Privacy Notice

Basics

We abide by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.  If you are located in an EU country or in the UK the GDPR Addendum at the end of this policy also applies to personal information concerning you.  

“We“, “us” and “our” and “Rely” means Clarity Plus Pty Ltd ACN 085 927 377, trading as Rely Platform, and any subsidiaries of that company.

“Rely Service” means the incident management software platform made available by Rely. 

“Rely Subscriber” means an organisation that uses the Rely Service. 

“Rely Website” means the public-facing website made available at relyplatform.com or any replacement domain from time to time, and also includes any web-accessible components of the Rely Service. 

“Rely Website User” means a person who interacts with our Rely Website.

“Rely Service User” means a person who interacts with any web-accessible components of the Rely Service to submit information.

You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.

Who do we disclose your personal information to, and why?

Generally, we may disclose your personal information to any Rely Subscriber you are associated with. However, if we tell you that we will preserve your anonymity then we will not share your name (or other information we believe will identify you) with a Rely Subscriber unless you consent to it or the law requires us to.  (For instance, the law might require us to disclose your name in court proceedings.)  Similarly, we will not share Google Analytics or other technical data about your interactions with the website with a Rely Subscriber unless you consent to it or the law requires us to.

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to external service providers so that they may perform services for us or on our behalf, and to third party platforms where your relevant Rely Subscriber chooses to use any plugins or integrations between the Rely Service and those platforms.

We may also disclose your personal information to others where:

1. we are required or authorised by law to do so;
2. you have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; 
3. the disclosure appears reasonably necessary to protect or enforce our legal rights or to protect anyone’s safety; or
4. we are otherwise permitted to disclose the information under the Privacy Act.

If the ownership or control of all or part of our business changes, or we enter into a joint venture or similar arrangement, we may transfer your personal information to the new operator (and some information may be provided if possible new operators, investors or lenders investigate our business).

What is personal information?

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

What personal information do we collect and hold?

We collect information about you and your interactions with us, for example, when you visit the Rely Website, create an account to login to the Rely Service, login to the Rely Service,  call us, interact with any chatbots we provide or submit information via the Rely Service. 

We also collect information about you when a Rely Subscriber or another Rely Service User enters it into the Rely Service.  For instance, if your employer is a Rely Subscriber and you make a bullying complaint in your workplace, or are the subject of one, your employer is likely to enter information about you in the Rely Service, and so might other people involved in the investigation process.  Or, as another example, if you are an employee of a business, that business has a customer who is auditing whether its pays its employees properly and the customer is a Rely Subscriber, then the customer may enter information about you in the Rely Service. 

Some of the information we collect may be sensitive information, such as your racial or ethnic origin, religious beliefs, sexual orientation or health conditions.  This will generally only be collected by us when a Rely Subscriber or Rely Service User enters it into the Rely Service.  For instance, if your employer is a Rely Subscriber and you make a complaint that you have been discriminated against on the basis of your religious beliefs, your employer is likely to enter details of your religious beliefs in the Rely Service. 

We may collect information about how you access, use and interact with the website and our software. We do this by using a range of tools such as Google Analytics. This information may include:

1. the location from which you have come to the site and the pages you have visited and other information about how you interact with our services, including page views, bytes transferred, hyperlinks clicked and other actions you take; and
2. technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language, operating system and inferred location.

We use cookies and other user recognition technologies, such as web beacons (or clear gifs), on the Rely Website. We may use persistent cookies and recognition technologies (which function even after you close your browser) and session cookies and user recognition technologies (which no longer function after you end your browsing session) to help manage the display and presentation of information on the website. You might be able to block some of these technologies, such as cookies, by configuring your browser, but that is likely to render you unable to use the Rely Service and may also inhibit your use of the Rely Website.

Why do we collect, hold and use your personal information?

We collect, hold and use your personal information so that we can:

1. provide the functionality of the Rely Service and Rely Website to you, where you are an end user or are interacting with the Rely Website;
2. provide the functionality of the Rely Service to a relevant Rely Subscriber; 
3. contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
4. comply with our legal obligations and assist government and law enforcement agencies or regulators; or
5. identify and tell you about other products or services that we think may be of interest to you.

If you do not provide us with your personal information we may not be able to provide you with our services, communicate with you or respond to your enquiries.

How do we collect your personal information?

We will collect your personal information directly from you whenever you interact with us.

We may also collect your personal information from third parties such as Rely Subscribers and Rely Service Users. 

How do we store and hold personal information?

Rely Service User 

We store most information about you in computer systems and databases operated by us, on servers made available by reputable cloud hosting services.  Those servers are located in Australia. 

We implement and maintain processes and security measures aimed at protecting personal information from misuse, interference or loss, and from unauthorised access, modification or disclosure. 

These processes and systems include:

1. the use of identity and access management technologies to control access to systems on which information is processed and stored;
2. the use of technologies aimed at ensuring that the only Rely Subscribers to whom personal information is available are the Rely Subscribers you are associated with;  and
3. requiring all employees to comply with internal information security policies and keep information secure.

Our Information Security Management System was certified as being compliant with ISO27001 in 2022. 

No process, system or technology is perfect however, and we cannot guarantee that these will be effective. 

Rely Website User

We utilise the Hubspot Platform to store all website visitor, contacts and customer details. Hubspot XYZ . Hubspot utilises datacentres based in the USA and Europe. Hubspot’s commitment to best practice security can be found here https://legal.hubspot.com/security 

Do we disclose personal information to overseas recipients?

We may disclose your personal information to recipients which are located outside Australia. 

Do we use de-identified personal information for other purposes?

Once we have de-identified personal information so that you can no longer reasonably be identified from it that information is outside the scope of this policy, and the restrictions in this policy don’t apply to it.  

Do we use your personal information for marketing?

We do not, unless it is for our own services and you are a user of the software (as opposed to a person just referred to in information that a user uploads to the Rely Service). If that is the case, you consent to us sending you electronic messages for the purpose of that marketing.  

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

Remarketing Using Third Party Ad Networks

We may also market our services to Rely Website Users and Rely Service Users by using ‘remarketing’ or ‘re-engagement’ services offered by third party ad services.  At the time of writing this policy, the third party service we use for this is Google Ads.  In this respect:

• Google Ads (or any similar service we use in the future) are more likely to show ads for our services on other websites and other electronic channels to Rely Website Users and Rely Service Users, compared to the general public.
• Google Ads (or any similar service we use in the future) will deploy cookies and possibly other user recognition technologies (such as web beacons (or clear gifs)) on the Rely Website. 
• Those cookies (and possibly other user recognition technologies) will be used by Google Ads (or any similar service we use in the future) to identify you or your device as a prior visitor to the Rely Website or Rely Services and serve our ads (and perhaps other ads) to you based on that.  
• You can opt out of Google Ads’ use of cookies or other recognition technologies by visiting Google’s Ads Settings: http://www.google.com/settings/ads.
• You may also  be able to opt out of another service’s cookies or other recognition technologies by visiting http://www.networkadvertising.org/managing/opt_out.asp , and may be able to prevent or limit the use of some cookies and user recognition technologies via settings in your browser or elsewhere on your device.  

Who else might collect information about you as you use the Rely Service or the Rely Website?

Like most websites and services, the Rely Website and Rely Service utilise some third party technologies, such as help desk technologies like JIRA or Zendesk and user analysis technologies like Google Analytics.  Those third parties might also collect personal information.   

Access to and correction of your personal information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

Feedback/Complaints

If you have feedback/complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your feedback/complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact details

If you have any questions, comments, requests or concerns, please contact us at:

Privacy Officer, Rely Platform
Level 1, 400 High Street, Kew, 3101; or 
privacy@relyplatform.com

Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.

GDPR Addendum to Rely Platform’s Privacy Policy

Version: published May 2022. 

Basics

This is an addendum to Rely’s Privacy Policy, which is primarily designed to cover personal information concerning individuals in Australia.  This addendum applies where an individual in relation to whom Rely collects personal data is located in the European Union and that information is governed by the European Union’s General Data Protection Regulation (GDPR) (or, for so long as the United Kingdom maintains laws broadly equivalent to the GDPR, the individual is located in the United Kingdom and that information is governed by those equivalent laws). 

Who is the ‘controller’ and ‘processor’?

If personal data regarding you is uploaded to the Rely Service then Rely is the ‘processor’ of that data for the purpose of the GDPR and the Rely Subscriber is the ‘controller’.  The controller determines how that data shall be used and processed, and we ‘process it’ (for instance, storing it when the controller enters it and retrieving it when the controller requests it).   

Transparency regarding processing of personal data

Please see Rely’s Privacy Policy for details of the ways in which Rely collects and processes your personal data.