Privacy Policy

1. ACCEPTANCE OF POLICY

1. 1.1 ZOFELA Pty Ltd (ACN: 169 724 181) and/or its associates, related parties, successors and assigns (collectively referred to as “Provider”, “us”, “we” or “our”), being owner and operator of the Website, has created this Privacy Policy in order to demonstrate our firm commitment to your privacy. The following discloses our information gathering and dissemination practices for the Website.
2. 1.2 This Privacy Policy is supplementary to the General Terms and Conditions (“T&C“) of the Website, and is incorporated into the general T&C by this reference. Unless otherwise defined herein, all capitalised terms are defined in the T&C.
3. 1.3 By accessing and using the Website, you agree to be bound by this Privacy Policy.
4. 1.4 The Website may contain links to websites of third parties. By clicking on such links, you may be transferred to the website of the third party. We are not responsible in any way for the privacy practices of such third parties and you are advised to view and read the privacy statements issued by the third parties to ensure that you understand and agree to the same.

2. COLLECTION OF DATA

1. 2.1 Your privacy and security is of utmost importance to us. We will always follow the principles of the National Privacy Principles promulgated under the Privacy Act 1988 (Cth), as amended or updated from time to time (“National Privacy Principles”) and ask you how you would like us to communicate with you.
2. 2.2 In order to become a Registered User of the Website, or a Client of the Provider, you may be required to provide certain information, including any information which may be used to personally identify you (“Personal Information”), in the applicable registration, submission or contact form as part of your Registration Data or Client Data, as the case may be. Personal Information includes your name, address, phone number(s) and email address and any other information which may, or may lead to, the disclosure of your identity as an individual.
3. 2.3 You may also be required to provide Personal Information to us when you communicate with us in any other way through or in connection with the Website, including when you:
   • (a) request for further information on our services;
   • (b) request for any advice or assistance in relation to the Website Content, including any resource tools thereof; or
   • (c) report a problem or contact us by way of email, telephone call, fax message, letter or through any other means of communication.
4. 2.4 Except for the circumstances outlined in Clauses 2.2 and 2.3, we do not collect Personal Information from you when you access the Website as a Visitor.

3. USE OF DATA

1. 3.1 Any Personal Information submitted to us, together with any other information, material or content you have provided, including all other User Content (collectively, “Data”) shall be used primarily for administrative purposes and for the purposes to which they were submitted or required.
2. 3.2 We may also decide to use the Data for the following additional purposes:
   • (a) to understand what your needs and requirements are;
   • (b) to provide personalised content and match the most relevant services for you;
   • (c) to improve on our marketing and customer service efforts;
   • (d) in other advertising, statistical compilation or marketing-related purposes; and
   • (e) to profile your information preferences, for example, understanding how you use the Website and reviewing your search contents, any service pages or Website Content you access.
3. 3.3 Unless you inform us otherwise in accordance with Clause 5.3, we may also use your Data to communicate with you (“Communications”): (
   • (a) by sending you notices regarding updates, changes or additions to the Website or Website Content and regarding any promotions which may be of interest to you;
   • (b) by inviting you to participate in our surveys;
   • (c) by requesting for your views on the Website and/or our customer support; or
   • (d) by responding to your requests.

4. DISSEMINATION OF DATA

1. 4.1 Be assured that we will never sell your Data to any third parties for commercial gain.
2. 4.2 However, we may disclose your Data:
   • (a) to our consultants, advisors, service providers and agents (“Third Parties”):
     • (i) to assist us to achieve the purposes described in Clauses 3.1 and 3.2; and
     • (ii) to assist us in our Communications to you (unless you have informed us that you do not wish to receive any of our Communications in accordance with Clause 5.3); and
   • (b) to our business partners who may communicate with you (“Business Partner Communications”)
     • (i) by sending you notices regarding any promotions or products or services offered by them which may be of interest to you;
     • (ii) by inviting you to participate in their surveys;
     • (iii) for other advertising, statistical compilation or marketing-related purposes; or
     • (iv) by responding to your requests, unless you have informed us that you do not wish to receive any Business Partner Communications in accordance with Clause 5.3.
3. 4.3 We may also be required to disclose your Data in the following circumstances:
   • (a) to comply with a legal process;
   • (b) to enforce the general T&C, this Privacy Policy or any other agreements executed with you or any related entity;
   • (c) to protect the rights, property or personal safety of other Users and/or the public, or to protect the business operations of the Website;
   • (d) where applicable, to credit reference agencies, where your Data may be used by other credit grantor’s for the purposes of:
     • (i) making credit decisions about you and the people with whom you are financially associated with;
     • (ii) fraud or money laundering prevention; and
     • (iii) occasionally, for tracing debtors.
4. 4.4 Accordingly, your Data will be disclosed where we are obliged or permitted by law to do so. If you post or send offensive or objectionable content to us or otherwise engage in any disruptive behaviour in respect of the Website, we can use whatever Data that is available to us about you to stop such behaviour. This may involve informing relevant third parties such as your employer and law enforcement agencies about the content and your behaviour.
5. 4.5 In addition, any Client who purchases a domain name from us will need to be aware that domain name registration information must legally be disclosed to the public and accessible to any persons conducting a “WHOIS” search. The “WHOIS” database is a publicly accessible database that lists the domain name and contact information of each domain name registrant and a Client may consequently be exposed to solicitation and/or spam messages from such persons.

5. CONSENT AND OPTING-OUT

1. 5.1 By submitting or providing your Data to us, you expressly acknowledge, consent and agree to:
   • (a) our use or processing, or the disclosure to, or use or processing by, Third Parties, of your Data, including any Personal Information contained in your Data, for the purposes described in Clauses 3.1 and 3.2;
   • (b) subject to Clause 5.3, the use or processing of your Data, including any Personal Information contained in your Data, for the purpose of sending you any Communications; and
   • (c) subject to Clause 5.3, the use or processing by our Business Partners of your Data, including any Personal Information contained in your Data, for the purpose of sending you Business Partner Communications.
2. 5.2 We follow strict security procedures to ensure that your Data is protected and that it is not damaged or destroyed. All Data is kept in a secure place with restricted physical or electronic access, and with confidentially preserved. Only the senior management team of the Provider is permitted access to the Data. Notwithstanding the aforesaid, you expressly acknowledge and agree:
   • (a) that the transmission of information via the internet is not completely secure. We will do our best to protect your Data but we are unable to guarantee the security of your Data submitted or provided through or in connection with our Website, and accordingly, any submission or provision of Data is made at your own risk; and
   • (b) that the transfer and processing of your Data may be undertaken in countries outside of China, which may not provide the same level of data protection as China. If we do make such a transfer or if your Data is to be processed outside China, we will put a contract in place to ensure your Data is protected or where applicable, is covered by the US ‘Safe Harbor Program’.
3. 5.3 You may inform us by way of email sent to info@23digital.com.au if you wish to exercise your right to opt out of receiving any Communications from us or Business Partner Communications from our business partners. If you do opt out, this may preclude you from receiving any of our special offers or promotion, whether offered by us or by any business partners in future.

6. COOKIES

1. 6.1 As with the majority of websites on the internet, when you visit the Website, our computer server will automatically send you a cookie. A cookie is a small ‘log-file’ that can be placed on your computer’s hard disk for record-keeping purposes and we may use them to do a number of things:
   • (a) cookies help us to recognise you when you next visit our Website and note the advertisements displayed to you. This allows us to tailor the promotions we provide to your preferences. We may use the services of third party servers for this purpose;
   • (b) cookies may be used to compile anonymous statistics related to the take up or use of Services, or to patterns of browsing. A third party may collect such data on our behalf to measure the performance of the Website. Information collected is aggregated for reporting purposes, and no personally identifiable information is collected by this service. The use of this service assists us in measuring and improving the structure and ease of use of the Website;
   • (c) we may also track IP addresses. An IP Address is a number that can identify an Internet Service Provider, country location etc. It cannot provide personal information. We will not use the IP Address to build a profile on Users, we only use the information for demographic and statistical purposes.
2. 6.2 It is also possible that others may download cookies to your computer when you access, visit or use the Website. We cannot control nor do we have access to any cookies placed on your computer by such other persons.
3. 6.3 Cookies cannot be used by themselves to identify you. You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. If you do disable cookies, many of the Services may not be available to you.

7. RETAINING AND DELETING DATA

1. 7.1 Upon termination of your access to the Website in accordance with the general T&C, we may still be required to retain your Data in order to comply with legal obligations, prevent fraud, collect fees owed (if any), resolve disputes and troubleshoot problems etc, but always done within a legal framework.
2. 7.2 When you request for your Data to be removed in accordance with Clause 5.3, you will be added to a suppression list to ensure your request is complied with. All Data is used and processed in line with the requirements of the National Privacy Principles.

8. INFORMATION REQUESTS

1. 8.1 You have a right to ask for a copy of your Personal Information and are obliged to correct any inaccuracies in your Personal Information. If you are unable to use our Website to correct such inaccuracies, you may ask us to do so on your behalf (where possible). To make sure we follow your instructions correctly and to improve our services to you through training of our staff, if your request is made orally, we may monitor or record your telephone calls with us.
2. 8.2 Unless the Personal Information relates to an individual which you are legally responsible for (such as a minor), you may not give us Personal Information about any other person. If you do so, you confirm that they have appointed you to act for them, to consent to the processing of their Personal Information, including sensitive personal data, to the transfer of their Personal Information abroad and to receive on their behalf any Communications from us or any Business Partner Communications from our business partners.

9. MODIFICATION OF PRIVACY POLICY

1. 9.1 This Privacy Policy may be modified from time to time as a result of any changes in the law, best practice and/or in the Website without notice to you. The most current version of this Privacy Policy as posted on this page shall supersede all previous versions.
2. 9.2 It is your responsibility to check regularly to determine whether a new version of the Privacy Policy has been uploaded.

10. QUESTIONS

1. 10.1 If you have any questions about this Privacy Policy, the practices of the Website, or your dealings with the Website, you can email the Data Officer at info@23digital.com.au