Sentral Pty Ltd (ACN 085 316 310), and its subsidiary Our Online Canteen Pty Ltd (trading as QuickCliq) (ACN 142 542 014) (“Sentral”, “us”, “we” or “our”) respects your rights and preferences regarding data privacy. Through our software offerings, we provides systems to schools (our “Customers”) with tools that help them manage their operations, including cafeteria management, payment solutions, and communication with parents and students. Our users include our Customers, parents and guardians that engage with our Customers, as well as, where enabled by a parent or guardian, their students (collectively “Users”). Personal information that we receive from our Customers is subject to Privacy Act 1988 (Cth) (“Privacy Act”). Personal information that we receive from our Users is owned by the Users, and only processed by us as described below.

You may choose not to give us your personal information. However, if we do not collect your personal information, we may not be able to provide you with our services.

This Privacy Policy is subject to change without prior or separate notification. Any changes will be posted on our website.

1.0 Collection of personal information

1.1. What kind of personal information do we collect and hold?

The types of personal information that we collect, hold, use and disclose may include:

• name;
• date of birth;
• gender;
• address;
• email address;
• phone number(s);
• family situation;
• identity of your parent, carer, child or other family members;
• marital status;
• academic results;
• attendance;
• IP address;
• occupation or position of employment;
• details of your school, business or company;
• details of the school your child attends;
• information about any complaints; and
• a record of the pages you visit on our website.

We may also collect sensitive information, which  is a subset of personal information that is afforded a higher level of privacy protection. The kinds of sensitive information we collect and hold may include:

• health information; and
• religious affiliation;

1.2 How do we collect personal information?

We usually collect personal information directly from our customers (for example, we may collect personal information about a student or parent from their school).

We may also collect personal information in connection with the use of our services when:

• You request us to provide you with a fee estimate or quote;
• You register or complete an application form to use our services;
• You enter details through our website;
• A third party engaged by you contacts us or provides information to us on your behalf;
• You use software or any other electronic application which has been integrated with our software;
• You communicate with us via phone or email;
• You make changes on your account with us;
• You provide feedback in a survey;
• We engage a third party provider to perform checks on you;
• You enter into a promotion run by us;
• You subscribe to our mailing list;
• You accept or follow links to our website and mobile apps; and
• You follow us through social media or post to one of our social media sites.

If you call us, we may monitor and record those calls for quality, training, dispute resolution and security purposes.

1.3 Cookies

A “cookie” is a small file used to uniquely identify the visitor’s browser or to store information or settings in the browser. Our sites use cookies, including cookies that are necessary to enable the features of the site, performance cookies to see how visitors use the site, and functionality cookies that enable sites to ‘remember’ machines or devices, personalize website content and tailor user experience and to help us target advertisements to users when they are browsing this website and other websites.

Most browsers allow you to customise or turn off cookies, however if you turn off cookies or change your settings, some features of our website may not work correctly.

2.0 Use and disclosure

2.1 Why do we collect, hold, use and disclose personal information?

If you purchase or use the services or products we provide, we collect your personal information for the purpose of operating our business and providing our services to you in accordance with our legitimate and legally protected interests. This includes:

• Confirming your identity;
• Confirming accuracy of information provided to us;
• Confirming your authority to act on an account;
• Sending notices;
• Resolving disputes and addressing complaints;
• Collecting fees;
• Remedying fraud and other illegal activities; and
• Marketing our other services and products to you.

We partner with and share personal information with third parties to provide our services, and those third parties may use that personal information to provide marketing communications and targeted advertising to you.  You may opt out of marketing communications by selecting “unsubscribe” for email communications, or contacting us on the details in section 4 below.

If you are a supplier or business partner, we collect your personal information that is necessary for the purpose of operating our business and providing our services to software users, as well as receiving products or services from you and conducting due diligence on you and your products or services.

2.2 How do we hold personal information?

We hold personal information in a database that may be hosted on a cloud service within Australia.

We take reasonable steps to:

• Protect your personal information that we hold from misuse, interference and loss and from unauthorized access, modification or disclosure
• Ensure our system is appropriately backed-up to prevent the loss of your personal information
• Destroy or de-identify personal information when it is no longer required for our purposes or permitted by law.

Security measures that we have in place to protect your Personal Information include the following:

• where possible, Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information are used;
• physical access to our premises is limited;
• information access restrictions, including two factor authentication and different levels of security clearance;
• configurable account locking policies to lock out accounts after failed login attempts;
• all staff are required to sign confidentiality agreements and undergo relevant background and/or working with children checks; and
• We require third party providers to implement appropriate security safeguards to keep Personal Information secure.

It is your responsibility to keep your login details to our sites and apps secret and secure.

2.3 When do we disclose personal information?

We may disclose your personal information to third party contractors to facilitate the delivery of our software and services or improve the quality of our software or services, to confirm your identity, diagnose technical problems, administer our website and carry out maintenance, repairs and develop our computer software and hardware.

Your account, financial and billing information (including any changes to or corrections of such) may also be made available to providers of payment services or any other electronic applications which have been integrated with the our software to enable those service providers to process payments when instructed to do so, or to our intermediaries to manage accounts processing. We may also disclose your personal information to third parties, such as advisors, lawyers, accountants, and resellers who sell our services, including to debt collection agencies for the purposes of collecting debts, to third parties for fraud prevention and risk management, to law enforcement agencies or to government bodies.

We disclose personal information to our related companies for services they provide to us, for oversight of our operations and where it is of relevance to their own operations. We may also disclose your personal information to acquirers (or potential acquirers) of all or any part of our business, or in order to run the business or part of the business acquired.

We may disclose your personal information to our related companies or to third parties located outside of Australia.

We may also disclose personal information to the extent required or authorized by applicable law.

We do not sell any of your personal information.

2.4 Third Party Websites

Our websites may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for those websites.

3.0 How you can access or correct your personal information

3.1 Access to personal information

Upon request, we will provide you with access to your personal information held by us, except in circumstances where refusing you access is required or authorised by law.

To request access to the information held by us about you, please contact us using the contact details listed below. We will respond to your request within a reasonable time after the request is made, and will advise you if we will not or cannot provide you access, together with the reasons for denying you access.

We reserve the right to charge you for providing access to your personal information. We will notify you of those costs prior to providing you with access to the information. We may require those costs to be paid prior to providing you with access.

3.2 Correction of personal information

We take reasonable steps to ensure that the personal information collected by us is accurate, complete, relevant and up to date. If you believe that any of the personal information we hold about you requires correction, please inform us in writing using the contact details set out below.

4.0 Contact details

Please direct any correspondence in relation to your personal information or this Privacy Policy to:

Privacy Officer
Email: gpaunz-legal@globalpay.com
Post: Level 9, 2 King Street Bowen Hills Brisbane QLD 4006 Australia

5.0 How to make a complaint

If you have a complaint about how we have collected, used or disclosed your personal information, or if we have not corrected or provided you with access to your personal information, then you may contact our support team using the contact details above so that we can investigate the complaint and respond to your concerns. 
If you are not satisfied with our response, you can submit a complaint to:

• In Australia: the Office of the Australian Information Commissioner (see: http://www.oaic.gov.au/privacy/privacy-complaints).