Effective as of 12th January 2021
Under the Act, “Personal Information” is defined as: “Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.”
1. ABOUT HOOZU
Hoozu is a social content agency that (a) specialises in sourcing brand advocates and social influencers, creating compelling content and tracking and optimising marketing campaigns and (b) develops technology platforms to automate content creation (Hoozu Connect) and an analyse ad performance (AiLY) . In delivering its’ services Hoozu provides a variety of digital and online offerings including the Hoozu website and the influencer and agency platform (collectively ‘Hoozu Platform’).
In providing the Hoozu Platform, we are sensitive to Users’ concerns about the safety of their Personal Information.
In essence, Hoozu will typically only:
- collect, use or share your Personal Information with your consent (unless it is not reasonable in the circumstances to obtain your consent and it is legally permissible for us to do so) or when required by a legal obligation; and
- interact with your Personal Information in order to: (a) provide you with access to the Hoozu Platform, (b) help us improve and develop the Hoozu Platform, and (c) meet our obligations in respect of any agreement we have with you.
Hoozu has developed our privacy framework to assist Users, and to comply with privacy legislation and regulations applicable to us and our management of your Personal Information.
2. HOW HOOZU COLLECTS YOUR PERSONAL INFORMATION
Hoozu collects Personal Information from individuals in one of three main ways:
- (a) Directly from Users, when they interact with Hoozu or the Hoozu platform (e.g. fill out User account information and preferences, or provide us with feedback);
- (b) Passively from Users, when they interact with and use the Hoozu Platform;
- (c) From third-parties in certain, specific circumstances (e.g. when you sign up to the Hoozu Platform through a third-party service or platform they may provide us with information you have consented to them sharing).
The types of Personal Information collected in each situation is discussed further below.
3. WHEN HOOZU COLLECTS INFORMATION FROM USERS AND WHAT WE COLLECT
(a) Personal Information collected directly
When Users sign up to components of the Hoozu Platform we collect the following types of Personal Information directly and consensually:
- Basic User information, including your name, User name, email and date of birth;
- Basic account information, including any biographical information, social media handles or other information you choose to associate with your account; and
- when you access the Hoozu Platform through a third-party service or platform (e.g. Facebook or Instagram), we will collect information that is made available to Hoozu by those services or platforms. You can generally control the information we receive from these sources by using the privacy settings on the third-party services or platforms.
We will collect the following types of information from Users as they use the Hoozu Platform:
- Basic account preferences, such as your preferences regarding social media channels; and
- Content that you post and submit to the Hoozu Platform (including content from third-party platforms) as well as content you may post directly on our social media pages, which includes any content from third-party platforms.
In the course of creating content, running a campaign or providing you with our services we may collect the following types of Personal Information directly and consensually from you:
- Delivery information, such as your full address and contact number;
- Payment related information, such as bank account details or other information required to give effect to our agreement(s).
When a User makes an enquiry or sends us unsolicited feedback we may collect the following types of Personal Information directly and consensually:
- Basic contact information, including your name and email; and
- Feedback information and the details of your interactions with us, including communications with customer support or other Hoozu personnel (e.g. the contents of an email an email sent to contact@Hoozu.com) or other information provided by you regarding your enquiry.
When you respond to a survey we may directly and consensually collect the Personal Information disclaimed on the survey form.
When you make an application for employment at Hoozu, we may collect any Personal Information provided within that application, such as the contents of a personal statement made in support of your application.
(b) Personal Information collected passively
As you interact with the Hoozu Platform or advertisements, we may collect the following types of Personal Information about your usage:
- Content that is posted about you by others over Hoozu campaign materials, your social media accounts and if applicable, directly over the Hoozu platform;
- Background account information, such as your notification settings;
- Information about transactions, such as records of your purchases and any preferences relevant to the online store; and
- The following types of browser, system and device information regarding devices you link to the Hoozu Platform or use to access our digital content:
- Location information, regarding which country you’re accessing the platform from, (e.g. the form of the IP address from which you access the Hoozu 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 of the Hoozu Platform;
- Device information provided by devices you link to your Hoozu Platform accounts (e.g. device information from a GoPro or smartphone); and
- System usage information, such as logs of Users you have followed or are following you, and friends that you have added and been added by.
(c) Personal Information collected from third-parties
In certain specific situations, Hoozu will collect Personal Information about you from third-parties. The types of Personal Information collected include:
- Third-party account information made available to us when you link a third-party service or platform to your account on the Hoozu platform; and
- Third-party web data tracking information about your social media accounts, including information about your followership that fits certain parameters of who we think could become Hoozu Users (e.g. heat maps developed through Google Analytics which track patterns of User interactions with our web pages).
4. WHY HOOZU COLLECTS YOUR PERSONAL INFORMATION AND WHAT WE USE IT FOR
Although Hoozu collects Personal Information from Users in a number of circumstances, Hoozu will only collect this information in order to provide you with access to the Hoozu Platform, improve and develop the Hoozu Platform, and to meet our obligations in respect of any agreement we have with you (e.g. if you are a brand advocate of social influencer).Here are the main ways we use Personal Information to achieve these objectives:
Communicating with Users
Hoozu will use basic User, account and contact information to communicate with individuals about their feedback or issues with the Hoozu Platform.
If Users have consented, Hoozu will also use these types of Personal Information to share relevant news and updates about Hoozu and the Hoozu Platform.
Administration and delivery of Hoozu Platform
Hoozu will use basic User and account information, as well as other basic preferences to provide you with the baseline experience over the Hoozu Platform (e.g. connecting brand advocates and social influencers with marketing campaigns they might be interested in participating in).
Hoozu will also use third-party service or platform information, including third-party web data tracking information for the same reasons.
Hoozu will use your basic User information for simple administrative tasks, such as resetting account passwords.
Hoozu will use your delivery and payment related information to allow brand advocates and social influencers to participate in campaigns through the Hoozu Platform.
Hoozu will use your account preferences to provide you with a tailored experience when using the Hoozu Platform.
Ensuring User safety
Hoozu will also use any type of information collected to prevent and address risks to all Users (e.g. Hoozu will use information to investigate suspicious or threatening activity).
Research and development
Hoozu will use the following types of information to develop, test and improve the Hoozu Platform:
- Survey and feedback information, as well as any content that is submitted in relation to competitions or features of the Hoozu Platform;
- Basic account information;
- Content you submit, either directly through the Hoozu Platform or through third-party platforms or services.
- Background account, browser, system and device information; and
- Third-party web tracking information.
Together these types of Personal Information are used to provide us with an overview of how the Hoozu Platform is being used, any shortcomings it may have, and subsequently to highlight what will be the best means of improving the experience for all Users.
Hoozu’s preference will be to de-identify these types information first, and then use it for this purpose in conjunction with de-identified browser and device information (see section 6 below for an explanation of what we mean by “de-identified”).
Where Users have expressly consented, Hoozu will use basic contact, enquiry and account information to provide Users with relevant marketing materials and offers. Users can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
5. HOOZU’s DISCLOSURE OF PERSONAL INFORMATION
Generally, Hoozu does not disclose Personal Information to any third-parties except:
- Service providers Hoozu engages to help us provide and develop the Hoozu services and Hoozu Platform (e.g. cloud service providers); and
- Law enforcement agencies, or another party that has a legitimate legal right to access the information.
Some of the third-parties Hoozu discloses Personal Information to are located overseas. This is particularly the case for our third-party software and cloud service providers which are currently located in the United States
As with disclosures to third-party service providers, overseas disclosures are always made once Hoozu has taken all reasonable steps to determine the information will be treated at least as favourably under the Act and other applicable privacy laws.
6. HOOZU’S TREATMENT AND STORAGE OF INFORMATION
Hoozu’s general approach
Hoozu will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third-parties, unless:
- The disclosure is made in accordance with an agreement on foot with you, or to which you otherwise consented;
- 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 Hoozu Platform (e.g. a cloud service provider or local marketing and development partner);
- Other entities acquire ownership or operation of Hoozu or the Hoozu Platform; and/or
- We need to protect the safety of Users, and the security of our Hoozu Platform.
Users can always refuse or revoke this consent, but sometimes this will affect Hoozu’s ability to provide them with the Hoozu Platform and other offerings. Hoozu will advise Users if this is the case.
De-identified information refers to information that cannot reasonably be used to identify a particular individual.
De-identified information that will never be able to personally identify particular individuals is referred to as anonymised information (e.g. statistics that show 90% of Users were happy with the Hoozu Platform). Additionally, de-identified information that can identify individuals only if it is combined with another, separate piece of information is referred to as pseudonymised information (e.g. ID numbers).
Where possible Hoozu will aim to collect, store and use anonymised information as a first preference, and if not, then pseudonymised information.
However, sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, Hoozu will continue to use and hold the information in a personally identifiable state. For example, if Hoozu needs to reply to a User enquiry we will have to use the contact information provided.
Hoozu 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. To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Information, and to respond appropriately if it is ever breached.
When information collected or used by Hoozu is stored on third-party service providers (e.g. Dropbox cloud servers), Hoozu takes reasonable steps to ensure these third-parties use industry standard security measures that meet the level of information security Hoozu owes Users.
As part of our privacy framework we endeavour to routinely review these security procedures and consider the appropriateness of new technologies and methods.
In the circumstances where Hoozu suffers a data breach that contains Personal Information, we will execute our Data Breach Response Plan and endeavour to take all necessary steps to comply with the Notifiable Data Breach Scheme outlined under the Act.
This means we will immediately make an objective assessment of whether a breach of Personal Information is likely to result in serious harm to individuals, and if this is the case, endeavour to notify the affected individual(s) and the Australian Information Commissioner.
7. HOOZU’S RETENTION OF INFORMATION
Hoozu retains Personal Information until it is no longer needed to provide or develop the Hoozu Platform.
However, Hoozu will retain:
- Personal Information in circumstances where we have legal and regulatory obligations to do so (e.g. for law enforcement purposes, employment law, corporate or tax record keeping, or where the information is relevant to legitimate legal proceedings); and
- anonymised information for analytic and service development purposes.
8. MANAGING PERSONAL INFORMATION YOUR INFORMATION
Requesting Deletion of Personal Information:
Users may request the deletion of their Personal Information by contacting firstname.lastname@example.org. Hoozu will perform the deletion within one month (30 calendar days) and will send Users a confirmation once the Personal Information has been deleted. Hoozu aims to complete the request in advance of the deadline wherever possible.
Accessing and ensuring the accuracy of Personal Information
Hoozu takes reasonable steps to ensure that the Personal Information we collect and hold is accurate, up to date and complete.
Users have a right to access and request the correction of any of Personal Information we hold about them at any time. Any such requests should be made by directly contacting us at the details set out below. Hoozu will grant access to the extent required or authorised by the Act and applicable laws, and will take all reasonable steps to correct the relevant Personal Information where appropriate.
There may be circumstances in which Hoozu cannot provide Users with access to information. We will advise you of these reasons if this is the case.
Hoozu has appointed a Privacy Officer to be the first point of contact for all privacy related matters and to assist in ensuring our compliance with our privacy obligations.
Privacy Officer email: email@example.com
suite 3, 2-12 Foveaux St, Surry Hills, NSW, 2010
The Privacy Offer will respond to your query or complaint as quickly as possible. Hoozu will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email) of the relevant determination. If you are not satisfied with the determination you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.