[last updated December 2019]
When we talk about ‘us’ ‘we’ or ‘our’, we mean the entity detailed in the schedule at the end of this policy. Our contact details are also included.
We are the operator of the KeyDates App, our website https://keydates.com.au/ and any subdomain or related blog or public access area (for example our social media platforms) (collectively called ‘online services’). When we talk about ‘you’, we mean you as a user of our online services.
Personal information or personal data is information that directly identifies you, such as your name and email address, or data that could be used, on its own or in combination with other data, to identify you. (called in this policy ‘information’ or ‘personal information’).
2. Staying Anonymous
You can browse our online services anonymously, although cookies may collect data including your IP address. However, once you access our services, including downloading the KeyDates App, we will necessarily begin collecting your personal information in accordance with this policy.
3. Collecting personal information
At all times we aim to only collect the minimum information we need for the services we are providing. For example, if you download our App, we will collect and use your login details. As you would expect, the more involved you are with us, the more information about you we will collect.
Although the data you upload to the KeyDates App is stored by us, we do not access that information unless you make a request of our systems administrator or support personnel to resolve an issue with your use of our online services. We do not provide that information to anyone else.
If you create an account or access our online services via Google or Facebook, we will collect the information necessary to use their verification services for the purpose of insuring you are able to login again in the future using the same method.
You will have the option (depending upon your subscription level) to share your data with friends or family within the KeyDates App, or to external online services. When you make that choice, we facilitate the sharing of your data with that person. We may record your connection with that person for the purpose of your use of the KeyDates App in the future.
The main way we collect information about you is when you give it to us, and this can happen in a variety of ways. We may process the following categories of personal information about you:
Communication data: which includes any communication that you send to us. This might be when you download the KeyDates App, join our mailing list or when you contact us through the contact form on our online services, through email, text, social media messaging, social media posting or any other communication that you send us. If you sign in using social media, we may receive (by your consent) additional information such as your profile picture and social profile ID. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data: which includes data you give to us when you download the KeyDates App. This will include basic information about you and also the information we require for billing purposes such as your name, title, billing address, email address, phone number, contact details, and subscription details. We use Apple Store for processing subscriptions payments for the KeyDates App and we do not receive or store your full card payment information. We process this data to supply the services you have purchased and to keep records of those transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into a contract and our legitimate business interest of keeping records for accounting purposes.
User Data: which includes data about how you use our online services together with any data that you post for publication on our online services or through other platforms. We process this data to operate our online services and ensure relevant content is provided to you, to ensure the security of our online services, to maintain back-ups of our online services and/or databases and to enable publication and administration of our online services and our business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our online services and our business.
Automatically Collected Data. As you interact on our online services, we may collect information about your computer or device and visits to one or more of our online services. This is ‘automatically collected data’ through cookies, web beacons and other technologies, Internet Protocol (IP) address tracking/URL tracking, and other tools and is often referred to as tracking technology. The types of automatically collected data collected through our online services use of these and other tools that we may add from time to time may include: the search terms you used, new or returning user information, browser information, computer or device type, operating system, internet service provider, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, and ads viewed. We also use our own cookies for functions such as checking if you are logged in. We process this data to analyse your use of our online services, to administer and protect our business and online services, to deliver relevant online services content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our online services and our business and to grow our business and to decide our marketing strategy.
We may also use your personal information to carry out some automated decision making about you. For instance, our hosting provider Digital Ocean, may monitor your data use and use this information to automatically manage your access to and use of functions on the KeyDates App. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/ services and to grow our business.
4. Collecting information from third parties
As discussed above, we collect personal information about you when you give it to us and when it is collected by our online services however we may also collect personal information that is given to us or available to us by a third party (for example, information that is on a publicly maintained record or that you have made available on a public social media platform).
We may receive data from third parties such as analytics providers like Google, advertising networks such as Facebook, information providers such as Google, providers of technical, payment and delivery services, such as data brokers or aggregators.
This information forms part of the personal information described in this policy. We will not intentionally collect personal information that is unintentionally disclosed.
5. Collecting sensitive information
We do not intend to collect sensitive information about you and request you never disclose information about your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation to us, on our online services or any blog or social media account associated with our online services or business. If we do happen to receive sensitive information, we will take steps to keep it secure.
6. Children’s privacy
We acknowledge that children require special protection when it comes to their privacy. Our services are not designed for use by persons under the age of 13 years. Any information collected about persons aged between 13 and 18 should occur only with the consent of the parent or guardian of that child and only for the purpose the information has been provided. We do not allow minors to open an account with us without the parent or guardian of the child providing their own personal information and their consent for the collection and use of the minor’s personal information. If you are the guardian of a minor and suspect they may have provided us with their personal information without your consent, please contact us and request to have the minor’s personal information destroyed (use the contact information in the schedule below). We take steps to adequately protect personal information of minors.
7. Testimonials or Reviews
If you provide us with a testimonial or review, you give us your consent for the use of your name, likeness, product you are reviewing and the date of service delivery to be displayed on our online services or in our other marketing material, together with the content of the testimonial that you provide. We may edit your testimonial but will only do so where possible without changing the meaning of what you have said. We may store and/or use your review for as long as the information is relevant to our business. We process this information based on your consent which you may withdraw.
8. Marketing Communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). We do not share your information with others for their own marketing purposes without your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. If you opt-out of receiving our marketing communications, this opt-out does not apply to personal data provided for other transactions such as purchases.
9. Social Networking Services and links to other websites
You can connect with us via our social media pages on Facebook, Twitter and Instagram.
We may provide links to other online services or use social networking services to communicate with the public about our work. When you communicate with us using these services, we may collect your personal information. The social networking service will also handle your personal information for its own purposes and have their own privacy policies. You should become familiar with the privacy policies of any service you use.
We use a range of tools provided by third parties including our online services host, third party service providers and search engine browsers to collect or view access and traffic information for statistical, reporting and maintenance purposes. Third party providers have their own privacy policies. We may also use tracking pixels, cookies and session tools to improve your experience when accessing our online services.
The data collected by cookies does not usually identify you but may be combined with other information to identify you. If we identify you using information from cookies, we may use that information to track how you use our online services and send you information more specific to your needs, or to invite you to purchase our services.
The kind of information that can be collected includes:
device specific information such as mobile network information
server logs including your IP address, the times you use our services and system activity
location information including IP address, GPS, and Wi-Fi access points
local storage availability
We use the information for advertising and remarketing and to help to track your use of our online services to improve your user experience and the quality of our services.
11. KeyDates App
By downloading and using the KeyDates App, you agree that the App may have access to:
your device details, identity, status, call information and history of App usage
your personal identity information, to personalise your KeyDates account
your location services including network location and precise GPS location, to pick up your default information when adding a new KeyDate
your camera and photo library, to allow you to take photos or select photos from your library to add to a KeyDate
your contact list, to allow you to send invitations to selected contacts whom you would like to tag in KeyDates posts
your SMS service to enable you to send KeyDate invitations via text message
your calendar, to enable you to synch events to KeyDates
your Facebook profile, to enable you to import posts from Facebook
Updates to the KeyDates App may automatically add or remove capabilities.
12. Use and disclosure of personal information
In summary, as a legitimate business interest, the personal information we collect about you is used:
to verify your identity
to provide our services
to provide you with information about products and services that may interest you
to provide you with personalised service or special opportunities
to allow you to participate in interactive features of our online services
to run competitions, prize draws, and promotions (if any)
to facilitate our internal business operations
to improve our products or services and in planning new products or services
to conduct market research surveys
to monitor compliance with our terms and conditions
With your consent or at your request we may:
share your contact information with third party organisations who offer products or services that may be of interest to you
To enable the proper functioning of our business, we may also disclose your information to:
Other companies in our group who provide services to us.
Payment third parties if there is a dispute over a payment. For example, if Apple contacts us regarding a dispute over a payment, we will provide Apple with user activity information such as IP address, and activity linked to the IP address, billing details on our system etc to allow the payment dispute to be resolved.
Professional advisers including accountants, lawyers, bankers, auditors and insurers.
Government bodies that require us to report processing activities.
Third parties where we are required to in accordance with the law and we reserve the right to fully co-operate with any law enforcement authorities or court order requiring or requesting us to disclose the identity or other usage details of any user of our online or in-person services, or in accordance with a properly executed court order, or as otherwise required to do so by law.
If we reasonably believe a minor or other person is at risk of harm, we may also disclose relevant personal information to the authorities.
If we sell our business (or part of it), we may transfer your personal information to a legitimate buyer.
13. Security and overseas recipients
We are committed to ensuring that your information is secure to industry standards however no system can be 100% secure and, provided we have acted in accordance with this policy, we are not responsible for loss you may suffer should your personal information be unlawfully accessed. Using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis.
For example, our business is in Australia, our users are in various countries and our data storage is managed by Digital Ocean and processing and storage is completed via datacentres in Singapore. Not all countries have the same level of privacy protection as the country within which you reside. You acknowledge and agree to our processing of personal data across international borders in this way. We will do our best to ensure your data is protected to a similar standard as set out in this policy by using third party providers with similar privacy protections however we are not responsible for our third-party providers.
We will also take reasonable steps to protect all personal information within our direct control from misuse, interference, loss, unauthorised access, unlawful or accidental destruction, modification or disclosure. To prevent unauthorised access or disclosure we use firewall and other electronic security procedures and managerial procedures to safeguard and secure the information we collect from you.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
Our main business premises are located in Australia.
DISCLAIMER: While we do our best to ensure the security of your data, no storage is 100% secure and we cannot guarantee the safety of your data. If you feel this is not sufficient, please do not provide us with your personal information, or, if you have already provided personal information, please contact us and we will securely destroy it.
14. Opt-out/ unsubscribe
We will provide you with the opportunity to opt-in to receive information about our products or services. You can change your preferences at any time using the consent boxes. All emails will also have an unsubscribe function within the email so you can easily manage your preferences.
If you continue to receive communications you have unsubscribed from, please contact us using our contact details in the schedule at the end of this policy and we will remedy the problem.
15. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any business, legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes (and if these can be achieved by other means) and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including contact, identity, financial and transaction data) for some time even after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
16. Third Party Links
Our online services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our online services, we encourage you to read the privacy notice of every online services you visit.
17. Accessing and correcting your personal information – Your legal rights
If you are in the EU, you have rights under data protection laws in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the contact details in the schedule at the end of this policy and we will be happy to provide you with further assistance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights), however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. For record keeping purposes, we will record and store all information exchanged during an exercise of your rights under this clause.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you request to have your information erased (also known as the right to be forgotten), we will, if appropriate, delete your personal information from our active business operating system. Your personal information will however continue to be stored within our backup(s) as we are unable to delete specific items from our backup. It will be deleted at the next scheduled backup deletion. We will keep a log of your request to be forgotten so that, should our backup be used to restore our operating system while your personal information is still stored, your personal information will again be removed from our active system upon restoration.
If you are not a resident of the EU, you may request a copy of the information we hold about you, which will only be provided electronically. You may request to amend or correct your personal information. If we do not agree with your requested change, we will let you know and will keep a copy of your request and our reply with our information.
18. Contact Us
Please let us know if you have any requests, feedback or concerns regarding the way we manage your personal data. Use the contact details listed in the below schedule. We will respond to you within 30 days and take action, within reason, as quickly as possible.
If you are not happy with how we manage your concerns, you can contact your local data protection supervisory office. For example, in Australia this would be the Office of the Australian Information Commissioner of the https://www.oaic.gov.au/.
We regularly review and periodically update this policy to remain compliant with emerging laws. We will notify you of any changes by posting the new policy on this page. We post the ‘last updated’ information at the top of our policy so you can easily check if the policy has changed.
Milestones Technology Group Pty Ltd
ABN 68 600 686 351
Mitchelton, QLD 4053 Australia
Our contact details
If you have questions, require more information, have a complaint to register or details to amend, correct or delete in relation to your personal information, please contact our privacy compliance person via email at: