Routinr is committed to providing you with the best user experience. Routinr is bound by the Privacy Act 1988 (Crh), which sets out a number of principles concerning the privacy of individuals.
Information We Collect
When you register to the Site we ask you to provide certain personal information, including a valid email address, location, facebook or google account log in details and username. We may collect additional information such as physical address, telephone number or other contact details and additional authentication information, to provide you with the services you need (such as payment or withdrawal of funds, sending physical goods), or to ensure the marketplace integrity (for example, prevention of fraud).
In addition, we collect information while you access, browse, view or otherwise use the Site. In other words, when you access the Site we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage, including geo-location information, IP address, device and connection information, browser information and web-log information, and all communications recorded by Users through the Site. We use that information to enhance user experience, personalize your browsing experience as well as monitor the Site for preventing fraud and inappropriate content or behaviour. We may also collect supplemental information obtained from third parties such as demographic and navigation data.
How do we collect Information?
How do we use the Information collected?
Where relevant under applicable laws, all processing of your personal information will be justified by a "condition" for processing. In the majority of cases, processing will be justified on the basis that:
- you have provided your consent for us to use your personal information for a specific purpose;
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);
- the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or
- the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you or to customise your browsing experience), subject to your interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
We will use your personal information for the following purposes:
- to provide you with quality service and security. For example, we may use the information collected from you to verify your identity. We may also use this information to establish and set up your account, verify or re-issue a password, log your activity and contact you from time to time. The information helps us improve our services to you and customize your browsing experience. In addition, this information helps us track any fraudulent activities and other inappropriate activities and monitor content integrity; or
- to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law. Should you ever deactivate your account with us, we will keep your information for a limited period in order to meet the above purposes.
We will ask for your consent before using information for a purpose other than those set out in this Policy.
- We may use your personal information to send you direct marketing communications about our products, services or promotions from Routinr that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.
- In most cases our processing of your personal information for marketing purposes is based on our legitimate interest, although some cases (such as where required by law) may be based on your consent. You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out link attached to each communication or by sending an email to firstname.lastname@example.org
- We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
How long do we keep your information?
We apply a general rule of keeping personal information only for as long as is required to fulfil the purpose for which it was collected. However, in some circumstances we may retain your personal information for longer periods of time. We may retain your information for the following purposes:
- as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and
- we may retain personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law.
Children Under the Age of 13
Our Site is not intended for children under 13 years of age. No one under age 13 should provide any personal information to or on the Site. We do not knowingly collect personal information from children under 13. Parents and guardians should at all times supervise their children's activities. If we learn we have collected or received personal information from a child under 13, we will delete that personal information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
Where We Store Your Personal Information
Some of the personal information you provide to us may be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, such as the United States or Australia, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, any transfers of personal information from the European Economic Area (“EEA”) to countries not deemed to provide an adequate level of data protection are governed by European Union (EU) standard contractual clauses, or in the case of the United States, the EU - US Privacy Shield, and/or equivalent data transfer regulations to protect the security and confidentiality of personal information. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
When you visit the Site, we may use industry-wide technologies such as "cookies" (or similar technologies), which store certain information on your computer and which will allow us, among other things, to enable automatic sign-in to the Site, make your browsing much more convenient and effortless and allow us to test user experience and offer you personalized browsing or promotions. By continuing to use this Site, you are agreeing to our placing cookies on your computer or device in accordance with the terms of this Policy.
- Necessary cookies
Necessary cookies are essential and help you navigate the Site. This helps to support security and basic functionality and are necessary for the proper operation of the Site, so if you block these cookies we can't guarantee your use or the security during your visit.
- Functionality cookies
- Performance cookies
Performance cookies help us to understand the behaviour of users of the Site. This allows us to continuously improve the Site to provide the best information in support of our project aims. These cookies are also used to help us understand how effective our Site is; for instance these cookies tell us which pages visitors go to most often and if they get error messages from web pages. All of the information that these cookies collect is aggregated, to assist us to improve how the Site works. Some of these cookies are managed by third parties, and you may refer to the third parties' own website privacy notifications for further information. In particular, we use Google Analytics cookies to obtain an overall view of user habits and volumes, and to help improve the overall experience on the Site. Google Analytics is a third-party web analysis service provided by Google Inc, which uses performance cookies and targeting cookies. The information generated by these cookies about your use of the Site (including your IP address) will be transmitted to and stored by Google Inc on servers in the United States.
If you prevent these cookies, we cannot guarantee how the Site will perform for you.
Blocking or Deleting Cookies
- Internet Explorer
- Google Chrome
- Adobe (flash cookies)
Rights of Users Under EU Regulation
Under applicable EU regulation, as of May 25, 2018 you may have some or all of the following rights in respect of your personal information:
- to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
- to rectify inaccurate personal information;
- to erase your personal information in limited circumstances where it is no longer necessary in relation to the purposes for which it was collected or processed;
- to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim;
- to challenge processing which we have justified on the basis of our legitimate interest;
- to object to decisions which are based solely on automated processing or profiling;
- to obtain a portable copy of your personal information, or to have a copy transferred to a third party controller; or
- to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA
In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection.
We may ask you for additional data to confirm your identity and for security purposes, before disclosing data requested to you. We reserve the right to charge a fee where permitted by law. We may also decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
Updating Your Information
We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it - unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. If for any reason you have a problem with deleting your personal information please contact Routinr’s Customer Support and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws. You can review and change your personal information by logging into the Site and visiting your account profile page.
If you delete your User Generated Content (UGC) from the Site, copies of your UGC may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including UGC, is governed by our Terms of Service.
Accessing Your Personal Information
You have a right to access your personal information, subject to exceptions allowed by law. If you would like to do so, please let us know. You may be required to put your request in writing for security reasons. Routinr reserves the right to charge a fee for searching for, and providing access to, your information on a per request basis.