At Collaborative Solutions and Design Pty Ltd trading as Tech Studio (ACN 616 278 007) (“Tech Studio”, “we”, “us”) – we want you to know that we take children’s (“The User”) privacy seriously and safeguarding their game experience through our app (“The Game”, “Primary Colours AR”). We aim to comply with all regulations regarding children’s safety online and are committed to ensuring transparency with the information we collect.
When using our websites and apps we may collect some information. The data we collect is outlined below. If you have any questions regarding our websites or app, please send us an email via email@example.com we welcome your feedback or comments.
Information collected through our Games
Primary Colours AR App
Our app does not request, require or obtain any information from the user. The app does request access to the users’ camera in which no information is recorded or stored from. The app requests access to the users’ phone gallery and storage to store the games print out cards which are used with the app. The app does not use the gallery for other information nor is anything obtained from the users’ gallery.
Our app is developed using Unity which is a development engine. We want to ensure the games we develop are constantly performing as their intended to and your experience is fun. Unity collects analytical data that helps our development team understand our game and make improvements. No personal information is shared to third parties and it is de-identified
Information collected through our Websites:
Types of personal information we collect
Personal information is defined by the Australian Privacy Act 1988 (Cth) as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.’
The types of personal information we collect may include:
1) contact details such as your name, role or position, business name, residential and postal address, email address, URL, mobile number, landline number, fax number and Skype contact;
2) if you are an employee or prospective employee, information about your qualifications, skills, work experience and preferred working arrangements (e.g. part-time);
3) if you are a supplier or prospective supplier, information about your business skills, services, products and prices;
4) personal matters, such as allergies for catering purposes;
5) additional needs, such as wheelchair accessibility for meetings;
6) statistical information regarding views, access and use of the Websites or other services by our customers, including how visitors or customers found the Websites;
7) account access such as login details for websites, social media, analytics, website hosting and others; and
8) details for associated contacts, such as staff members names (e.g. receptionist/personal assistant) and alternative account contacts.
How we collect personal information
We collect this information from you when you make an enquiry with us (for example, by telephone or email), engage us to perform a service or do work on your behalf or submit a contact enquiry on our website.
We are committed to using lawful and fair means to collect personal information and collecting it from others only when it is unreasonable or impracticable to obtain certain information from you directly. We collect personal information about you from:
2) searches and enquiries; and
3) your use of our Websites
We will destroy or de-identify information where we form the opinion that the information has been provided to us unlawfully or unfairly.
Why we collect, hold, use and disclose personal information
We collect, hold, use and disclose your personal information as is reasonably necessary for us to perform our core functions and activities, including for the following purposes:
1) to contact and communicate with you;
2) to provide services and/or goods to you;
3)to maintain a database of customers, subscribers or similar;
to market to you and others, including remarketing (this may involve the use of a Facebook pixel or similar technology to allow us to display our advertising to you elsewhere on the internet, for example, on Google or Facebook);
for internal record keeping;
for statistical purposes; and
as required by law.
Links to other sites
How you can access and correct your personal information
1) Access: You can request details of personal information that we hold about you in certain circumstances set out in the Privacy Act 1988 (Cth) (the Act). We may refuse to provide you with information that we hold about you in certain circumstances set out in the Act. Otherwise, we will endeavour to provide access to the information if it’s reasonable and practicable to do so. In most cases we’ll do this free of charge, but if your request requires significant effort or expense on our part, we might ask you to compensate us for that.
2) Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details set out below. We rely in part on you advising us when your personal information changes. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date and to notify you of the correction, unless it is impracticable or unlawful to do so.
3) Deletion: If you want us to delete personal information we hold about you or to not collect information from you for a specific purpose, such as targeted advertising, please contact us using the details set out below. Please note that if we agree to delete your information, because of backups and records of deletions, it may be impossible to completely delete your information without retaining some residual information. We will functionally delete the information and we will not sell, transfer, or use personal information relating to you in any way moving forward.
4) We will respond to any request to access, correct or delete information within a reasonable time.
How we maintain the security of your information
We are committed to ensuring that the personal information we hold is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure. We undertake the following precautions to protect personal information we hold:
1) our Websites contain pages encrypted with SSL (Secure Sockets Layer) to ensure the safety of any data that is submitted through use of the Websites;
2) we limit access to personal information to a “need-to-know” basis and remove access when no longer necessary;
3) wherever possible, we protect devices we use to collect, hold, use and disclose personal information with industry-standard anti-virus software;
4) our email data is encrypted;
5) all hard copies of personal information are kept in secure storage with access by authorised personnel only;
6) all conversations involving the discussion of personal information take place in private, where conversations are unable to be overheard by unauthorised personnel; and
7) if we no longer need personal information, we take reasonable steps to delete or de-identify the information.
While we take commercially reasonable measures to maintain a secure business and Websites, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to you for any such occurrences.
If you make a request to store your data differently, on your preferred hosting provider for example we cannot ensure its protection or security.
How you can make a complaint about privacy breach
How you can unsubscribe or opt out
We like to keep our customers and website visitors up to date, so from time to time we’ll send you newsletters, invitations and updates. Not to worry: our emails will always come with an “Unsubscribe” button, so you can opt out at any time. To unsubscribe from our email database, or opt out of communications, use the “Unsubscribe” button in our communication or contact us using the details set out below.
You can also opt out of information collecting for advertising targeting by visiting www.aboutads.info/choices.
Accessing your personal information
You have a right to access your personal information, subject to exceptions allowed by law. If you’d like to do so, just let us know. You may be required to put your request in writing for security reasons. We reserve the right to charge a fee for searching for, and providing access to, your information on a per request basis.
EU and GDPR compliance
We are committed to looking after our customers in the EU and we make every effort to comply with the GDPR.
The words used in the balance of this policy have the meanings as defined in the GDPR.
The personal data we collect is:
1) processed lawfully, fairly and transparently;
2) collected for the specified, explicit and legitimate purposes;
3) adequate, relevant and limited to what is necessary for our purposes;
4) accurate, and where necessary, kept up to date (we will take every reasonable step to ensure that inaccurate personal data is erased or rectified without delay);
5) not stored than for longer than is necessary; and
6) processed in a manner that ensures appropriate security of the personal data.
We request your consent to the processing of your personal data for the purpose of better understanding your needs, tailoring our services, providing those services to you, creating our mailing list, marketing and taking payment. You give us consent to process your personal data. You can withdraw that consent at any time by sending an email to firstname.lastname@example.org. If you ask us to, we will stop using your personal data as soon as possible.
We are the controller of the data. The privacy contact is Anthony Lorkin.
The purposes for processing the personal data include: better understanding your needs, tailoring our services to you, providing those services, creating our mailing list, direct marketing and taking payment.
Legal basis for collection
Your data is received by us and by our key suppliers including our website construction and coding teams, our marketing platforms like Facebook and Instagram, Google Ads (AdWords), and subcontractors which we may engage such as a programmers, accountants, lawyers or business advisers.
Transfer of data to a third country
We may use cloud storage systems for our data, which rely on keeping multiple copies of our data in physical servers in several locations in Australia, the UK and the US.
Storage of your personal data
We store all order and customer information for 6 months after the date that the information ceases to meet the following criteria:
1) the information relates to a current client or prospective client;
2) the information relates to a former client who has a high likelihood of resuming services with us within the next 12 months (for example, computer repair services clients);
3) the information relates to a customer who has purchased a product which is within the warranty period of the service; or
4) we are required by Australian law to retain the information.
Please note that financial information gained during a course of dealing (such as details of payments made) will be kept indefinitely and stored with our business records.
This is necessary for our legitimate business purposes and to fulfil the purpose for which we collected the data, as set out above.
Access, Rectification and Erasure
You may request access to, rectification or erasure of your personal data, restriction of processing or object to processing for automated decision-making. You also have the right to data portability. We may request a reasonable fee to process a data portability request that is manifestly unfounded or excessive, based on the administrative costs of complying with the request. We will contact you promptly and inform you if we require payment of a fee. We will not be obliged to comply with the request until we have received the fee. Just contact us by phone or email if you have a request like this.
You have the right to lodge a complaint with a supervisory authority. We hope that you will not have complaints but if you do please raise them with us. You also have a right to lodge a complaint with the supervisory authority in the EU Member state where you live or work.
Legitimate business purposes
Where we have collected data from you where you have ‘opted in’ for direct marketing purposes pursuant to an offer, the provision of your personal data is a contractual requirement for the delivery of an opt in material. Similarly, if you are requesting a service it is a contractual requirement to provide the personal data necessary to perform those services. If you do not provide personal data, we will not be able to provide our services to you.
Automated decision making and profiling
Any automated decision making would only relate to decisions necessary for us to perform the services as agreed for you. Please note that we also utilise Facebook and Instagram advertising services and Google Ads which may also utilise automated decision making. Please refer to their privacy statement, available at https://www.facebook.com/privacy/explanation, for more information. Please note that we are not affiliated with or sponsored by Facebook or Instagram.
Other data sources
We may collect other personal data about you from other sources. All such data is obtained from government registers and is publicly available. The categories of personal data include names, addresses and contact details.
Changes to this policy
For any questions or notice, please contact us using these details:
CEO and Owner