Privacy Policy

Introduction

Spinsoft respects your privacy and is committed to the protection of it. This Privacy Policy applies to data collected by Spinsoft through the majority of its web sites and services. This policy also includes data collected by Spinsoft in offline venues. This policy does not apply to Spinsoft sites, services, products or other entities that do not display or link to this Privacy Policy or that have their own privacy statements.

Most private sector organisations in Australia are required by law to comply with Australian National Privacy Principles (hereinafter, "NPPs") and are subject to the Privacy Act 1988 (Cth). Spinsoft is bound by these NPPs and the Privacy Act 1988 (Cth).

Information Collected via the Spinsoft Website(s)

We may collect information about your visit(s) to our website(s), including the pages you view, the links you click and other actions taken in connection with Spinsoft websites and services. We also collect certain standard information that your web browser sends to every website you visit, such as your IP address, browser type and language, access times and referring web site addresses. In most occasions, except when investigating security-related issues or when required to do so by law or legal process, this information is kept apart from and will not be correlated or combined with any information that we may hold elsewhere that could personally identify you.

We may, at times, contract out functions pertaining to marketing-related activities that utilise this data. At all times such data is shared, it is divorced from any information that may be used by third parties to determine the identity of the individuals accessing the website.

Collection of Personal Information

In some interactions with Spinsoft, we ask you to provide personal information. Usually, this information is not of a sensitive nature, as defined in the NPPs. This personal information may include, based on the type of interaction:

Contact of Spinsoft via E-Mail or Fax (and via eSupport / Secure Helpdesk)

• In the case of Spinsoft Subscribers and former Subscribers, the Subscriber's Name, E-Mail Address, Facsimiles sent to us, and other information that clients may provide in their course of communication with us. This information can sometimes include the Subscriber's Telephone Number, Mail Address, financial information pertaining to our Subscriber's accounts (such as details regarding invoice payments) and information pertaining to third parties ( e.g. employees of the business client).
• In the case of individuals who do not subscribe and have not subscribed to Spinsofts' services, Name, E-Mail Address, Facsimiles sent to us, and other information that may be provided in the course of those individuals' communication with us.

Interactions Pertaining to Account Billing.

• In the case of Spinsoft Subscribers and former Subscribers, the Subscriber's Name; E-Mail Address; Telephone Number; Standard Mail Address; Financial information pertaining to the subscriber's account(s) such as details regarding all invoice payments; sometimes information pertaining to third parties ( e.g. information on the account administrator, in the case of accounts maintained by third parties); Usernames and Passwords assigned to the account(s); Other additional information they clients may provide in their course of communication with us.

Interactions With Spinsoft via the Telephone

• In the case of individuals who contact us via telephone, the only personal information always collected is their telephone number. Those wishing to preserve anonymity in their contact of Spinsoft may do so if they contact us for lawful purposes ( e.g. product inquiries), and if they use lawful means to un-identify their telephone number (such as "number blocking"). Our telephone representatives reserve the right, however, to request additional information that is required to ensure quality of service. Our telephone representatives will always request additional information to verify your identity before disclosing any personal information about you.
• Some calls may be recorded for quality assurance and training purposes. We will always inform you before recording a call (except if the call is made for unlawful purposes).

Generally

• Personal information may be collected in other interactions you may have with Spinsoft. Regardless of the source of such interactions, this Privacy Policy will apply to both protect this personal information, and to inform you of the ways in which and the purposes for which that personal information may be used.
• In order to access some Spinsoft services via the internet, you will be asked to sign in with an e-mail address and/or username, as well as a password (hereinafter,"your credentials"). As part of creating your credentials, you may also be requested to provide questions and secret answers and/or an alternative e-mail address. This information is collected to help verify your identity and assist in resetting your password, should such ever become necessary. Some Spinsoft services may require additional security; in these cases, you may be asked to provide additional personal information in order for us to provide you access to those services.
• Wherever lawful and practicable, in accordance with Australian National Privacy Principle #8, we provide options for you to interact with us anonymously.

Use of Personal Information

Spinsoft collects and uses your personal information to operate and improve its websites, and to deliver the services or carry out the transactions you have requested. In particular, this information is used to: provide you with accurate, secure support, sales, and other services; provide you with more effective customer service; make our sites or services easier to use; perform research and analysis aimed at improving our products, services and technologies; display content and advertising that are customised to your interests and preferences; maintain the security of our network and ensuring quality-of-service for all Spinsoft customers.

Sharing of Your Personal Information

Except as described in this Privacy Policy, we will not disclose your personal information outside ofSpinsoft and its controlled subsidiaries, affiliates, agents and suppliers, without your consent.

Some Spinsoft Services may be co-branded and offered in conjunction with other companies or entities. If you utilise such services, both Spinsoft and the other company may receive information collected in conjunction with the co-branded services. This also includes products or services, such as domain registration and SSL certificates, which although possibly not formally co-branded, involve the transfer of personal information to the entities that provide those services. In all such instances, any personal information we share will be limited to only that which is necessary to provide the aforesaid products or services, and we will make our best efforts to ensure that the use of such data is consistent with the purposes set out in this Privacy Policy.

Specifically, with respect to SSL Certificates, we are required by our providers of those certificates to collect personal information from you to give to that provider.

Specifically, with respect to Domain Registration, we are required by our domain providers/registrars to provide accurate personal information with respect to domain ownership. Although it sometimes an option that such information (normally referred to as "WHOIS" information) to be"guarded" or "protected," we cannot make any guarantees with the availability, validity, continued validity of any such arrangements. Because Domain Registration records fall outside of our direct control, we cannot make any guarantees as to the privacy of such information, and highly recommend that you seek independent advice if such matters are of concern to you.

On occasion, we hire or contract with other companies to provide limited services on our behalf, such as providing customer support, processing transactions, or performing statistical analysis of our services. Any personal information we share will be limited to only that which is necessary to provide the aforesaid services. Any such companies are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

Without limiting any of our rights per the NPPs, we further reserve the right to access and/or disclose your personal information if we believe such action is necessary to: comply with the law or legal process served on Spinsoft; protect and defend the rights or property of Spinsoft (including the enforcement of our agreements); or act in urgent circumstances to protect the personal safety of users of Spinsoft services or members of the public. These rights specifically extend to any subsidiaries, companies or contractors whom we retain on our behalf.

Security and Storage of Your Personal Information

Although the transfer of information across any media, including the internet, may involve some degree of risk, we carry out the maximal practicable steps possible to maintain the security and integrity of your personal information. This includes, but is not limited to:

• Ensuring all web servers involving financial information or involved in carrying out e-commerce transactions are accessible by Secure Socket Layer (SSL) encryption
• Ensuring all Spinsoft servers and systems that contain personal information are protected by strong passwords
• Maintaining tight access control policies that ensure that personal information is limited to only those individuals that require it, and under the circumstances that are relevant to their employment or contracts
• Ensuring all Spinsoft staff utilise strong passwords when accessing any system that may contain clients' personal information
• Engaging in both scheduled and random auditing of our security procedures and privacy compliance
• Other security methods, including storing most personal information on servers located in secured datacenters
• Carrying out identity-assurance procedures before we reveal personal information to you.

Accessing Your Personal Information

Under the NPPs, you are typically entitled to any personal information we hold about you, subject to certain exceptions as therein set out. You may have the ability to view or edit some of your personal information on-line, using methods that will require you to utilise your credentials. The appropriate method(s) for accessing your personal information will depend on which sites and services you have used. In cases that you do not know how to access information by those method(s), or that data is not normally accessible on-line, you are able to access that information through alternative means of access; if you wish to do so, please write us at privacy@spinsoft.com.au, and we will contact you within 30 days regarding your request.

You also have specific rights under the NPPs to assure the accuracy of the data we hold about you. If you believe any personal data we hold about you may be inaccurate, please write us at privacy@spinsoft.com.au, and we will contact you within 30 days regarding your request.

Use of Cookies

Spinsoft web sites sometimes utilise "cookies" to enable you to log into our services, and/or to help personalise your on-line experience. A cookie is a small text file that is placed on your computer by a web server. Cookies contain information that is later read by a web server in the same domain that issued the cookie to you. Cookies cannot be used to run programs, deliver viruses, or carry-out any malicious tasks on your computer.

We utilise cookies to store your preferences and other information on your computer, for your convenience (i.e. to save time by avoiding, for example, the need to repeatedly enter commonly-provided data or your credentials). We may also sometimes utilise cookies to customise the display of information in terms of showing personalised content or appropriate advertising on your later visits to our websites.

Other cookies may be used to manage "sessions," for example to assist our web server software and e-commerce packages in tracking your progress through some portions of our website (i.e. when ordering products or services).

You typically have the ability to accept or decline our cookies. Most web browsers will automatically accept cookies, but you can usually modify your web browser settings to decline cookies. Please be aware that if you choose to decline cookies, you may not be able to sign-in or use features of our websites or related systems that depend on cookies.

Privacy Practices

If you require any additional information about this policy and/or its implementation, or if you have a complaint regarding privacy-related issues at Spinsoft, please contact us.

If you have any questions about Privacy legislation and regulations in Australia, we recommend that you visit the website of the Office of the Privacy Commissioner of Australia at http://www.privacy.gov.au/