Privacy Policy
Effective date: 20 April 2023
Beyond Neutral Pty Ltd, an Australian registered company numbered ACN 128 938 278, (We, Us or Our) operates climate consulting and carbon offset solutions services (Business) and https://beyondneutral.com (Website).
We are committed to protecting the privacy of Our clients and Our Website’s user or customer (You or Your).
1. Privacy Policy
1.1 This Privacy Policy sets out details about Our practices in relation to the collection, use, disclosure, storage and handling of information which identifies You (Personal Data), and Your rights in relation to Personal Data that We hold about You.
1.2 We provide this privacy policy (Privacy Policy) under:
(a) European Union’s data protection laws – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data and Repealing Directive 95/46/EC (General Data Protection Regulation) [2016] OJ L 119/1 (European General Data Protection Regulation or EU-GDPR); and
(b) United Kingdom’s data protection laws – Data Protection Act 2018 (UK) (UK-DPA), including the application of the EU-GDPR as modified and incorporated within the UK-DPA (UK-GDPR);
(Data Protection Laws), and in accordance with the data protection principles contained in Article 5 of each of the EU-GDPR and the UK-GDPR (Data Protection Principles).
1.3 Our Privacy Policy does not create any rights or obligations upon either You or Us in addition to those imposed by the Data Protection Laws.
1.3 This Privacy Policy applies only to Personal Data that We collect and does not govern Personal Data that is collected by a third party, including where You interact with a third party site, tool or service directly or in connection with the Website.
1.4 The word ‘include’ in this Privacy Policy is used without any limitation.
2. Data Controller
2.1 We are the controller of Personal Data collected by or on behalf of the Business and the Website.
2.2 As controller, We are responsible for:
(a) handling and processing Personal Data in compliance with the Data Protection Laws and the Data Protection Principles; and
(b) facilitating the exercise of Your rights under the Data Protection Laws.
3. Your Rights
3.1 You have rights in respect of Personal Data we hold about You under Articles 15 to 22 of the EU-GDPR and the UK-GDPR, as set out in this clause 3.
3.2 You have the right to access Personal Data that We collect about You.
3.3 If You seek access to Your Personal Data pursuant to clause 3.2, We will:
(a) verify Your identity; and
(b) within a reasonable period of time, comply with Your request.
3.4 You have the right to ask Us to correct Personal Data that We hold about You, and We will update Your Personal Data so that it is up-to-date, accurate, complete, relevant and not misleading.
3.5 You have the right to ask Us to erase Your Personal Data.
3.6 You have the right to restrict Us from processing Personal Data concerning You under certain circumstances, including where You have contested to the accuracy of the Personal Data.
3.7 You have the right for us to communicate to any third party recipient of Personal Data in respect of any correction, erasure or restriction of processing of Personal Data concerning You pursuant to clauses 3.4, 3.5 and 3.6 of this Privacy Policy.
3.8 You have the right to receive Personal Data concerning You and to transfer those data to another controller.
3.9 Where technically feasible, You can ask us to transfer Personal Data under clause 3.8 directly to another controller directed by You.
3.10 You have the right to object at any time to Us processing Personal Data concerning You for Ours or a third party’s legitimate interests, including for direct marketing purposes. In such a case, We will only hold Your Personal Data for the purposes of keeping a ‘do not contact’ list.
3.11 You have the right not to be subject to automated decision-making which affects You legally or significantly, such as profiling.
4. Collection of Personal Data
4.1 We collect and process Personal Data only to the extent necessary to:
(a) operate the Business and/or the Website;
(b) discharge our obligations to provide Our products or perform services ordered by You; and
(c) to communicate with You about Your order, Our promotions, updates about Our Business or the Website, and products or services that may be of interest to You.
4.2 We collect and process Personal Data when You:
(a) engage services from the Business;
(b) browse, use or interact with the Website;
(c) interact with Us through the phone, in person or via email and You provide Us Personal Data about You, including where You contact Us to make enquiries about Our products or services, whether offered via the Business or the Website;
(d) purchase, subscribe, or make an order for Our products or services, whether offered via the Business or the Website;
(e) when You purchase Our product for the benefit of a third party (e.g. as a gift) and You give us Yours and that third party’s Personal Data;
(f) subscribe to Our mailing list or newsletters; or
(g) participate in any of Our surveys or promotions, whether via the Business or the Website.
4.3 We collect and process Personal Data for the following purposes:
(a) improve Our products and services to You;
(b) improve the Business or the Website;
(c) provide Our product or perform Our service ordered by You, which could include sharing Personal Data about You to a registry maintained by the Verified Carbon Standard or Gold Standard (as relevant) (Registry);
(d) where You have purchased Our product for the benefit of a third party (e.g. as a gift), or where you are a third party receiving such product, We collect and process Personal Data about that third party / you only to the extent necessary to provide Our product and to complete the transaction and our contractual obligations for that third party’s / your benefit. Our performance of this obligation could include sharing Personal Data about that third party / you to a Registry;
(e) communicate with You in relation to Our product or service ordered or enquired by You, including providing confirmation and updates about Your order;
(f) unless otherwise objected by You pursuant to clause 3.10, offer You promotional product or service, or market Our product or service that You are interested in;
(g) keep a record of Your order;
(h) keep a database of Our client or customer;
(i) to investigate and resolve any complaints, issues or queries that You raise, including in relation to an order or enquiry for Our product or service;
(j) to investigate whether You are in breach of Our terms and conditions;
(k) verify Your identity where You seek to access Personal Data about You pursuant to clause 3.2;
(l) to comply with the law or to satisfy Our legal obligation under the law; and
(m) use Personal Data for purposes that are related to the above.
4.4 We collect and hold the following types of Personal Data:
(a) Your first and last names, company or business name (if any), country, Your contact details, including contact and billing address(es), email address and phone number, and name to be published on a Registry;
(b) Your internet protocol address (IP Address);
(c) information regarding Your interactions and use of the Website, including information obtained from Cookies (as defined in clause 5.1), such as Your browsing activities and how You interact with the Website;
(d) optional Personal Data that You consent to provide (e.g. types of carbon offset projects that may be of interest to you, marketing preferences, etc); and
(e) optional surveys that provide Personal Data including whether You like the Business or Website, and what You like or do not like.
4.5 With your express consent, We may send You emails about Us, the Business or the Website, including new products, services and other updates.
4.6 We will not contact You to promote or market Our Business or the Website if You do not permit Us to do so or if You have objected to being contacted for such purposes pursuant to clause 3.10.
4.7 You can unsubscribe from Our mailing list at any time by following the prompts in Our emails or by contacting Us directly.
4.8 We will only collect and process Personal Data lawfully, fairly and in a transparent manner, and for a lawful purpose as in accordance with the prescriptions of the Data Protection Laws and the Data Protection Principles.
4.9 We do not collect Your credit card details as We use payment gateways and/or third party processor.
4.10 If We receive unsolicited Personal Data about You, We may destroy it or ensure that it is de-identified if it is lawful and reasonable to do so.
4.11 We do not collect special categories of Personal Data which concern sensitive information about You (e.g. information about Your race, ethnicity, political opinions, religious or philosophical beliefs, etc).
5. Cookies
5.1 We and Our third-party service providers may, with Your express consent, use ‘Cookies’ or similar tools on our Website or emails. For reference, ‘Cookies’ are small blocks of data file placed on Your web browser or device when You access the Website or interact with Our emails to store and gather information about Your browsing activities on the Website or interaction with Our emails (Cookies).
5.2 With Your express consent, We may use different Cookies for various purposes, including:
(a) session Cookies to keep track of Your activities whilst You are navigating the Website. Session Cookies are deleted once the web browser used to access the Website is closed;
(b) persistent Cookies to allow You to save selected settings and preferences on the Website for an extended period. Persistent Cookies do not expire when You close the web browser used to access the Website; and
(c) social media Cookies to allow You to engage with social media content on the Website, including to share Our content via social media.
5.3 With Your express consent, We may use Cookies for many reasons including but not limited to:
(a) monitoring and improving the Website’s performance and user experience;
(b) reporting any Website errors that occur;
(c) providing Us with statistics about how the Website is used;
(d) remembering settings and preferences that You used on the Website for Your convenience;
(e) identifying that You are logged into the Website; and
(f) facilitating cross-platform engagements between the Website and social networks like Facebook and Twitter. Please be aware, however, that these third party sites may also use third party Cookies when You interact with them and We do not have control over these third party Cookies. If You wish to obtain more information about third party Cookies and how to manage them, please view the relevant sites’ Cookies policy directly.
5.4 Please note that although Cookies do not generally store Personal Data, they may contain Your IP Address. However, You are effectively anonymous to Us because the data are collected in aggregate.
5.5 You may disable and delete Cookies in Your browser if You do not want Us to use Cookies but doing so may affect Your user experience on the Website.
6. Third Party Services
6.1 The Website uses third party services linked to the Website.
6.2 When You interact with a third party, whether via accessing a third party link or using a third party service linked to the Website, You are subject to that third party’s relevant policies as separate to this Privacy Policy.
7. Security
7.1 For transactions on the Website, We use a third party processor and/or payment gateway (e.g. PayPal and Stripe) that We may change from time to time so that:
(a) payments are processed in real time; and
(b) We do not gain access to Your credit card numbers.
7.2 We take reasonable precautions to keep Your Personal Data secure and to protect Your Personal Data from unauthorised or unlawful destruction, loss, alteration, disclosure, or misuse.
7.3 We implement technical and organisational measures as appropriate to protect Your Personal Data, including ensuring that any person or entity processing Personal Data on our behalf (Data Processor) is subject to a contract with Us, which imposes obligations upon the Data Processor that are substantially similar to Our obligations under the Data Protection Laws.
8. Retention
8.1 Your Personal Data is stored in the server of Our Website host in Australia, and Your Personal data is only accessible by the following:
(a) Us; and
(b) the Website managers from time to time, such as a Website designer or developer, who will be subject to the obligations at clause 7.3.
8.2 We retain Your Personal Data for no longer than is necessary for the purposes for which the Personal Data is processed. Therefore, the retention period for each Personal Data will vary on a case-by-case basis in accordance with the processing reason for the data.
8.3 We will permanently delete Your Personal Data if We no longer need to retain the data or where the processing purpose has been fulfilled.
8.4 Where You have purchased Our goods or services, We will only retain Your Personal Data for record keeping purposes only, for example, for tax and warranty purposes.
9. Third Country Transfer
9.1 Your Personal Data is stored and processed in Australia, a country not recognised by the European Commission to have an adequate level of protection to human rights and freedoms with respect to Personal Data.
9.2 Given that Your Personal Data is transferred outside of the European Economic Area, We have implemented appropriate safeguards as required under the Data Protection Laws to ensure that Your rights under the Data Protection Laws are adequately protected.
10. Anonymity and Pseudonymity
10.1 You may interact with Us anonymously or by using a pseudonym when You call or email Us, and You may refuse to give Us Personal Data concerning You.
10.2 This Privacy Policy, and Our obligations under the Data Protection Laws do not apply where We have collected information on an anonymous basis or where the information has undergone pseudonymisation, unless the information could result in identifying You or a person.
10.3 You must provide Personal Data when You:
(a) purchase goods or services from the Website or the Business;
(b) sign up for mailing list;
(c) lodge a complaint; and
(d) where You are required to provide Personal Data under the law.
11. Disclosure of Personal Data
11.1 We only disclose Personal Data concerning You for purposes that are reasonably related to provide the goods or services purchased by You, whether via the Business or the Website, for example, to publish Your preferred name on a Registry.
11.2 Other than the disclosure at clause 11.1, We will not disclose your Personal Data to third parties for payment, profit or advantage.
11.3 We may disclose Personal Data concerning You to third parties from time to time to assist Us in conducting the Business, including:
(a) technology service providers including internet service providers or cloud service providers;
(b) data processors that analyse the Website traffic or usage for Us;
(c) agents that perform functions on Our behalf, including such as customer relationship management, mailouts, debt collection, marketing or advertising;
(d) Our related bodies corporate; and
(e) where required under the law.
11.4 We may disclose Personal Data concerning You to third parties:
(a) to provide the goods or services purchased by You;
(b) to improve the products, services, Business and Website;
(c) to customise and promote Our goods and services which may be of interest to You;
(d) to comply with or as permitted under the law; or
(e) with Your consent.
11.5 The Third Parties that We may disclose Your Personal Data include entities in Australia and only where necessary for us to provide goods and services purchased by You.
12. Direct Marketing to You
12.1 Unless otherwise objected by You pursuant to clause 3.10, We may communicate with You to promote Our products, services, the Business or the Website via email, phone or post.
12.2 We may use Personal Data You gave Us for the purposes of promoting and marketing Our products, services, the Business or the Website to You if We:
(a) use the information that You reasonably expected Us to use to receive promotion and marketing updates; and
(b) provide You a simple method to opt-out.
12.3 We will not contact You to promote or market Our products, services, Business or Website if You have objected to such communication from us under clause 3.10.
12.4 Notwithstanding clause 12.3, You may still receive non-marketing communications from Us from time to time, for example, to provide You with updates in relation to a purchase You have made with Us.
13. Complaints
13.1 If You believe We have breached the EU-GDPR, You have the right under the EU-GDPR and the EU Charter to lodge a complaint against Us to your local supervisory authority in your European Member State.
13.2 If You believe We have breached the UK-DPA or the UK-GDPR, You have the right to lodge a complaint against Us to the UK’s Information Commissioner’s Office at the following contact details:
Website: https://ico.org.uk/make-a-complaint/
Phone: +44-3031231113
13.3 If:
(a) You wish to discuss Your rights under this Privacy Policy or any of the Data Protection Laws;
(b) You believe We have breached the Data Protection Laws and wishes to raise a complaint with Us directly;
(c) You wish to discuss, or have questions about, any aspect of this Privacy Policy,
You may contact us at any time by email, phone or mail at the following contact details:
Contact person: Mark O’Brien
Email: office@beyondneutral.com;
Postal address: GPO Box 1584, Canberra ACT 2601; or
Phone: +61-408963626
13.4 If You contact Us pursuant to clause 13.2, please must allow Us a reasonable time, about 30 days, to reply to You.
14. Variation
14.1 We may update this Privacy Policy from time to time to reflect any changes to our processes or procedures and the Data Protection Laws’ obligations.
Beyond Neutral Pty Ltd, an Australian registered company numbered ACN 128 938 278, (We, Us or Our) operates climate consulting and carbon offset solutions services (Business) and https://beyondneutral.com (Website).
We are committed to protecting the privacy of Our clients and Our Website’s user or customer (You or Your).
1. Privacy Policy
1.1 This Privacy Policy sets out details about Our practices in relation to the collection, use, disclosure, storage and handling of information which identifies You (Personal Data), and Your rights in relation to Personal Data that We hold about You.
1.2 We provide this privacy policy (Privacy Policy) under:
(a) European Union’s data protection laws – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data and Repealing Directive 95/46/EC (General Data Protection Regulation) [2016] OJ L 119/1 (European General Data Protection Regulation or EU-GDPR); and
(b) United Kingdom’s data protection laws – Data Protection Act 2018 (UK) (UK-DPA), including the application of the EU-GDPR as modified and incorporated within the UK-DPA (UK-GDPR);
(Data Protection Laws), and in accordance with the data protection principles contained in Article 5 of each of the EU-GDPR and the UK-GDPR (Data Protection Principles).
1.3 Our Privacy Policy does not create any rights or obligations upon either You or Us in addition to those imposed by the Data Protection Laws.
1.3 This Privacy Policy applies only to Personal Data that We collect and does not govern Personal Data that is collected by a third party, including where You interact with a third party site, tool or service directly or in connection with the Website.
1.4 The word ‘include’ in this Privacy Policy is used without any limitation.
2. Data Controller
2.1 We are the controller of Personal Data collected by or on behalf of the Business and the Website.
2.2 As controller, We are responsible for:
(a) handling and processing Personal Data in compliance with the Data Protection Laws and the Data Protection Principles; and
(b) facilitating the exercise of Your rights under the Data Protection Laws.
3. Your Rights
3.1 You have rights in respect of Personal Data we hold about You under Articles 15 to 22 of the EU-GDPR and the UK-GDPR, as set out in this clause 3.
3.2 You have the right to access Personal Data that We collect about You.
3.3 If You seek access to Your Personal Data pursuant to clause 3.2, We will:
(a) verify Your identity; and
(b) within a reasonable period of time, comply with Your request.
3.4 You have the right to ask Us to correct Personal Data that We hold about You, and We will update Your Personal Data so that it is up-to-date, accurate, complete, relevant and not misleading.
3.5 You have the right to ask Us to erase Your Personal Data.
3.6 You have the right to restrict Us from processing Personal Data concerning You under certain circumstances, including where You have contested to the accuracy of the Personal Data.
3.7 You have the right for us to communicate to any third party recipient of Personal Data in respect of any correction, erasure or restriction of processing of Personal Data concerning You pursuant to clauses 3.4, 3.5 and 3.6 of this Privacy Policy.
3.8 You have the right to receive Personal Data concerning You and to transfer those data to another controller.
3.9 Where technically feasible, You can ask us to transfer Personal Data under clause 3.8 directly to another controller directed by You.
3.10 You have the right to object at any time to Us processing Personal Data concerning You for Ours or a third party’s legitimate interests, including for direct marketing purposes. In such a case, We will only hold Your Personal Data for the purposes of keeping a ‘do not contact’ list.
3.11 You have the right not to be subject to automated decision-making which affects You legally or significantly, such as profiling.
4. Collection of Personal Data
4.1 We collect and process Personal Data only to the extent necessary to:
(a) operate the Business and/or the Website;
(b) discharge our obligations to provide Our products or perform services ordered by You; and
(c) to communicate with You about Your order, Our promotions, updates about Our Business or the Website, and products or services that may be of interest to You.
4.2 We collect and process Personal Data when You:
(a) engage services from the Business;
(b) browse, use or interact with the Website;
(c) interact with Us through the phone, in person or via email and You provide Us Personal Data about You, including where You contact Us to make enquiries about Our products or services, whether offered via the Business or the Website;
(d) purchase, subscribe, or make an order for Our products or services, whether offered via the Business or the Website;
(e) when You purchase Our product for the benefit of a third party (e.g. as a gift) and You give us Yours and that third party’s Personal Data;
(f) subscribe to Our mailing list or newsletters; or
(g) participate in any of Our surveys or promotions, whether via the Business or the Website.
4.3 We collect and process Personal Data for the following purposes:
(a) improve Our products and services to You;
(b) improve the Business or the Website;
(c) provide Our product or perform Our service ordered by You, which could include sharing Personal Data about You to a registry maintained by the Verified Carbon Standard or Gold Standard (as relevant) (Registry);
(d) where You have purchased Our product for the benefit of a third party (e.g. as a gift), or where you are a third party receiving such product, We collect and process Personal Data about that third party / you only to the extent necessary to provide Our product and to complete the transaction and our contractual obligations for that third party’s / your benefit. Our performance of this obligation could include sharing Personal Data about that third party / you to a Registry;
(e) communicate with You in relation to Our product or service ordered or enquired by You, including providing confirmation and updates about Your order;
(f) unless otherwise objected by You pursuant to clause 3.10, offer You promotional product or service, or market Our product or service that You are interested in;
(g) keep a record of Your order;
(h) keep a database of Our client or customer;
(i) to investigate and resolve any complaints, issues or queries that You raise, including in relation to an order or enquiry for Our product or service;
(j) to investigate whether You are in breach of Our terms and conditions;
(k) verify Your identity where You seek to access Personal Data about You pursuant to clause 3.2;
(l) to comply with the law or to satisfy Our legal obligation under the law; and
(m) use Personal Data for purposes that are related to the above.
4.4 We collect and hold the following types of Personal Data:
(a) Your first and last names, company or business name (if any), country, Your contact details, including contact and billing address(es), email address and phone number, and name to be published on a Registry;
(b) Your internet protocol address (IP Address);
(c) information regarding Your interactions and use of the Website, including information obtained from Cookies (as defined in clause 5.1), such as Your browsing activities and how You interact with the Website;
(d) optional Personal Data that You consent to provide (e.g. types of carbon offset projects that may be of interest to you, marketing preferences, etc); and
(e) optional surveys that provide Personal Data including whether You like the Business or Website, and what You like or do not like.
4.5 With your express consent, We may send You emails about Us, the Business or the Website, including new products, services and other updates.
4.6 We will not contact You to promote or market Our Business or the Website if You do not permit Us to do so or if You have objected to being contacted for such purposes pursuant to clause 3.10.
4.7 You can unsubscribe from Our mailing list at any time by following the prompts in Our emails or by contacting Us directly.
4.8 We will only collect and process Personal Data lawfully, fairly and in a transparent manner, and for a lawful purpose as in accordance with the prescriptions of the Data Protection Laws and the Data Protection Principles.
4.9 We do not collect Your credit card details as We use payment gateways and/or third party processor.
4.10 If We receive unsolicited Personal Data about You, We may destroy it or ensure that it is de-identified if it is lawful and reasonable to do so.
4.11 We do not collect special categories of Personal Data which concern sensitive information about You (e.g. information about Your race, ethnicity, political opinions, religious or philosophical beliefs, etc).
5. Cookies
5.1 We and Our third-party service providers may, with Your express consent, use ‘Cookies’ or similar tools on our Website or emails. For reference, ‘Cookies’ are small blocks of data file placed on Your web browser or device when You access the Website or interact with Our emails to store and gather information about Your browsing activities on the Website or interaction with Our emails (Cookies).
5.2 With Your express consent, We may use different Cookies for various purposes, including:
(a) session Cookies to keep track of Your activities whilst You are navigating the Website. Session Cookies are deleted once the web browser used to access the Website is closed;
(b) persistent Cookies to allow You to save selected settings and preferences on the Website for an extended period. Persistent Cookies do not expire when You close the web browser used to access the Website; and
(c) social media Cookies to allow You to engage with social media content on the Website, including to share Our content via social media.
5.3 With Your express consent, We may use Cookies for many reasons including but not limited to:
(a) monitoring and improving the Website’s performance and user experience;
(b) reporting any Website errors that occur;
(c) providing Us with statistics about how the Website is used;
(d) remembering settings and preferences that You used on the Website for Your convenience;
(e) identifying that You are logged into the Website; and
(f) facilitating cross-platform engagements between the Website and social networks like Facebook and Twitter. Please be aware, however, that these third party sites may also use third party Cookies when You interact with them and We do not have control over these third party Cookies. If You wish to obtain more information about third party Cookies and how to manage them, please view the relevant sites’ Cookies policy directly.
5.4 Please note that although Cookies do not generally store Personal Data, they may contain Your IP Address. However, You are effectively anonymous to Us because the data are collected in aggregate.
5.5 You may disable and delete Cookies in Your browser if You do not want Us to use Cookies but doing so may affect Your user experience on the Website.
6. Third Party Services
6.1 The Website uses third party services linked to the Website.
6.2 When You interact with a third party, whether via accessing a third party link or using a third party service linked to the Website, You are subject to that third party’s relevant policies as separate to this Privacy Policy.
7. Security
7.1 For transactions on the Website, We use a third party processor and/or payment gateway (e.g. PayPal and Stripe) that We may change from time to time so that:
(a) payments are processed in real time; and
(b) We do not gain access to Your credit card numbers.
7.2 We take reasonable precautions to keep Your Personal Data secure and to protect Your Personal Data from unauthorised or unlawful destruction, loss, alteration, disclosure, or misuse.
7.3 We implement technical and organisational measures as appropriate to protect Your Personal Data, including ensuring that any person or entity processing Personal Data on our behalf (Data Processor) is subject to a contract with Us, which imposes obligations upon the Data Processor that are substantially similar to Our obligations under the Data Protection Laws.
8. Retention
8.1 Your Personal Data is stored in the server of Our Website host in Australia, and Your Personal data is only accessible by the following:
(a) Us; and
(b) the Website managers from time to time, such as a Website designer or developer, who will be subject to the obligations at clause 7.3.
8.2 We retain Your Personal Data for no longer than is necessary for the purposes for which the Personal Data is processed. Therefore, the retention period for each Personal Data will vary on a case-by-case basis in accordance with the processing reason for the data.
8.3 We will permanently delete Your Personal Data if We no longer need to retain the data or where the processing purpose has been fulfilled.
8.4 Where You have purchased Our goods or services, We will only retain Your Personal Data for record keeping purposes only, for example, for tax and warranty purposes.
9. Third Country Transfer
9.1 Your Personal Data is stored and processed in Australia, a country not recognised by the European Commission to have an adequate level of protection to human rights and freedoms with respect to Personal Data.
9.2 Given that Your Personal Data is transferred outside of the European Economic Area, We have implemented appropriate safeguards as required under the Data Protection Laws to ensure that Your rights under the Data Protection Laws are adequately protected.
10. Anonymity and Pseudonymity
10.1 You may interact with Us anonymously or by using a pseudonym when You call or email Us, and You may refuse to give Us Personal Data concerning You.
10.2 This Privacy Policy, and Our obligations under the Data Protection Laws do not apply where We have collected information on an anonymous basis or where the information has undergone pseudonymisation, unless the information could result in identifying You or a person.
10.3 You must provide Personal Data when You:
(a) purchase goods or services from the Website or the Business;
(b) sign up for mailing list;
(c) lodge a complaint; and
(d) where You are required to provide Personal Data under the law.
11. Disclosure of Personal Data
11.1 We only disclose Personal Data concerning You for purposes that are reasonably related to provide the goods or services purchased by You, whether via the Business or the Website, for example, to publish Your preferred name on a Registry.
11.2 Other than the disclosure at clause 11.1, We will not disclose your Personal Data to third parties for payment, profit or advantage.
11.3 We may disclose Personal Data concerning You to third parties from time to time to assist Us in conducting the Business, including:
(a) technology service providers including internet service providers or cloud service providers;
(b) data processors that analyse the Website traffic or usage for Us;
(c) agents that perform functions on Our behalf, including such as customer relationship management, mailouts, debt collection, marketing or advertising;
(d) Our related bodies corporate; and
(e) where required under the law.
11.4 We may disclose Personal Data concerning You to third parties:
(a) to provide the goods or services purchased by You;
(b) to improve the products, services, Business and Website;
(c) to customise and promote Our goods and services which may be of interest to You;
(d) to comply with or as permitted under the law; or
(e) with Your consent.
11.5 The Third Parties that We may disclose Your Personal Data include entities in Australia and only where necessary for us to provide goods and services purchased by You.
12. Direct Marketing to You
12.1 Unless otherwise objected by You pursuant to clause 3.10, We may communicate with You to promote Our products, services, the Business or the Website via email, phone or post.
12.2 We may use Personal Data You gave Us for the purposes of promoting and marketing Our products, services, the Business or the Website to You if We:
(a) use the information that You reasonably expected Us to use to receive promotion and marketing updates; and
(b) provide You a simple method to opt-out.
12.3 We will not contact You to promote or market Our products, services, Business or Website if You have objected to such communication from us under clause 3.10.
12.4 Notwithstanding clause 12.3, You may still receive non-marketing communications from Us from time to time, for example, to provide You with updates in relation to a purchase You have made with Us.
13. Complaints
13.1 If You believe We have breached the EU-GDPR, You have the right under the EU-GDPR and the EU Charter to lodge a complaint against Us to your local supervisory authority in your European Member State.
13.2 If You believe We have breached the UK-DPA or the UK-GDPR, You have the right to lodge a complaint against Us to the UK’s Information Commissioner’s Office at the following contact details:
Website: https://ico.org.uk/make-a-complaint/
Phone: +44-3031231113
13.3 If:
(a) You wish to discuss Your rights under this Privacy Policy or any of the Data Protection Laws;
(b) You believe We have breached the Data Protection Laws and wishes to raise a complaint with Us directly;
(c) You wish to discuss, or have questions about, any aspect of this Privacy Policy,
You may contact us at any time by email, phone or mail at the following contact details:
Contact person: Mark O’Brien
Email: office@beyondneutral.com;
Postal address: GPO Box 1584, Canberra ACT 2601; or
Phone: +61-408963626
13.4 If You contact Us pursuant to clause 13.2, please must allow Us a reasonable time, about 30 days, to reply to You.
14. Variation
14.1 We may update this Privacy Policy from time to time to reflect any changes to our processes or procedures and the Data Protection Laws’ obligations.
