Direct IT Privacy Policy

DirectIT Pty Ltd and its related entities (“DIT”, “we”, ‘us’) recognize that data protection and privacy rights are important to the people (“you” or “your”) whose information we collect or receive. This privacy policy (“Policy”) explains how we collect, use, share and protect the information you provide to us and other information we may collect about you and other individuals and companies.

Please read this Policy in its entirety so that you can obtain a clear understanding of what data we collect, how it’s collected as well as how we use the data.

The Policy will also help you to understand the choices that we offer, as well as how to change your preferences regarding how we collect and use your data.

In this Policy, ‘Personal Information’ means any information that may be used to identify you personally, such as your name, address, email or telephone number.

From time to time, we will include links to third party websites (including via display advertising) on our website or communications with you. If you choose to follow such links to any other websites, please be aware that our privacy policy no longer applies and that, from the moment you enter a third party’s website, their own privacy policy will govern any collection, storage and use of any of your information.

1. Who are We?

We are an Australian owned and operated provider of marketing and sales solutions to a wide range of IT clients, operating globally, across a variety of areas of technology.

Our offering includes the following:

  • the operation of its own website www.directit.com.au;
  • the operation of landing pages on behalf of our clients (directit.com.au and landing pages collectively, the “DIT Sites”);
  • advertising services (“DIT Ad Services”) whereby we assist our clients to display relevant online advertising to end users (“End Users”) who interact with third party websites (“Third Party Sites”); and
  • a range of other marketing-related services, including email, mail and telemarketing.

2. What Information do we collect? and How?

What we collect from you (either directly or via 3rd parties) and how we collect it, along with our privacy practices depend on what sort of relationship we have with you as well as the requirements of applicable law. Here, we set out why we collect information from you, both directly and automatically as well as from other sources, how we collect and use that information, and what type of information we collect directly as opposed to from third parties.

a) Information That You Share with Us.

From time to time, we may ask you to provide Personal Information on DIT Sites voluntarily, such as when you submit a request for further information in relation to our services, subscribe to marketing emails, or otherwise contact us. We collect this Personal Information in order to provide you with relevant and useful content and services, and, from time to time, to offer you opportunities to obtain other products and services from us and our partners.

The Personal Information that you might provide to us in these settings, include business contact information such as your name, address, phone number or email address) and contact preferences. You may also provide us with further Personal Information such as specific professional information such as your role, or the company you work for) as well as the nature of your request or communication. We sometimes also collect further information from ‘free text’ boxes you may choose to fill-out on our forms.

From time to time, you may provide us with Personal Information, during a marketing call or in response to an email or direct mail campaign such as alternative or additional contact methods or details. This might include business contact information such as your name, address, phone number or email address) and contact preferences and other professional information. What information do third parties collect automatically?

When End Users visit Third Party Sites, we or our client may use and deploy technologies to automatically collect certain information about those End Users and their devices. From time to time this information (including, for example, an IP address and unique identifiers stored in a cookie) may identify a computer or device and may in certain circumstances be considered “Personal Information”. The DIT Ad Services are, however, designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as your name, address, or email address). We may collect this information by assigning a random unique identifier to your device the first time you interact with an advertisement on a Third-Party Site. This unique identifier may then associate you with information that we may collect about you. This information we may collect includes information about your browser and device information, information about your online behaviour and information about ads served, viewed or clicked on.

b) Information provided by Third Parties.

Sometimes we may combine or enrich the information we collect about you with information collected from third parties such as other web-based and mobile networks, exchanges and websites (“Partners“) or our clients.

This information may include hashed identifiers derived from other information such as email addresses, mobile device IDs, demographic or interest data (like your industry, employer, company size, job title or department) and content viewed or actions taken on a Third-Party Site to help make the ads served to an End User more relevant while limiting exposure to less relevant ads.

From time to time, in order to perform our marketing services, our clients might provide us with business contact lists to use as part of a specific campaign. This data is only used for the client providing the information and its use is limited by the client’s instructions. Occasionally, we may also obtain information from the reception of a business which may include business contact information (e.g. your name, physical address, phone number or email address) and other professional information (e.g. your job title, department or job role).

Data contained in the DIT database originates from a variety of sources including data suppliers, campaigns and our own research.

3. Is your collection, storage and usage of Personal Information legal?

We process Personal Information relying on both consent and legitimate interest.

We are able to process Personal Information pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. Our collection, storage and use of Personal Information pursuant to legitimate business purposes allows us to respond to your inquiries and to fulfill your requests, to send you relevant marketing information and offers, or to complete transactions. We are also able to share the information provided by you with third parties, who use this information to recognise you across different channels and platforms over time for advertising, analytics, attribution and reporting purposes

The legal basis for our collection and usage of Personal Information will depend on the Personal Information concerned and the specific circumstances in which it is collected. Generally, however we rely on our legitimate interests to collect Personal Information from you (unless such interests are overridden by your data protection interests or fundamental rights and freedoms).

If you have any further questions about the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the ‘contact us’ section below.

4. Why do we use your Information?

We collect, store and use your information based on the legal grounds and for the legitimate business purposes outlined in this Policy, including:

  • In order to provide and enhance our services - We may use information we acquire to manage, operate, research, develop, improve, and personalise its business and services, including its business systems and infrastructure and upgrading these systems.
  • Advertising (including ‘interest based’ advertising) and marketing for us and our customers
  • As required by applicable law - We may use all data we collect or receive as required under law, legal or financial processes such as audits or regulations, or to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence.
  • For reporting purposes - We may create reports for DIT clients on the companies and/or users that complete certain actions, such as completing a survey, opening/clicking email, visiting an DIT managed site or a client managed site.
  • To operate our business - We may use the information we collect for billing, account management, invoicing, internal and external audit requirements, information security purposes, investigating security and privacy incidents, including verifying your identity as part of any complaint about or submitted by you, or if we have reason to suspect that you are in breach of any of our terms and conditions, as well as other legitimate business interests.
  • Other purposes - we may also use the information: (i) to respond to or provide you with information you request; (ii) if you have applied for a role with us, for recruitment related purposes; (iii) to prevent, detect, respond and protect against potential or actual claims, liabilities, prohibited behaviour and criminal activity; and (iv) as we otherwise believe to be necessary or appropriate under applicable law, which may include laws outside your country of residence.

5. Who else do we Share Your Information With and for What Purpose?

We will only share or disclose information in accordance with all applicable laws and regulations. Examples include:

  • Our clients and Partners - We share information for marketing, advertising, and engagement with our customers, such as market research and providing interest-based advertising. We also share company or Personal Information with our clients for reporting and marketing purposes. In addition, from time to time we may share this information with third parties on behalf of the client where DIT have been specifically requested to do so by the client or through a contractual arrangement e.g. a client has appointed a third party to analyse the data or carry out a further service on the client’s behalf.
  • Business Activities – We share information for our legitimate business needs, (including, but not limited to, for any business, audit, or legal purposes). We may also share your information with third party service providers who work on our behalf and who may need access to your information in order to provide their services to us and may use your information in connection with the provision of such services.
  • Security - We may share information for security, fraud prevention, law and policy enforcement purposes, such as responding to legal matters or law enforcement requests or enforcing our policies and terms, protecting rights, property, and safety of individuals or other third parties.
  • Marketing - Any information provided by you voluntarily, for marketing purposes or otherwise, may be shared with i) any other third party, client or partner mentioned when you provide such information or are contacted by us or ii) clients who have products or services that may be of interest to you.
  • Website advertising partners - We may partner with third party advertising networks and exchanges to display advertising Third Party Sites, or to manage and serve our advertising on such sites and may share your Personal Information with them for this purpose.
  • Vital interests and legal rights - We may disclose information about you if we believe it necessary to protect our, your or any other person’s vital interests or legal rights.
  • To our related parties - We may provide your information to our affiliates (meaning any subsidiary, parent company or company under common control with DIT). Our affiliates will use your information only for the purposes described in this Policy.
  • For legal purposes - We may share your information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • With consent - We may disclose an individual’s information to any other person with the individual’s consent to such disclosure

6. How Do We Protect Your Data?

We use a wide range of different strategies to protect data and information under our control from misuse, loss or alteration. We have deployed various appropriate technical and organizational measures to protect the information we hold, including technology and equipment to help protect our information, segregated databases and systems, firewalls, systematic controls and maintained security measures regarding who may and may not access our databases, systems etc.

7. Opting Out and Your Privacy Rights

We will only use your Personal Information for the purposes described in this Policy or as otherwise consented to by you. The choices we offer regarding how your Personal Information is used and shared is set out below.

If you no longer want to receive marketing-related emails, mail or telemarketing from us on a going-forward basis, you may opt out of receiving these marketing-related communications by: (i) clicking on the unsubscribe link within the email message that you receive from us; or (ii) notifying us during a marketing call.

8. General

a) Can I Make a Complaint About a Breach of Privacy?

In the event that you have any questions or concerns about our Privacy Policy, or believe that we have breached your privacy, please contact us using the contact information below with details of the incident so that we can investigate it.

We have a formal procedure for dealing with any complaints around privacy breaches. Once the Privacy Officer receives a complaint, they will open an investigation with the relevant business unit from which the alleged breach stemmed. They will look to determine what sort of breach occurred and how it happened. We may contact you during the process to seek any further clarification if necessary. In the event that a breach is discovered, the matter will be escalated to management in order for inadequate systems to be rectified thereby preventing further breaches from occurring. We will endeavour to resolve all investigations within a reasonable time and will notify you of the outcome of such investigations

All requests and complaints regarding privacy will be treated as confidential. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved

Please contact our Privacy Officer at:

To: Privacy Officer, DirectIT Pty Ltd

Address: Level 1, 55 Mountain Street, Ultimo NSW 2007 Australia

Tel: +61 2 9563 4000

Email: privacy@directit.com.au

b) Data Retention

We will retain Personal Information we collect from visitors as well as data we process on behalf of our clients for as long as needed to provide our services to our visitors and clients. We will retain Personal Information only as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements in your (respective) jurisdiction(s).

c) Privacy Policy Updates

This Privacy Policy will be updated from time to time in order to comply with any changing legislation and to ensure the policy accurately reflects our current business practices. If and when we amend this Privacy Policy, an updated version of this Privacy Policy will be maintained at www.directit.com.au.

All personal information, collected both before and after any changes take effect, will be subject to the terms of the updated Policy (for which you will be taken to have provided consent) unless you indicate otherwise by contacting the office of DIT’s Privacy Officer as per the details in section 9 above. We encourage you to check our website from time to time to view our most current Policy.