other sites which are outside our control, and other sites outside our control may link to our websites. Whilst we try to ensure that we link only to sites which share our privacy and security standards, once you have left our websites we cannot be responsible for the protection and privacy of any information which you provide on other sites. You should exercise caution and review the privacy statement applicable to the site in question.

10. SECURITY

We’re committed to protecting your personal data and have put in place appropriate technical and organisational measures to help make sure that happens. Where necessary and appropriate, we will:

• train our staff in how to keep your information safe and secure;

• undertake privacy impact assessments;

• restrict access to personal data to those who need access such information to conduct their designated responsibilities;

• implement physical, electronic and managerial procedures to safeguard the security and integrity of personal data;

• store your hard copy and electronic records in secure systems; 

• use trusted contracted service providers; and

• follow the guidance of the National Farmers' Federation's Australian Farm Data Code.

11. RETENTION

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements). We’ll retain your personal data 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 policies and practices. Following that period, we’ll make sure it’s deleted or anonymised. 

If we have shared your personal data pursuant to this policy with a third party, you acknowledge that we may not be able to procure deletion by such third party recipients (depending on the capacity and purposes on which that information was shared with the recipient).

12. HOW CAN I ACCESS OR CORRECT MY PERSONAL INFORMATION?

We have put in place measures to help ensure the information we hold about you is accurate, complete and up to date.

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.

If we refuse to provide you with access to your record or to update your record in the way you request, we will provide you with written reasons.

If we refuse to correct or update your information, you may request that we make a note on your record that you are of the opinion that the information is inaccurate, incomplete, out of date, irrelevant or misleading, as the case may be.

13. HOW CAN I MAKE A COMPLAINT?

If you have a complaint or concern regarding our handling of your personal information or think that your privacy has been affected, you should contact us using our contact details set out below to raise your complaint or concern. 

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled your privacy complaint or concern, you may approach an independent advisor or contact the OAIC. See the OAIC website (https://www.oaic.gov.au/) for more information about how to make a complaint.

14. HOW TO CONTACT US

If you would like to know what personal data we hold about you or you have a question for us regarding this policy, our websites or services, please contact us at hello@ruminati.com.au, your designated account manager (if applicable) or via the contact page on our websites.