Privacy Policy

The original version of this privacy statement was written by Roger Clarke
and can be found at: http://www.anu.edu.au/people/Roger.Clarke/DV/PST.html


EB Strada's Privacy Statement

This document declares the undertakings by EB Strada in relation to its handling of Your Data.


Contents


Data Collection

EB Strada undertakes to collect Your Data by means that are:

If you visit EB Strada's web-site, your web-browser automatically discloses, and EB Strada's web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.

Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.

Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as EB Strada.com). This data may or may not be sufficient to identify you.

If you disclose personal data to EB Strada in conjunction with an identifier such as your name or your credit-card details, EB Strada will collect Your Data. Moreover, any data that becomes available to EB Strada through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.

Subject to the qualifications immediately below, EB Strada undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:

Where EB Strada collects Your Data from sources other than you, it undertakes:

EB Strada undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.


Data Security

EB Strada undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

EB Strada undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.

EB Strada undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

EB Strada undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by EB Strada's staff-members and contractors. These include:


Data Use

Use refers to the application of Your Data by any part of EB Strada, or any staff-member or contractor of EB Strada in the course of their work.

EB Strada undertakes to use Your Data only for:

EB Strada undertakes to use Your Data only if it has demonstrable relevance to the particular use to which it is being put.

EB Strada undertakes to use Your Data in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.


Data Disclosure

Disclosure refers to making Your Data available to any party other than EB Strada and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.

EB Strada undertakes to disclose Your Data only under the following circumstances:

In all cases, EB Strada undertakes to disclose only such of Your Data as is necessary in the particular circumstances.


Data Retention and Destruction

Subject to the qualifications immediately below, EB Strada undertakes:

This undertaking is qualified as follows:


Access by You to Your Personal Data

EB Strada undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, EB Strada undertakes to enable access:

EB Strada undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with EB Strada (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.

In the event that you dispute some aspect of Your Data, EB Strada undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.

You undertake:


Information about Data-Handling Practices

EB Strada undertakes to make information available to you about the manner in which EB Strada handles your data:

Where Your Data is disclosed to a contractor, EB Strada undertakes to make information available to you on request about the manner in which EB Strada's contractors handle your data.

EB Strada undertakes to ensure that the information provided is meaningful, and addresses your concerns.

You undertake:


Handling of Enquiries, General Concerns and Complaints

If you have enquiries, general concerns, or complaints about these Terms, or about EB Strada's behaviour in relation to these Terms, you undertake:

EB Strada undertakes:

You further undertake to not pursue EB Strada through any Regulator or the media:


Enforcement

EB Strada declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.

You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and EB Strada, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which EB Strada is domiciled or performed the relevant acts.

If you wish to discover the relevant laws in any particular jurisdiction, EB Strada draws your attention to the following resources:


Changes to These Privacy Undertakings

EB Strada undertakes:


Definitions

EB Strada means EB Strada Pty Ltd.

Your Data means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that EB Strada is capable of correlating with you, using such means as server-logs and cookie-contents.

Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.

Consent means your concurrence with an action to be taken by EB Strada. Consent may be express or implicit, but in either case must be informed and freely-given.