Last updated: April 2020
Eggy Pty Ltd (ACN 636 901 258) (‘Eggy’, ‘we’ or ‘us’) is committed to protecting the safety and security of the personal information of individuals who use the Eggy mobile application and platform and related websites and services (collectively, ‘Services’) and other persons with whom Eggy interacts (each a ‘User’ or ‘you’).
Information collected by Eggy is used to optimise the Services and to enhance the User’s experience. Eggy is committed to ensuring that the User’s privacy and confidentiality is protected, and to abiding by the Australian Privacy Principles (APPs), under the Privacy Act 1988 (‘Act’). For the purposes of this policy ‘Personal Information’ has the meaning currently given in the Act.
2. Information we collect
Eggy collects Personal Information in three main ways:
- Directly from Users, when they interact with Eggy or the Services;
- Passively from Users, when they interact with and use the Eggy platform; and
- From third parties, in certain, specific circumstances.
1. Personal information collected directly
When Users sign up to components of the Services, we may collect the following types of Personal Information directly and consensually:
- Basic User information, including your name, date of birth, email address, and telephone number;
- Basic account information, including any other information you choose to associate with your account;
- Other information you upload or otherwise make available about yourself as a normal part of using the Services; and
- Qualitative Data (‘Qualitative Data’) and Quantitative Data (‘Quantitative Data’) from Users. This may include written feedback (e.g. emails from Users), verbal feedback (e.g. from interviews with Users) and electronic feedback (e.g. online surveys) that Users provide related to their experience of using and interacting with the Services.
2. Personal Information collected passively
As you interact with the Services, we may collect the following types of Personal Information about your usage:
- Background account information, such as your notification settings;
- Locational information, regarding which country you’re accessing the platform from (e.g. the Internet Protocol (‘IP’) address from which you access the Eggy platform);
- Web data tracking information, such as data from cookies stored on your device, including cookie IDs and settings, as well as logs of your access on the Eggy platform;
- Device information provided by devices you use to access your Eggy Platform accounts (e.g. device information from a smartphone); and
- System usage information, such as logs of your searches and navigation across the Eggy platform.
3. Personal information collected from third parties
In certain specific situations, Eggy may collect Personal Information about you from third parties. The types of Personal Information that may be collected include:
- Analytical and usage data (‘Data Analytics’). This may include information and metrics such as the frequency of Service access and usage, the pages and screens visited, the Service features accessed and used/not used, the flow of screens/pages accessed, the time and date at which the Service was used, the time that is spent on each page/screen, lifestyle and demographic factors, as well as publicly available sources such as internet search engines or social networking services. When we do so, we ensure that we have a legal basis for using your personal information, such as to enable us to contact you and offer our products and services to you; and
- Information from other people or organisations who might be representing you or any person assisting or representing us. The contents of any personal documentation uploaded by the User to the Services may be accessed and stored for the purpose of optimising the User’s experience and delivering features of the Services.
3. How and why we use your information
Information may be collected from the User through their use of, and interaction with, the Services. This may include information that the User has directly provided (e.g. in their use of the Eggy mobile application) or information that the User has indirectly provided (e.g. through their use of the Eggy website).
Although Eggy collects Personal Information from Users in a number of circumstances, Eggy will only collect this information in order to provide the Services and enhance the User’s experience. This may include using Personal Information:
- to identify a User;
- to administer and provide the Services;
- to provide personalised information, support and services;
- to provide technical support;
- to notify Users of product updates;
- for marketing communications, invitations and offers for products/services;
- to conduct business processing functions;
- to provide improved services through website, social media channels and to develop and improve the products and Services we offer;
- to conduct User surveys and research;
- to measure User satisfaction;
- to fix bugs and problems;
- to manage, train and develop our employees and representatives;
- if you apply for employment with us, to consider your application;
- to amend records to remove personal information; and
- for other everyday business purposes that involves the use of personal information.
Personal Information may be anonymised and aggregated to better understand how the Service is being used so that the Service may be optimised.
Data Analytics may also be used to better understand how the Service is being used and how the User’s experience may be optimised. Usage metrics may be used to develop business reports, to promote Eggy’s Services, to identify User’s needs and behaviours, and to enhance the User’s experience. This information may be anonymised, aggregated and analysed to indicate how the Service is used collectively by all Users.
We ensure that we have an appropriate legal basis to deal with your personal information. This may be wherever:
- you have provided your consent;
- it is necessary to perform a contract and protect vital interests;
- there are legal or regulatory obligations that must be complied with;
- it is in the substantial public interest;
- courts are acting in their judicial capacity; and
personal information is needed for legitimate business interests.
4. Tools we use to collect your information
Eggy’s Services have tools embedded into them to help us collect useful information. These tools may include, without limitation, Google Analytics, Amplitude and cookies.
Google Analytics and Amplitude are tools that help understand Users’ interactions with the Services and provides insights into how Users are engaging with the Services. Data is aggregated and can generate useful information such as where Users are coming from (e.g. through Google searches) and the pathways Users take while using the Services (e.g. the flow of pages/screens visited). Identifying usage patterns may be used to help improve the performance and usability of the Product.
Cookies are small text files which are sent to a User’s browser from a web site to collect information about the User’s web browsing behaviour (e.g. web pages visited). This allows Eggy to analyse website traffic and enables services to be tailored to Users’ preferences. Users can set their browser to refuse all cookies or to indicate when a cookie is being sent. Actioning this option may prevent Users from taking full advantage of Eggy’s Service features.
Qualitative Data may be collected via feedback mechanisms including both written (e.g. emails, comments on social media, mobile applications) and verbal methods (e.g. interviews, group discussions). Additional quantitative data related to Users’ satisfaction and experience of Eggy’s Products may be collected via online surveys.
5. How your information is stored and protected
Eggy’s general approach
Eggy will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third parties, unless:
- We believe, in good faith, that we are required to share the Personal Information with a third party in order to comply with legitimate legal obligations;
- The disclosure is to a third-party processor of Personal Information that acts on our behalf and/or under our instruction in order to enable us to develop and deliver the Services (e.g. a local marketing and development partner);
- Other entities acquire ownership or operation of Eggy or the Services; and/or
- We need to protect the safety of Users, and the security of the Services.
Eggy is committed to information security. We will use all reasonable endeavours to keep the Personal Information we collect, hold and use in a secure environment.
All Eggy team members (i.e. employees, advisors, contractors and consultants), as well as any third-party suppliers, are bound by Eggy’s Information Security Policy.
Hard copies and electronic records are stored in secure buildings and systems. The Services are all hosted on secure platforms. The design and development of Eggy Services has been implemented using best practices.
Data uploaded by Users to their accounts and stored on Eggy’s systems is encrypted, so that it cannot be read or accessed by unauthorised users. Encryption keys are strictly managed in accordance with Eggy’s Information Security Policy.
Authorised access to User’s information is only granted to Eggy team members (i.e. employees, advisors, contractors and consultants) on an ‘as needs’ basis. Access is controlled through multifactor authentication and is restricted via user permission levels.
In the event that a User deletes or deactivates their account, all reasonable steps will be taken to permanently delete Users’ information.
Documents and data related to the internal business operations of Eggy are stored in private files on secure, password-protected data storage applications.
While we take steps to protect your personal information when you send it to us, you should keep in mind that no internet transmission is ever completely secure or error-free. If you provide any personal information to us via our online services (including email), or if we provide information to you by these means, the privacy, security and integrity of any data transfer over the internet cannot be guaranteed. When you share information with us (such as over the internet, or sending us an email), it is at your own risk as factors beyond our control include the security of the device and/or program you use to communicate with us, and steps you take to protect your login details and password. If you reasonably believe that there has been an unauthorised use or disclosure of your personal information, please contact us by email email@example.com.
6. Who can access your information
Users’ Personal Information, Data Analytics, Qualitative Data and Quantitative Data can only be accessed by authorised Eggy team members (i.e. employees, advisors, contractors and consultants). This information will be shared with Eggy team members on an ‘as needs’ basis for the purpose of delivering the services featured in the Product, for enhancing the User’s experience and for optimising the Product. All Eggy team members (i.e. employees, advisors, contractors and consultants) are bound by Eggy’s Information Security Policy, when handling any User’s information.
Users’ information will only be disclosed to third party suppliers when it is required by law, or in order to provide the services featured in the Product. When required to by law, Eggy may share User’s information with government and/or law enforcement agencies or regulators. In the event that we need to send Users’ information overseas, for the purpose of utilising the services of a provider outside Australia, these service providers will also be bound by Eggy’s Information Security Policy.
In addition, Users’ information may be shared with Eggy stakeholders (e.g. investors) in order to demonstrate Product validation and to justify business activities. The information will be anonymised and aggregated to ensure the identity of Users is protected.
You can request to access a copy of your Personal Information at any time by emailing us at firstname.lastname@example.org. You can also request to edit, update or correct any of your Personal Information by emailing us at email@example.com.
7. Editing or deleting your information
Users can edit or delete their Personal Information by logging into their account. Alternatively, Users can contact us and request for their Personal Information to be edited or deleted by emailing firstname.lastname@example.org.
We may use Users’ Personal Information to contact them for the purpose of marketing our Product and providing relevant content (e.g. newsletters). Marketing communications will only be sent to Users if they have requested or subscribed to them. Users can opt out of marketing communications by unsubscribing via the link provided in the email or by emailing us at email@example.com .
10. Contact Us
Eggy welcomes any questions, feedback, comments or suggestions which can help enhance Users’ experience and help to optimise our Services.
In the event that you have a complaint or concern about your interaction with or use of Eggy’s products, we will attempt to remedy your issue as soon as possible.
If you wish to make a complaint about our handling of your information, please contact us via email at firstname.lastname@example.org .
You can also contact the Office of the Australian Information Commissioner (OAIC) by phoning 1300 363 992 and/or by email email@example.com .