Privacy Policy
1. Introduction
1.1. The mobile application (the Salt Diary App), the products and services made available the Salt Diary App and our website https://www.saltdiary.com/) are owned and operated by Salt Diary Pty Ltd (ACN 696 461 122) (our, us or we).
1.2. We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
1.3. By accessing and using our website, the Salt Diary App and/or our products or services, you agree to this Privacy Policy.
1.4. This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
2. The information we collect about you
2.1. Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
2.2. We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our website, the Salt Diary App and our products and services to you, or as otherwise permitted by law.
2.3. The type of Personal Information that we collect, and use depends on the type of dealings that you have with us and includes the following:
- your account registration information (for example, your full name, email address and boat name), and your account credentials (such as your username and password created by you as a user of the Salt Diary App);
- any content, information, ideas, images, pictures and videos and other data that you post or receive on, or via the Salt Diary App or data or information that is generated by the Salt Diary App (such as photographs or images of the fish species caught by you, the geolocational coordinates of your fishing locations and where you caught a fish, the date and time you caught a fish, the identify of the fish species caught by you and other information and metric about the fish species caught by you and [anything else?]);
- marketing data and information relating to your dealings, or enquiries you have made, with us, including information about: (i) the products and services you have accessed and used; (ii) the third party products and services have used or enquired about; and (iii) what features or functions of the Salt Diary App you have used and how you have used such functions and features;
- device information which is automatically collected from you when you visit, navigate and use the Salt Diary App and our website. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Salt Diary App, our and our website, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Salt Diary App, our website and other usage statistics; and
- other information that you provide to us or that we may collect in the course of our relationship with you.
2.4. We may also collect:
- some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use the Salt Diary App; and
- if you are a candidate seeking employment with us. We will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future employment opportunities.
2.5. We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.
2.6. If you have accidentally sent us Sensitive Information, please contact us using the details below.
3. How we collect Personal Information
3.1. We will collect Personal Information and non-Personal Information about you in a number of different ways. We may collect Personal Information directly from you or in the course of our dealings with you. For example, when you:
- setup and create an account on the Salt Diary App (including when you edit or update your account on the Salt Diary App or when you create or reset your password);
- access and use the Salt Diary App, our products and services (including when you using your camera to take photographs of your fish catches, when you log your fish catches and when you use our artificial intelligence fish species recognition system to identify your fish catch and [anything else?]);
- contact or correspond with us online (for example, when you complete online forms, or subscribe to our publications, alerts and newsletters), request customer support services, contact us via email or telephone with a query or request or make a comment on our social media sites or you participate in a promotion, competition or survey; or
- from publicly available sources of information.
3.2. When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.
3.3. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us. We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:
- when you provide your Personal Information to our Third Party Providers; and
- if you use our social media sites or applications, pages or plugins or third party products or services that interact with the Salt Diary App (such as our third party payment processors).
3.4. If you provide us with Personal Information about another user, we rely on you to:
- inform them that you are providing their Personal Information to us; and
- advise them that they can contact us for further information.
4. How we use your Personal Information
4.1. We only use, process and disclose your Personal Information for the purposes for which it is collected. We will not sell your Personal Information or share it with anyone not authorised to access it. In particular, we use, process and disclose your Personal Information to:
- provide or deliver the Salt Diary App, our website and our products and services to you;
- inform you about the Salt Diary App, our products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Salt Diary App or other matters which we believe are of interest to you (such as recruitment or job opportunities);
- manage, administer, improve, test, develop and upgrade the Salt Diary App, our products, services and website, (including content on our website), informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the Salt Diary App;
- to perform research and analysis in relation to: (i) fish stock sustainability and marine biodiversity; (ii) our products, service and the Salt Diary App, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your information (such as fishing logs and geolocation information) for this purpose, we ensure any Personal Information is de-identified and anonymised so that you cannot be identified using your data;
- share with our Third Party Providers;
- customise the content on the Salt Diary App;
- charge and bill you to access and use the Salt Diary App and our other products and services;
- for direct marketing purposes (see section 6 below); and
- complying with our legal and regulatory obligations.
4.2. We may use de-identified Personal Information and other aggregated statistical data related to the use of the Salt Diary App, our products and services to administer and monitor the use of the Salt Diary App, our products and services, for our internal business improvement purposes, benchmarking, market and industry research, and for use in commentary, media releases and other publications.
4.3. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
5. Disclosure to Third Party Providers
5.1. In order to provide or deliver the Salt Diary App, our products, services and website to you, we may disclose your Personal Information to:
- our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers, external business advisors or other authorised external service providers who perform functions on our behalf (such as credit reporting bodies, credit providers, third party payment processors, hosting companies, online security and user authentication service providers, web developers, internet service providers, telecommunication providers, location service providers, customer service providers, customer support specialists, fulfilment companies, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us to (for example, previous employers and referees), recruitment agencies and from publicly available sources of information (for example, online databases and social media)) (collectively, Third Party Providers);
- law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law or emergency service operators or first responders in an emergency to prevent the loss of life or personal injury; and
- external business advisors, such as auditors, lawyers, insurers and financiers.
5.2. We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party payment processors, Apple Pay and Googe Pay, whose use of your Personal Information is governed by their privacy policies, which may be viewed at viewed at:
- www.apple.com/au/legal/privacy/data/en/apple-pay; and
- https://payments.google.com/payments/apis-secure/get_legal_document?ldo=0&ldt=privacynotice&ldl=en
5.3. Prior to the disclosure of Personal Information to Third Party Providers, we will take such steps as reasonable in the circumstances to ensure that the Third Party Providers treat your Personal Information securely and otherwise complies with the relevant Australian Privacy Principles in relation to the Personal Information.
6. Marketing communications
6.1. We may use and disclose your Personal Information to send you information about the Salt Diary App and the products or services we offer, as well as other information that may be of interest to you. We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media or by customising online content and displaying advertising on our website.
6.2. If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out in section 12 below.
7. Overseas disclosures of Personal Information
7.1. In the course of providing you with the Salt Diary App, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose your payment information to our third party payment processor, Apple Inc. (App Pay) and Google LLC (Google Pay), who manage subscription billing on or behalf. Our third party payment processors are located outside of Australia, including United States, Taiwan, Japan and elsewhere in the world.
7.2. The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, we will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
8. Notifiable Data Breaches Scheme
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.
9. Cookies, Tokens and Analytics
9.1. Cookie policy
- We use small text files placed on your computer called ‘cookies’ to collect standard log and visitor behaviour information in an anonymous form. We use this information to analyse how visitors use our website and to compile statistical reports on website activity.
- You can set your computer to reject cookies, but this may affect your ability to use certain parts of our website.
9.2. Tokens
We use access and authentication tokens to verify your identity and grant you permission to access and use the Salty Diary App and to securely store your Personal Information and Non-Personal Information from unauthorised access.
9.3. Apple Analytics
- Services that our website may use from time to time include Apple Analytics, which transmits website traffic data to Apple servers. Apple Analytics does not identify or track individual users or associate your IP address with any other data held by Apple. We use reports provided by Apple Analytics to help us understand traffic and usage on the Salt Diary App. By using the Salt Diary App, you consent to Apple processing your data in the manner described in Apple’s Privacy Policy (www.apple.com/legal/privacy) and for the purposes set out in this Privacy Policy.
- The data collected by Apply Analytics includes, but is not limited to, App installations and deletions, app usage (number of sessions, active devices), crashes and performance metrics, app store engagement (downloads, impressions, conversion rates), device information (device model, OS version, country/region), in-app purchases and subscriptions (revenue, retention, purchase behavior) and app source (how users found the app: search, referral, ad campaign).
9.4. Google Analytics
- Services that the Salt Diary App and our website may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on the Salt Diary App and our website. By using the Salt Diary App and our website, you consent to Google processing your data in the manner described in Google’s Privacy Policy (https://policies.google.com/privacy?hl=en-US) and for the purposes set out in this Privacy Policy.
- Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://tools.google.com/dlpage/gaoptout).
10. Security and destruction of your Personal Information
10.1. We take steps reasonable in the circumstances to ensure that the Personal Information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
10.2. We protect your information using physical, technological and administrative security measures to minimise and manage the risks of unauthorised access, disclosure, use and alteration of your Personal Information.
10.3. The transmission of information via the internet is not completely secure. While we do our best to protect Personal Information, we cannot guarantee the security of any Personal Information transmitted through the Salt Diary App. You provide your Personal Information to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, such Personal Information.
10.4. When you delete your account with us, we will destroy or de-identify your Personal Information within 30 days or earlier in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.
11. Accessing and correcting your Personal Information
11.1. We will take reasonable steps in the circumstances to ensure Personal Information we hold is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have the right to access and seek correction of your Personal Information that is collected and held by us.
11.2. If at any time you would like to access or correct the Personal Information we hold about you, or you would like more information about our approach to privacy, please contact us via the contact details set out in section 12 below. If we refuse your request to access or correct your Personal Information, we will provide you with written reasons for the refusal and details of complaint mechanisms.
12. Privacy complaints
If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information or would like to discuss any issues about our Privacy Policy, please contact us directly by email at admin@saltdiary.com.
13. Changes to this Privacy Policy
From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our website. We encourage you to check our website from time to time to ensure you are familiar with our latest Privacy Policy.