Last updated 12/08/2020
1. Introduction
Hello! We’re Willsentry. Our website address is: https://www.willsentry.com. Willsentry is a product offering by TotalP2P (ABN 28827915272), based in Alexandria, Sydney, NSW, 2015, Australia. Please view our about us page for further information.
This Policy discloses how Willsentry (“Willsentry, we, us”) collect, disclose, use, store or otherwise handle personal information when you access our website or applications. We recognise the importance of protecting your privacy. Your information is a vital part of our relationship with you.
Principles that we follow:
- We don’t ask you for personal information unless we truly need it.
- We don’t share your personal information with anyone except to comply with the law, develop our products, or protect our rights.
- We don’t store personal information on our servers unless required for the on-going operation of our site.
This policy explains:
- What is considered to be personal information;
- What data we collect & why we collect it;
- Who we share your data with & why we share it;
- How we manage the personal information that we collect about you and measures we take to securely retain your data;
- Your rights to your data and how you can seek access to and correct that information;
- Our approach regarding third party content;
- Our communications approach in relation to your data;
- If necessary, how you can make a complaint relating to our handling of that information.
This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (“Privacy Act, the Act”);
We may, from time to time, review and update this policy, including taking account of new or amended laws, new technologies, and/or changes to our operations. All personal information held by us shall be governed by the most recently updated policy. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change. By using our website and our services, you acknowledge your consent to the practices described herein.
2. What is considered to be personal information?
When referred to in this policy, the term “personal information” has the meaning given to it in the Act. In general terms, it refers to any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card or direct debit account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
3. What data we collect and why we collect it
3. 1 Non personally-identifying information
Like most website operators, Willsentry collects non-personally-identifying information of the sort that web browsers and servers typically make available , such as the browser type, language preference, referring site, and the date and time of each visitor request. Willsentry’s purpose in collecting non-personally identifying information is to better understand how Willsentry’s visitors use its website. From time to time, Willsentry may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
3.2 Personal information
The following information is collected when individuals interact with our website in order that we can provide our service, understand product usage on our website, and respond to any customer queries or feedback. We collect information about you and your interactions with us, for example, when you visit our website using a desktop, tablet or mobile device. Some of this information is provided directly by you, and some is gathered by collecting data about your interactions with our products.
Depending on how you interact with our website, this may include personal information, such as:
- Your IP address
- Your name, or a pseudonym
- Your email address, or a pseudonymous email address
- Your company
- Your phone number
- Any messages you have sent us (feedback or queries)
- Additional information relating to you that you provide to us directly through our website, by phone, or in person, or information you have provided indirectly by means of using our website or online presence through our representatives or otherwise
3.2.1 Comments
If you leave a comment on our website, we collect the data shown in the comments form, and also your IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here. After approval of your comment, your profile picture is visible to the public in the context of your comment.
3.2 Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
3.3 Contact forms
We request you provide an email (a pseudonymous email may be provided), your name (a pseudonym may be provided), and your telephone number (optional) when you utilise our primary contact us form or engage with us via our Hotjar feedback. This information is requested in order that we can respond to your question or feedback.
For prospective legal partners that contact us via our legal partner page, in addition to the aforementioned fields, we request your company name. This is in order that we can adequately respond to your feedback or query.
3.4 Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
3.5 Embedded content from other websites
Articles on this site may on occasion include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
3.6 Analytics
3.6.1 Google analytics
We utilise Google Analytics to inform our understanding of how our website is being utilised by visitors. Google Analytics cookies help us distinguish between different users and understand how often a particular user may visit our site, how the user got to our site, and the user’s activity on our site. Google developed a resource – How Google Uses Information from Sites or Apps that Use Our Services – to help provide website visitors more information and choice on how their data is collected when websites use Google services.. You may elect to opt-out of customised advertising via the Google and Beeswax marketing platforms by using the opt-out mechanism available here.
3.6.2 Hotjar
We use Hotjar in order to better understand our users’ needs and to optimise our service and customer experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymised user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.”
3.7 Forms
3.7.1 Formidable forms
We use Formidable forms to provide contact us forms, and our on-boarding questionnaire form that is presented to users when they initially select to proceed to creating a beneficiary access plan plan. Any personal information collected is knowingly provided by you and only when requested/required. Formidable forms also records the browser and operating system you were using when you engaged with the forms on our website. While Formidable allow the possibility to record IP addresses of submissions via forms, we have disabled this feature. For further details regarding Formidable and their privacy policy, please see Formidable’s support site.
3.7.2 Mailchimp
We allow users to request to be contacted by us regarding upcoming feature availability where we currently do not offer a solution that suits their holding criteria. Additionally, we allow prospective legal partners to request to be contacted by us. In both cases, the sole information we collect is an email address. We utilise the mailchimp subscription service and capture entered emails in Mailchimp. While Mailchimp allows capture of additional personal information, the only field we capture is your email address. This is captured in order that we can contact you with an update regarding feature availability, or regarding a prospective partnership. Mailchimp’s privacy policy can be found here.
4. Who we share your data with
4.1 Google reCaptcha
We utilise Google’s reCaptcha v2 checkbox to prevent spamming from bots, and to verify that messages sent to us via our Contact us forms are legitimate. The reCAPTCHA API works by collecting hardware and software information, such as device and application data, and sending these data to Google for analysis. The information collected in connection with your use of the service will also be used for improving reCAPTCHA and for general security purposes. It will not be used for personalized advertising by Google.
First, the reCAPTCHA algorithm will check to see if there’s a Google cookie placed on the computer being used. Then, an additional reCAPTCHA-specific cookie will be added to the user’s browser, and a complete snapshot of the user’s browser window at that moment in time will be captured, pixel by pixel.
Some of the browser and user information collected at this time that can be considered as personal information includes:
- All cookies placed by Google over the last 6 months,
- How many mouse clicks you’ve made on that screen (or touches if on a touch device),
- The language your browser is set to,
- Any plug-ins you have installed on the browser
4.2 Askimet spam detection service
Visitor comments may be checked through the automated spam detection service, Askimet. Askimet collect information about visitors who comment on Sites that use their Akismet anti-spam service. The information they collect typically includes the commenter’s IP address, user agent, referrer, and Site URL (along with other information directly provided by the commenter such as their name, username, email address, and the comment itself).
4.3 Other parties
We do not share your data with any other third party where not already mentioned. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We may however release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. We do not send your data to any overseas party.
4.4. In the event of acquisition
If Willsentry, or substantially all of its assets were acquired, or in the unlikely event that Willsentry goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Willsentry may continue to use your personal information as set forth in this policy.
5. How we manage and retain your data
If you leave a comment on our website, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
We take all possible measures to ensure your data is protected. Our website uses an advanced real time security solution powered by Cloudflare, via our hosting provider WPEngine. 2 factor authentication is also required of site admins, to further protect data. Our staff have also undertaken security training.
Under no circumstances will we ever sell, or rent your personal data.
6. What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
7. How to contact us
In the event of any privacy concerns, you may contact us at any time via our contact us page.
8. Third party content
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
9. Marketing and communication activities
Under no circumstances will we engage with you via communications that could be deemed to be spam. We will only make contact with you where you have expressed intent that we should do so. In general terms – that is when you have contacted us via our contact us form, subscribed to be contacted, or engaged with our feedback form powered by Hotjar.
10. Making a privacy complaint
If you have a concern about your privacy, you have a right to make a complaint and we’ll do everything we can to put matters right.
To lodge a complaint, please get in touch with us using our contact us page. We’ll review your situation and try to resolve it straight away.
We will acknowledge every complaint we receive and keep you updated on the progress we’re making towards fixing the problem.
If your complaint is about the way we handle your personal information you may also contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, online at www.oaic.gov.au or by writing to the Office of the Australian Information Commissioner (“OAIC”), GPO Box 5218 Sydney NSW 2001.