Extra Labs Pty Ltd (ACN 648 945 948) trading as Cost Center and its Related Bodies Corporate (as defined by the provisions of the Corporations Act 2001 (Cth)) (Cost Center, we, us and our) respects your privacy and is committed to protecting it. We comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep secure and disclose Personal Information or Personal Data.
The Privacy Act defines “Personal Information” to mean any information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can be reasonably ascertained, from the information or an opinion.
If you are a resident of the European Union or the United Kingdom, we are required to comply with the GDPR (as defined in Section 12) in relation to your Personal Data (as defined in Section 12).
If you have any concerns or complaints about the manner in which your Personal Information or Personal Data has been collected, used or disclosed by us, please contact us via the information set out in Section 11 and will resolve your concern or answer your question.We recommend that you keep this information for future reference.
1. The kinds of Personal Information or Personal Data collected, used and disclosed by Cost Center
We will only use or disclose your Personal Information or Personal Data for the primary purposes for which it was collected, or as consented to by you. At or around the time we collect Personal Information or Personal Data from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information. We set out some common collection, use and disclosure instances in the table below.
Type of Information
When you submit a general enquiry with us, we will collect the following information as applicable to your enquiry:
- Contact information: Such as your name, Company name, address, billing address (if different to address), email address, phone numbers, username and password.
- Transaction Sales: Such as:
- Delivery information.
- Billing and account details.
- Payment card details.
- Customer Service: Information collected in connection by our customer services department, including any additional Personal Information or Personal Data you disclose to us as part of your enquiry.
The types of uses we will make of Personal Information or Personal Data collected for this type of purpose include:
- Identity verification: if required, the verification of your identity.
- Services: the provision of our services to you including:
- Using your Personal Information or Personal Data in order for you to use the products and services offered.
- Payment processing, including charging, credit card authorisation, verification and debt collection.
- Checks for financial standing and credit-worthiness (as detailed in our Credit Reporting Policy).
- To provide customer service functions, including handling your enquiries and complaints.
- Marketing: using your Personal Information or Personal Data for the purposes set out in “Marketing Services” section below, if applicable to your enquiry.
- General administrative and security use:
- To protect Cost Center’s websites from security threats, fraud or other criminal activities.
- The use for the administration and management of Cost Center.
- The maintenance and development of our products and services, business systems and infrastructure.
- In connection with the sale of any part of Cost Center’s business or a company owned by a Cost Center entity.
- To provide customer services to clients and for quality assurance purposes.
The types of disclosures we will make of Personal Information or Personal Data collected from general enquiries include, without limitation, to:
- Third parties connected with the sales process including ecommerce, payment gateway providers and financial institutions (where applicable to your enquiry).
- Service providers (including IT service providers and consultants) who assist Cost Center in providing our products and services.
- Related bodies corporate of Cost Center (including related entities).
- Third parties in connection with the sale of any part of Cost Center’s business or a company owned by a Cost Center’s entity.
- As required or authorised by law.
When we collect your Personal Information or Personal Data in the provision of our marketing services, we will collect the following types of information, depending on your relationship with us:
- Cost Center customers: Your name, email address, current postal and residential addresses, billing address (if different to address), phone numbers, country of residence (and, if applicable, age), Bank account, credit or debit card details.
- Marketing targets: information relating to your engagement with our customers’ games and marketing campaigns (e.g. via ad networks on Facebook, AppsFlyer and Firebase), which may include your Apple IDFA, iOS device IDFV, your country, your Firebase user ID, details as to your use of certain apps e.g. your in-app spending, ad display and ad views data, the total revenue you generate for certain gaming apps, etc.
- Purchases of Cost Center’s products and services: Payment processing, including charging, refunds (if applicable), credit card authorisation, verification and debt collection.For full details relating to uses of Personal Information or Personal Data in relation to the use of credit information, please refer to our Credit Reporting Policy.
- General marketing and consumer analytics: using your Personal Information or Personal Data:
- To aggregate with other information and to then use it for marketing and consumer analytics for our customers.
- Where you are a Cost Center customer, we use your Personal Information or Personal Data to offer you updates on products, events or information that may be of interest to you, and for other marketing and promotional activities by us (including by email) such as our email alerts, product awareness information and newsletters.
- For the Uses detailed above in “General enquiries”.
In summary, where you are a Cost Center customer, we may disclose this type of Personal Information or Personal Data to:
- Our contractors, agents and third party providers who undertake billing and credit services on our behalf.
- Third party providers who assist us in providing our products and services to you, such as our help desk team and data storage provider.
- Third parties connected with the marketing process who assist us in providing our products and services to you.
- Third parties, such as external debt recovery agents, court or other entities to which we are required by law to disclose Personal Information or Personal Data.
For full details relating to disclosures of Personal Information or Personal Data in relation to any credit information, please refer to our Credit Reporting Policy. Where we collect your Personal Information or Personal Data as marketing targets, we will disclose this information to our customers and their third party marketing vendors, as well as third party ad networks such as Facebook, AppsFlyer and Firebase in respect of those marketing activities.We may also disclose your Personal Information or Personal Data to the parties listed in the Disclosures column for “General enquiries”.
When we engage you as a contractor or employee, we may collect the following information about you:
- Contact information: Such name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details.
- Employee record information
- Identifying information: Such as your photo, passport and residency details, date of birth.
- CV, resume or application related information: Such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications.
- Tax, superannuation and payroll information: Such as your Tax File Number and ATO Declaration, Superannuation details and financial institution details.
- Background check information: Information obtained from you or third parties to perform background checks.
- Medical or health information which you voluntarily provide to us as part of pre-employment medicals, random drug and alcohol testing or such other information which may be related to an incident which has occurred during the course of your employment.
- Performance related information: Pre-employment testing and other information collected by Cost Center’s systems in the course of the employee or contractor’s engagement with Cost Center.
- Information collected from referees
- Security information: Such as CCTV footage and photographs taken on our premises.
- Background checks:
Utilising the information collected for the purpose of assessing candidate suitability for role, including by obtaining:
- Verification of your identity and age.
- Criminal history background checks including publicly available information including Facebook, Twitter, Instagram, YouTube.
- Confirmation of eligibility to work in Australia.
- Confirmation of education and qualifications.
- Confirmation of previous employment.Consideration regarding medical leave.
- Administration and performance monitoring use: Utilising the information collected for the purpose of:
- Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
- Use of such information whether or not the employment or contractor relationship is prospective, current or past.
- Use of such information to monitor systems, performance and time usage and internet usage.
- The use of your Personal Information or Personal Data collected in the administration and management of Cost Center.
- In connection with the sale of any part of Cost Center’s business or a company owned by a Cost Center entity.
We may disclose your Personal Information or Personal Data to:
- Relevant superannuation company.
- Government agencies, including but not limited to The Australian Taxation Office, Centrelink and Child Support Agency.
- Relevant Worker’s Compensation organisation (e.g. WorkCover etc).
- Third party referees provided by you in connection with an application made to Cost Center.
- Service providers (including IT service providers and payroll providers), if any.
- Recruitment agents used in connection with your application with us.
- Third parties in connection with the sale of any part of Cost Center’s business or a company owned by a Cost Center entity.
- Third party parties in connection with obtaining any background checks, pre-employment screening.
- Financial institutions for payroll purposes.As required or authorised by law.
2. How Cost Center collects and holds Personal Information or Personal Data
2.1 Collection from general enquiries, Cost Center customers and in connection with human resources
Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.
2.2 Collection of Personal Information or Personal Data as a marketing target
If your Personal Information or Personal Data is included in the marketing data of our customers, we will collect that Personal Information or Personal Data about you from other sources and third parties. Some examples of these alternative collection events are:
a) when we collect Personal Information or Personal Data about you from our customers; or
b) when we collect Personal Information or Personal Data about you from ad network platforms such as Facebook.
Generally, your Personal Information or Personal Data is used by us in aggregate form to provide our customers with market insights. We try to limit use of Personal Information or Personal Data in a manner that has any potential to identify an individual.
Notification of collection
If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause 2.3(a) to 2.3(d) below. Generally speaking, we will not tell you when we collect Personal Information or Personal Data about you in the following circumstances:
a) where we collect your Personal Information or Personal Data on behalf of one of our customers (and we are therefore unlikely to be able to contact you directly);
c) where information is collected from any personal referee you have listed on any application form (including any employment application) with Cost Center;
c) where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or
d) as otherwise required or authorised by law.
2.4 Unsolicited Personal Information or Personal Data
In the event we collect Personal Information or Personal Data from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Cost Center (in its absolute discretion) that the Personal Information or Personal Data is not required, we will destroy the information or ensure that the information is de-identified.
In the event that the unsolicited Personal Information or Personal Data collected is in relation to potential future employment with Cost Center, such as your CV, resume or candidacy related information, and it is determined by Cost Center (in its absolute discretion) that it may consider you for potential future employment, Cost Center may keep the Personal Information or Personal Data on its human resource records.
2.5 How we hold your Personal Information or Personal Data
Once we collect your Personal Information or Personal Data, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act. We provide some more general information on our security measures in Section 9 (Data security and quality).
2.6 Cookies and IP addresses
If you use our website, we may utilise "cookies" which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.
We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer.
3. Uses and discloses of Personal Information or Personal Data
3.1 Use and disclose details
We provide a detailed list at Section 1 of some common uses and disclosures we make regarding the Personal Information and Personal Data we collect.
3.2 Other uses and disclosures
We may also use or disclose your Personal Information or Personal Data and in doing so we are not required to seek your additional consent:
a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your Personal Information or Personal Data to be used or disclosed for such a purpose;
b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
d) if it is required or authorised by law.
3.3 Use and disclosure procedures
3.4 Communications opt-out
4. Sensitive information
4.1 Sensitive information generally
Sensitive information is a subset of Personal Information or Personal Data. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
4.2 Information Provided by Third-Party Services
4.3 Collection and use of sensitive information
In general, we do not generally collect sensitive information, but if you are employed by us we may collect sensitive information from you in order to manage your employment by us (e.g. if you disclose to us you have a medical condition that affects your ability to perform certain duties). However, we will not collect sensitive information from you without your consent.
The sensitive information we collect about you will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the “Human resources” section of the table at Section 1 above.
We do not use sensitive information to send you Direct Marketing Communications (as set out in Section 5 below) without your express consent.
We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.
5. Direct Marketing
5.1 Express informed consent
You give your express and informed consent to us using your Personal Information or Personal Data set out in:
a) the “General enquiries” section of the table at Section 1 of this document above; and
b) the “Marketing services” section of the table at Section 1 of this document above (where you, or your employer, have engaged us for our products or services);
to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).
5.2 Inferred consent and reasonable expectations of direct marketing
Without limitation to paragraph 5.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your Personal Information or Personal Data the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 6, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out at the top of this document.
6. Credit Information and our Credit Reporting Policy
6.1 Credit information generally
The Privacy Act 1988 (Cth) contains provisions regarding the use and disclosure of credit information, which applies in relation to the provision of both consumer credit and commercial credit.
6.2 Credit information and Cost Center
As we provide terms of payment of accounts which are greater than 7 days, we are considered a credit provider under the Privacy Act in relation to any credit we may provide you (in relation to the payment of your account with us).
We use credit related information for the purposes set out in the “Credit information” section of the table at Section 1 above and our Credit Reporting Policy which includes but is not limited to using the information for our own internal assessment of your credit worthiness.
6.3 Storage and access
We will store any credit information you provide us, or which we obtain about you, with any other Personal Information or Personal Data we may hold about you.You may request to access or correct your credit information in accordance with the provisions of Section 10 and the provisions of our Credit Reporting Policy.
Please see Section 11 and the provisions of our Credit Reporting Policy if you wish to make a complaint in relation to our handling of your credit information.
6.5 Our Credit Reporting Policy
Please see our Credit Reporting Policy for further information as to the manner in which we collect, use, store and disclosure credit information.
7. Anonymity and pseudo-anonymity
Due to the nature of the services we provided, it is only practicable or reasonable for Cost Center to transact and correspond with you on a named basis. Your Personal Information or Personal Data may be required in order to provide you with our goods and services, or to resolve any issue you may have.
8. Cross Border Disclosure
8.1 Cross border disclosures
Any Personal Information or Personal Data collected and held by Cost Center may be disclosed to, and held at, a destination outside Australia, including but not limited to Vietnam and Singapore, where some of our client base resides, and the United States where we utilise third party service providers to assist Cost Center with providing our products and services. Personal Information and Personal Data may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed above.
In addition we may utilise overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist Cost Center with providing our products and services to you.
8.2 Provision of informed consent
8.3 If you do not consent
If you do not agree to the disclosure of your Personal Information or Personal Data outside Australia by Cost Center, you should (after being informed of the cross border disclosure) tell Cost Center that you do not consent. To do this, either elect not to submit the Personal Information or Personal Data to Cost Center after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.
9. Data security and quality
9.1 Cost Center’s security generally
We have taken steps to help secure and protect your Personal Information or Personal Data from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or Personal Information or Personal Data, especially where human error is involved or malicious activity by a third party.
Notwithstanding the above, we will take reasonable steps to:
a) make sure that the Personal Information or Personal Data we collect, use or disclose is accurate, complete and up to date;
b) protect your Personal Information or Personal Data from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
c) destroy or permanently de-identify Personal Information or Personal Data if it is no longer needed for its purpose of collection.
The accuracy of Personal Information or Personal Data depends largely on the information provided to us, so we recommend that you:
a) let us know if are aware if any errors in your Personal Information or Personal Data; and
b) keep us up-to-date with changes to your Personal Information or Personal Data (such as your name or address). We provide information about how you can access and correct your information in Section 10.
10. Access to and correction of your Personal Information or Personal Data
You are entitled to have access to any Personal Information or Personal Data relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of Personal Information or Personal Data we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.
Where we have collected your Personal Data or Personal Information as a marketing target on behalf of our customers, access to or correction of that information should be sought from the original source.
11. Resolving Privacy Complaints
11.1 Complaints generally
We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
11.2 Contacting Cost Center regarding complaints
If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your Personal Information or Personal Data, please contact us:
Address: 45 Moorbell st, Tarragindi, QLD 4121
11.3 Steps we take to resolve a complaint
In order to resolve a complaint, we:
a) will liaise with you to identify and define the nature and cause of the complaint;
b) may request that you provide the details of the complaint in writing;
c) will keep you informed of the likely time within which we will respond to your complaint; and
d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.
11.4 Register of complaints
We will keep a record of the complaint and any action taken in a Register of Complaints.
In providing our products and services, or collecting and using your Personal Data, we are required to comply with the GDPR where you are a European Union resident or a United Kingdom resident. The following defined terms have the associated meanings:
a) “Data Subject” has the meaning attributed to that term in the GDPR.
b) “GDPR”, when used in the context of European Union residents, means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC and when used in the context of United Kingdom residents, means the UK General Data Protection Regulation as implemented by the Data Protection Act 2018; and
c) “Personal Data” means the Personal Data (having the meaning attributed to that term in the GDPR) of the Data Subjects whose data is processed for the purposes of the provision of our retail services.
12.2 GDPR Obligations
If you are a resident of the European Union or the United Kingdom for the purposes of the GDPR, then in addition to what is set out in Sections 1 - 11 above, the following applies to you.
If you are a Cost Center customer then under the GDPR, Cost Center is considered a “data controller” in the provision of its services to you, and as such determines the purposes and means for processing of Personal Data.
If you are a “marketing target” as discussed above in Section 2, then Cost Center is considered a “data processor” in respect of its relationship with you, in that it processes your Personal Data on behalf, and at the direction, of our customers as a service to those customers.
In addition to your rights of access and correction as set out above, as a Data Subject you may:
a) (access) request access to your Personal Data held by Cost Center;
b) (rectification) request to update or rectify any of the Personal Data that we hold about you by contacting us at the details specified above and request Personal Data updates;
c) (erasure) withdraw your consent to Cost Center’s use of your Personal Data as described in this policy by deletion or erasure of your Personal Data that we hold where that data is no longer required for the purpose for which it was collected;
d) (restriction on processing) obtain from Cost Center a restriction on processing of your Personal Data where:
(1) accuracy of the Personal Data is contested;
(2) the processing by the processor is unlawful (and you oppose erasure but request restriction of use);
(3) Cost Center no longer needs your Personal Data; or
(4) you have objected to processing pursuant to your right to object under Article 21(1) of the GDPR;
e) (data portability) request that Cost Center:
(1) provides you with a copy of the Personal Data that Cost Center holds about you in a portable and machine readable form; or
(2) share your Personal Data with a nominated third party.
12.3 Exercising Data Subject rights
If you wish to exercise any of your Data Subject rights, then please send your request in writing to the details above in section 11.3.We will process your request promptly and in any event, within one month of receipt of receiving it.
If you have any concerns in relation to Cost Center collection or processing of your Personal Data, then you also have a right to complain to a supervisory authority (within the meaning of the GDPR).
13. Consent, modifications and updates
13.1 Interaction of this Policy with contracts
a) certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Cost Center, but do create contractual obligations on the other party to the contract; and
b) the consents provided in this policy become contractual terms provided by the other party to the contract.
13.3 Modifications and updates