Effective Date December 2020
Upside.Digital Pty Ltd
ACN: 139 669 248
ABN: 65 139 669 248
Our Commitment to Protecting your Privacy
Upside.Digital Pty Ltd respects your privacy and is committed to protecting it.
use it for, and to whom and when we disclose it. It is an important document so
please take the time to read it.
We will treat your personal information in accordance with our obligations under the
Australian Privacy Principles (APPs), the Privacy Act 1988 (Cth) and related
Australia laws. We refer to these collectively as “the Privacy Law”.
“Personal information” has a specific meaning set out in the Privacy Law, but
includes any information we hold which is about you or is reasonably identifiable as
being about you.
By providing us with personal information, visiting our websites or by using our
What Type of Personal Information Do We Collect?
We only collect personal information where necessary and relevant so that we can
provide you with access to information or other services. This may include, for
example, when you request to receive further information from an advertiser.
The extent and type of personal information collected will vary depending on how
you interact with us, but will usually include:
- data about you, your interests, and products/services you select to receive
- contact details such as your name, address, phone number and email address;
- other information such as your year of birth, gender, family size including children
and pets, your type of mobile phone, personal income, employment situation, online
shopping habits and personal interests.
Some personal information may be collected for activities not specifically outlined in
it when we do so.
How Do We Collect Your Personal Information?
We collect personal information from you in a variety of ways, including when you
interact with us electronically or in person, when you access our websites and when
we provide our services to you. We may receive personal information from third
How Do We Use Your Personal Information?
We use and disclose personal information to fulfil the purpose for which it is collected
or else for related purposes. This includes, for example, providing you with
information, updates and services.
We may make you aware of new and additional products, services and opportunities
available to you. We may also use your personal information to improve our products
and services and better understand your needs.
We may contact you by a variety of measures including, but not limited to telephone,
email, SMS (text message) or mail.
We may disclose your personal information to any of our employees, officers,
insurers, professional advisers, agents, suppliers or subcontractors insofar as
information is only supplied to a third party when it is required for the delivery of our
We may from time to time need to disclose personal information to comply with a
legal requirement, such as a law, regulation, court order, subpoena, warrant, in the
course of a legal proceeding or in response to a law enforcement agency request.
We may also use your personal information to protect the copyright, trademarks,
legal rights, property or safety of Upside.digital Pty Ltd,
https://www.realaussieheroes.com.au/ and http://UpsideDigital.com.au, our
customers or third parties.
If there is a change of control in our business or a sale or transfer of business
assets, we reserve the right to transfer to the extent permissible at law our user
databases, together with any personal information and non-personal information
contained in those databases. This information may be disclosed to a potential
purchaser under an agreement to maintain confidentiality. We would seek to only
disclose information in good faith and where required by any of the above
If we need to disclose your personal information to an overseas recipient such as an
advertiser or data warehouse who is not in Australia, we will take reasonable steps
to ensure that the recipient adheres to the Privacy Law in relation to your personal
We may also provide your information directly to third-party service providers for the
purposes of servicing your requests or enquiries. These providers have their own
obligations under the Privacy Law and will have their own privacy policies. Your
interactions with those providers will be governed by those separate policies, and by
using our Services you are consenting to the disclosure of your personal information
on that basis.
How Do We Hold and Disclose Your Personal Information?
We hold your personal information on secure servers located in Australia and the
We disclose personal information to our advertisers, customers, third party agents,
directors, employees and contractors only for a purpose that is consistent with the
How Do We Keep Information Secure?
We are committed to ensuring the security of the information we hold about you. We
will always try to ensure that we take all reasonable steps to protect your information
from misuse, interference and loss, and from unauthorised access, modification or
If we no longer need any information, we will take reasonable steps to destroy and/or
de-identify the information, unless this is required to be retained to comply with any
of our legal requirements.
We have no control over information that may be transmitted over the internet, so
therefore cannot guarantee its safety whilst in transit.
What Happens if There is a Data Breach?
If a suspected data breach occurs, we will determine the extent of the breach. A data
breach may occur if your personal information is lost or subjected to unauthorised
access or disclosure.
If we believe that the suspected data breach is likely to result in serious harm to you,
we will notify you and the Office of the Australian Information Commissioner as soon
as practicable and as required by the Privacy Law. This notification will set out a
description of the data breach, the kinds of information concerned, and
recommendations about the steps you should take in response to the data breach.
What Additional Data Do We Collect via Our Websites?
When you come to our websites (e.g. https://BillySumo.com.au and
http://UpsideDigital.com.au) we may collect certain information such as browser
type, operating system, website visited immediately before coming to our site, etc.
This information is used in an aggregated manner to analyse how people use our
site, such that we can improve our service.
Our web server will also collect the following information:
• Your Internet service provider’s address;
• The number of users who visit the website;
• The date and time of each visit;
• The pages accessed;
Data collected from our websites remain the property of Upside.digital Pty Ltd.
A cookie is a small piece of computer code which remains on your computer and
contains information which helps us identify your browser and previous information
viewed in relation to our services. When you visit our websites, the cookie records
certain details including the date, time and advertising content. None of the
information in the cookie contains personally identifiable information about you.
when they are being used, by adopting the appropriate settings on your browser. If
you do not allow cookies to be used some or all of our websites might not be
accessible to you.
By using our websites you consent to us sharing a hashed, anonymous, readable
version of your email with our partner Service Providers who will drop a cookie on
your browser for the purpose of improving the relevance of online advertising and
content by third parties that are unaffiliated with our websites.
marketing and other purposes.
Third party sites
Our websites may from time to time have links to other websites not owned or
controlled by us. These links are meant for your convenience only. Links to third
party websites do not constitute sponsorship or endorsement or approval of these
websites. Please be aware that we are not responsible for the privacy practices of
other such websites. We encourage our users to be aware, when they leave our
websites, to read the privacy statements of each and every website that collects
personal identifiable information.
How do you contact Us to Amend, Delete, Unsubscribe or Access Your
We try to ensure that all information about you that we collect, use or disclose is
accurate, complete and up-to-date.
Under the Privacy Law, you have the right to obtain access to any personal
information which we hold about you, and to advise of any inaccuracy, if it is out of
date, incomplete, irrelevant or misleading. There are some exceptions to this right
set out in the Privacy Law.
If you want to correct data about you as you believe the data we hold is incorrect or
you want to request the deletion of your personal information from our database or
you simply require access to any personal information that we hold about you, then
you should inform us and we will make every reasonable efforts to provide it and, if
required, correct it.
If you would like to unsubscribe at any time you may simply click the hyperlink
located at the bottom of all our branded mailings.
Any enquiries or requests should be in writing to: Privacy Officer, Upside.Digital,
Level 5, 501/22 Central Avenue, Manly, NSW, 2095, Australia.
please contact us on either: email@example.com or +61 2 9114 6715 or write to us at
The Privacy Officer, Upside.Digital Pty Ltd, Level 5, 501/22 Central Avenue, Manly,
NSW, 2095, Australia.
The Privacy Officer will act upon all substantiated complaints or comments made on
modify this Policy at any time, in our sole discretion and all modifications will be
effective immediately upon our posting of the modifications on our website or notice