SPUR LABS PTY LTD ACN 619 512 015, its subsidiaries, affiliates and related entities in Australia and overseas (together as “Spur”, “we” or “us”) are committed to protecting and managing personal information in accordance with the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
The APPs provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APPs consist of 13 principle-based laws and apply equally to paper-based and digital environments.
Broadly speaking, when we are referring to personal information, we are referring to information or an opinion about you, or information that is reasonably recognisable as you. It includes information or an opinion that may or may not be accurate and recorded in a hardcopy or electronic form.
When we refer to sensitive information, we are referring to certain personal information that is more sensitive and may include health information and, in particular, mental health or details of memberships of professional associations. Under the APPs, sensitive information is afforded a higher level of privacy protection and requires us to obtain your consent before collecting this type of information.
About Spur Spur is a strategy, design and venture studio focused on positively affecting human actions and measuring the outcome.
Spur works with organisations and communities to create a fairer and more sustainable world.
As part of Spur’s commitment to giving back to the community, 5% of Spur’s revenue and 20% of employee time is donated to Spur’s sister company Spur:org.
Spur offers its products and services through its websites (Websites), mobile applications downloadable through third-party platform providers (Apps) and related social media channels. Spur may also conduct research and development initiatives and provide access to other service providers and applications.
Spur has a particular focus on mental health projects and campaigns to reduce the number of suicides worldwide. However, Spur, it’s Apps and Websites are not designed to provide medical advice or a mental or physical health diagnosis. The information provided or displayed by Spur on our Websites, Apps or related social media channels does not consider your unique situation and needs. Please refer to our disclaimer for further information, which is accessible at [INSERT LINK].
What information do we collect about you?
When you enquire about our products and services or become a client of Spur, a record is made that includes your personal information.
The types of information that we collect will vary depending on the circumstances of collection and the kind of product and/or service that you request from us, and may likely include:
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
We may collect personal information about children and other individuals below the legal age of majority (Minors) (for example, when children participate in events our access our Websites, mobile applications or social media platforms we are involved with). Where those Minors do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf. However, we may be unable to distinguish the age or identity of the people accessing and using our Websites or social media platforms or mobile applications or who attend events or activities run by us. This may result in the accidental collection of personal information from Minors without the consent of a parent or guardian. If this does occur, then we recommend that you contact us and ask for the personal information to be de-identified or destroyed.
You can always decline to give Spur any personal information we request, but that may mean we cannot provide you with some or all of the products or services you have requested. If you have any concerns about the personal information we have requested, please let us know.
How and why do we collect and use your personal information?
Spur collects personal information reasonably necessary to carry out our business, assess and manage our clients’ needs, and provide our products and services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client relationships.
Spur generally collects personal information directly from you. We may collect your personal information over the phone, by email, through our Websites or mobile sites, over the internet or when you visit one of our social media sites (such as Facebook, Twitter or Instagram), through our mobile applications or when you visit our office in person.
We may also collect personal information about you from other sources, for example:Spur may collect personal information about other individuals who are not clients of Spur. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Spur, and other individuals who interact with us on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Spur. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
We may receive information about you that we have taken no active step to collect. If this does occur, we recommend contacting us and asking for the personal information to be de-identified or destroyed.
The purposes for which Spur usually collects and uses personal information depends on the nature of your interaction with us, but may include:
You can always decline to give us your personal information, but that may mean that we cannot provide you with some or all of the products and services you have requested.
Who do we disclose your personal information to?
During the conduct of our business, we may use and disclose your personal information to the following parties:
Spur may also use Google Analytics to help us understand how our customers and clients use our platforms, products and services. You can read more about how Google uses your personal information via. You may also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout
Do we use or disclose your personal information for direct marketing?
Spur may use or disclose your personal information to inform you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, we may still contact you concerning any ongoing relationship with you.
How do we hold, store and secure your personal information?
Spur takes reasonable steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification, or disclosure. For example, we may maintain computer and network security, use firewalls and other security methods and other security systems such as user identifiers and passwords to control access to our computer systems.
Please be aware that there is no transmission method over the internet or through electronic storage that is fully secure and safe. We cannot guarantee the security of your personal information that we hold, but we do take reasonable steps to protect your information. If we are required by law to inform you of any misuse, interference, loss or unauthorised of your personal information, then we will notify you electronically, in writing or by telephone.
Our Websites, Apps or email systems may not use encryption or other technologies to ensure the secure transmission and receipt of information via the internet. Anyone using our Websites or receiving an email from us is encouraged to exercise care in sending personal information or depositing money via the internet. We recommend that you refrain from clicking any unsecured links or opening unknown attachments.
If you hold any concerns or become suspicious of any misuse, interference, loss or unauthorised access to our Websites, our email systems or to our business more generally, we ask that you contact us immediately to verify your concern or suspicion.
Spur hold and store your personal information in paper-based files, other electronic record-keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas), which may include cloud-based storage providers.
Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
Your personal information is usually collected in electronic form.
Your personal information may be collected in electronic form for use or storage with a third-party storage provider that we engage.
We cannot ensure that your personal information is or will remain secure. This is due to us not having control over the third-party provider’s policies and procedures concerning the handling and storing your personal information.
What are the choices that you can make about your personal information?
At any time, you can request us to:
Please understand that we may not be able to entertain your request if it is unlawful to do so or is otherwise impractical or unreasonable to do so at our discretion.
Delete or destroy your personal information
Until you request for it to be deleted or destroyed, your personal information is kept by us for as long as necessary to provide our products and services to you and for legitimate and essential business purposes, such as complying with our legal obligations or settling disputes. This means that your personal information can be held for some time.
Remaining Anonymous & De-Identification
Spur may require you to provide specific details and information to enable us to provide our products and services to you. We try to allow you to stay anonymous or use a pseudonym in your dealings with us where it is lawful and practicable to do so. For example, when making a general and nonspecific enquiry. Typically, it is not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect your personal information, you may not be able to utilise our products and services, deal with us or participate in our events, programs or activities we manage or deliver.
Accessing or correcting your personal information
You are entitled to access or request a copy of your personal information held by us by sending us a request. You will not be charged for requesting to access or copy your personal information, but you may be charged for the reasonable time and expense incurred in compiling the information.
You are responsible for ensuring that your personal information with us is accurate and up to date. We take steps to ensure that the personal information we collect, use or disclose is accurate and up to date. You can help us do this by letting us know if you notice errors, inaccuracies or discrepancies in the information we hold about you and letting us know if your details change.
We may decline your request to access or correct your personal information in accordance with the APPs. If we refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Does the European Union General Data Protection Regulation apply to us?
The European Union (EU) General Data Protection Regulation (GDPR) contains new data protection requirements and is effective as of 25 May 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU. The GDPR applies to the data processing activities of businesses, regardless of size, that are data processors or controllers with an establishment in the EU.
Consequently, Australian businesses of any shape and size may need to comply if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU. There are also some notable differences, including certain rights of individuals (such as the ‘right to be forgotten’) which do not have an equivalent right under the APPs and the Privacy Act.
Currently, the GDPR does not apply to our business as Spur does not currently offer our products and services to individuals located in Europe, our Websites does not explicitly target customers located in the EU nor do we monitor the behaviour of individuals in the EU.
What should you do if you have a complaint about the handling of your personal information?
Complaint handling process
Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps that can be taken to resolve the complaint. We will contact you within thirty (30) days of the date we receive the written details of your complaint to acknowledge that we have received it. We may ask you to provide further information about your complaint and the outcome you are seeking.
Our privacy officer will review the way we dealt with your personal information, conduct an internal investigation (if necessary) into the complaint and will likely respond to you within thirty (30) days of the date we acknowledged receipt of your complaint. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within sixty (60) days of receipt of the complaint. If the matter is more complex or our investigation takes longer than anticipated, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that Spur may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au
Our contact information
Attention: Privacy Officer
Telephone: [insert main telephone number that will receive privacy questions/complaints]
Email: [insert email address that will receive privacy questions/complaints]