UCBT Operations Pty Limited (ACN 626 754 390) (Better That, we, us or our) and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) are committed to protecting and maintaining the privacy, accuracy and security of the personal information you provide to us.
We abide by and are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep secure and disclose personal information.
The Privacy Act defines “Personal information” to mean any information or an opinion about an identified individual, or an individual who is reasonably identifiable; whether the information is true; and whether the information is recorded in material form.
“Personal Data” means any information relating to an identified or identifiable natural personal (i.e. by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person). We are required to comply EU General Data Protection Regulation (GDPR) for persons located in the European Union in relation to your Personal Data. Please refer to section 10 if this applies to you.
If you have any concerns or questions, please contact us at the details set out in section 9 and our privacy officer will resolve your concerns and answer your questions (resident of the European Union, refer to section 10).
Links to other sites
Our platform may contain links to other sites, including our business partners who are offering products and services via Better That’ s platform, that are not owned or controlled by Better That. Please be aware that we are not responsible for the privacy practices of such other sites and you access these sites at your own risk. You should therefore familiarise yourself with privacy policies of those sites.
In the process of conducting our business, we are likely to collect a range of Personal Information or Personal Data from or about you. The types of Personal Information or Personal Data we collect generally includes:
If you utilise our platform, we may use technology to collect information as to your activities, including the IP address of your computer (or other devices), your browsing history on our platform and transactional data including your product scanning, auction and payment history.
If you are an employee or contractor with Better That, we will collect the following information from you:
In general, we do not collect "sensitive information" (such as information about ethnic origin, religious or political views, health information etc) from you.
Credit card information
We do not store any credit card information obtained through our platform. We pass it onto our bank or where applicable, our supplier for processing. If you use Stripe, Apple Pay, Google Pay or After Pay to complete your transaction, your Personal Information or Personal Data (including credit card information) will be collected and used by those parties in accordance with their individual privacy policies, which are available on their websites for review.
Anonymity and pseudonymity
Due to the nature of the services we provide and the goods offered for sale on our platform, it is only practicable or reasonable for Better That to deal with you on a named basis. Your Personal Information or Personal Data may be required in order to provide you with our services or the products you purchase on our platform from our business partners, or to resolve any issue you may have.
Better That collects Personal Information or Personal Data directly from you when you submit it via the platform operated by Better That.
We may also collect Personal Information or Personal Data from publicly available sources or third parties, such as via our business partners, where we are responsible for delivering goods directly to you, or social media platforms such as Facebook or Twitter.
Depending on the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our services to you or the products you purchase on our platform from our business partners, we may be unable to provide our services to you in an effective manner, or at all.
If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why unless: (a) the information has been provided by you on application to register or work with Better That, (b) such information is publicly available or (c) as otherwise required or authorised by law.
Unsolicited Personal Information or Personal Data
In the event that we collect unsolicited Personal Information or Personal Data from you, or a third party, in circumstances where we have not requested or solicited that information, and it is determined in the sole discretion of Better That, that the Personal Information or Personal Data is not required, we will destroy the information or ensure that it is de-identified.However, where such information or data relates to your engagement with or by Better That we may choose to keep that.
How to we hold your Personal Information or Personal Data?
Once we collect your Personal Information or Personal Data, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who has taken reasonable steps to ensure they comply with the Privacy Act.
Cookies and IP addresses
Better That may use your Personal Information or Personal Data for the purposes for which it was initially collected or purposes related to such initial purpose if such purposes would be within your reasonable expectations. For example, to:
Where you are a contractor or an employee of Better That, your Personal Information or Personal Data may be used to:
We may also use your Personal Information and Personal Data for purposes authorised by laws or regulations, such as to prevent or investigate an alleged crime or fraud (and we are not required to seek your further consent).
Furthermore, Better That may also use or disclose your Personal Information or Personal Data, and we are not required to seek your further consent:
Better That may also, from time to time, use your Personal Information or Personal Data to contact you to identify promotions, competitions, products and services offered by our business partners that may be of interest to you.
By supplying us your information, you provide us with your express and informed consent to communicate with you via email, SMS, MMS, social media or post to inform you about products and services offered by us or our business partners which we consider are relevant to you (Direct Marketing Communications).
Without limitation to the preceding paragraph, if you have provided, inferred or implied consent (i.e. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your Personal Information or Personal Data for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
This permission is not limited in time unless you choose to opt out by contacting us using the contact information provided below, or by utilising an ' unsubscribe' facility on a communication we send to you in which case, Better That will take steps to ensure you do not receive any future such Direct Marketing Communication.
Some business partners of Better That advertise with Google. Google may show you these advertisements based on your previous visits to our site. If you do not wish to see these advertisements you can opt-out by visiting the Google advertising opt-out page here: https://policies.google.com/technologies/ads
Better That’s servers are located in Australia, and so when we are storing your Personal Information or Personal Data we only store it in Australia.
The third parties (including our IT service providers) listed above that we utilise to assist us and our business partners in providing products and services to you, may be located in Australia or overseas. As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information or data is stored in this way, disclosures may occur to destination outside Australia, including (but not limited to) the United States or other countries.
If you do not agree to the disclosure of your Personal Information or Personal Data outside Australia by Better That, you should (after being informed of the cross border disclosure) tell Better That that you do not consent.To do this, either elect not to submit the Personal Information or Personal Data to Better That after being reasonably informed in a collection notification or please contact us via the details set out at in Section X below.
Better That takes reasonable steps to ensure that your Personal Information or Personal Data is protected from misuse, interference or loss and unauthorised access, modification or disclosure. We have systems and procedures in place to protect your privacy whenever we collect, store, and use or disclose Personal Information or Personal Data. We will regularly upgrade these systems and review our procedures to ensure high standards of security are used to protect your Personal Information or Personal Data.As a condition of working for Better That all our employees and service providers sign up to express confidentiality obligations. However, since no system is 100% secure or error free, we cannot guarantee that your Personal Information or Personal Data is totally protected, for example, from hackers or misuse. If you enter Personal Information or Personal Data on our platform, you should exercise due care to safeguard any passwords, ID number, or other special access features associated with your use of our platform.
We will take reasonable steps to destroy or permanently de-identify Personal Information or Personal Data from our systems which is no longer required by us.
We strive to keep your Personal Information and Personal Data accurate, up-to-date and complete. You are entitled to find out what information we hold about you and correct that information if it is wrong, incomplete, out of date, misleading or irrelevant.
If you become aware that any information we hold about you is incorrect or out-of-date, please let us know immediately via the contact details set out below at section 9. We will be happy to accept updated Personal Information or Personal Data in writing from the owner of that information at any time. However, in order to protect your privacy and security, we will take reasonable steps to verify your identity before granting you access or enabling you to make corrections to your Personal Information or Personal Data.
Our objective is to respond to any request within a reasonable timeframe and no later than 30 days. We will inform you if this timeframe is not achievable.
In some circumstances, Better That may not be in a position to grant access to Personal Information or Personal Data, such circumstances include:
In order to resolve a complaint, we:
Our contact details are:
UCBT Operations Pty Ltd
Shop 13, 45-55 Harris Street, Pyrmont NSW, 2009
Attention: Privacy Officer
If you believe Better That has not adequately dealt with your complaint, you may complain to the Privacy Commissioner, whose contact details are found at www.oaic.gov.au.
We will keep a record of the complaint and any action taken in a Register of Complaints.
In providing our or our business partners’ products and services, or collecting and using your Personal Data, we are required to comply with the GDPR where you are a European Union resident.
The following defined terms have the associated meanings:
If you are a resident of the European Union for the purposes of the GDPR, then in addition to what is set out in Sections 1 - 9 above, the following applies to you.
Under the GDPR, Better That is considered a “data processor” in the provision of its platform that facilitates the buying and selling of retail goods and services.
In addition to your rights of access and correction as set out above, as a Data Subject you may:
Exercising Data Subject rights
If you wish to exercise any of your Data Subject rights, then please send your request in writing to the details above in this section.
We will process your request promptly and in any event, within one month of receipt of receiving it.
If you have any concerns in relation to Better That’s collection or processing of your Personal Data, then you also have a right to complain to a supervisory authority (within the meaning of the GDPR).
Modifications and updates
Interaction of this policy with contracts
Last updated: 20 November 2018