We respect your privacy
Effective August 1, 2023
1. Notices and Disclosures for Employees and Residents in Specific Jurisdictions
2. Information We Collect
In the course of our business, we may collect information from you that identifies, relates to, describes, references, or is reasonably capable of being linked, directly or indirectly, with an individual (“personal information”). This information may include the following, where required and as permitted by applicable laws and regulations:
- Personal identifiers, such as name, alias, signature, postal address, phone number, email address, social security number, device identifier, date of birth, or age;
- Financial information, including bank account numbers or other financial information;
- Internet and other network activity information including online identifiers such as an Internet Protocol (“IP”) address or device identifiers, browsing history, search history, user mobile device type, browsing platform, Wi-Fi connectivity and signal strength, and information about individual interactions with our Websites, electronic communications, or advertisements.
We may collect personal information from you directly (for example when you contact us or make an order) or from third parties, including:
- our related companies, with which we co-operate in managing our respective businesses;
- public sources such as material published on the internet or other publicly available resources;
- your organisation and representatives, which may be involved in facilitating your relationship with us;
- information service providers (e.g. data brokers) which we may use where lawful, (e.g. to build and manage contact lists); and
- the parties with whom we exchange information as described in this policy as well as any specific policies referenced in this global policy.
A. Information We Collect Directly From You
RWC collects information directly from you, including:
- Registration Information. When you register for Services, complete an application form, attend a training, trade show, or RWC-sponsored event or enter contests or competitions, we will ask you for your personal information, such as name, email, address, postal address, demographics information, and any preferences that you may have (e.g., which newsletters you would like to receive). We use this to provide access to certain content or Services, personalize them, and remember your preferences.
- Billing and Payment Information. When you place an order with us or access certain services, we will collect certain payment and identity verification information, including your name, email address, and credit card information. We use this to bill you for your use of the Services.
- Information you Post on the RWC Services. We collect personal information when you provide or post information to our Services, including your username, comments, likes, interests, status, pictures or videos you submit, and references to your online presence. We make this information available to others as you request.
- Correspondence you Send Us. When you contact us directly by calling us or providing feedback, comments or suggestions on programs and activities via postal mail or electronically, we may collect information you provide as part of your correspondence. We use this to provide Services and to learn about your interests and concerns. Sometimes, you may provide information about others (e.g., to refer a friend to certain Services). We use this to make Services available to the people you refer.
- Information You Provide Offline. You might also provide personal information to us in person and offline. For example, you may attend an RWC sponsored event, apply for position with us, or participate in one of our programs by mail or in person. You may also be recorded if you visit our offices (including by security surveillance, such as CCTV). We use this information to provide Services to you, protect our security, and learn about your preferences.
Please note that we are required or authorised to collect your personal information under certain laws including the Income Tax Assessment Act and the Corporations Act in Australia. We are also required to make limited shareholder details available to members of the public on request.
B. Information Collected Automatically Through Cookies and Other Online Tracking Technologies
As you navigate through and interact with our Websites we may use automatic data collection technologies to collect certain information about your equipment browsing actions, and patterns, including:
- Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Websites.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
- Referring websites from which you visit our Websites.
The information we collect automatically helps us to improve our Websites and to deliver a better and more personalized Service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences (allowing us to customize our Websites according to your individual interests), speed up your searches, or recognize you when you return to our Websites.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Websites. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Access to and Control Over Information below at https://www.rwc.com/privacy#control-your-information.
- Web Beacons. Pages of our Websites may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for examples, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity); and
- IP Addresses. An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the internet. When you visit our Websites, we may view the IP address of the device you use to connect to the internet. We use this information to determine the general physical location of the devices and understand from what geographic regions our website visitors come. We may also use this information to enhance our Websites.
A few important things you should know about cookies and our Websites are that:
- Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session.
- You are always free to decline our cookies if your browser permits, although doing so may interfere with your use of the Websites.
- You may encounter cookies from third parties on certain pages of our Websites that we do not control. (For example, if you view a web page or advertisement created by another user or third party, there may be a “cookie” placed by that web page or advertisement.)
- Our Websites may use analytical tools (e.g., Google Analytics, Facebook Pixel, etc.) from time to time to monitor traffic on our Website(s), referrals from social media advertisements, improve the user experience, or to conduct marketing and advertising activities.
We currently do not track customers or visitors over time and across third party websites to provide targeted advertising, and therefore, do not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your website browser (e.g., Safari) may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. You can find additional information on DNT choice mechanisms at https://optout.aboutads.info/ and https://youradchoices.com/control.
C. Privacy Protection of Children
Our Websites are not directed to children, and we do not knowingly collect personal information from children under 16. If you believe that a child under the age of 16 has given us personal information, please contact us at [email protected].
We may hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We take a range of precautions to protect your personal information. Depending on the circumstances, those precautions may include encryption, information access restrictions and secure premises and facilities.
Please be aware that third parties outside of our control may unlawfully intercept or access transmissions. While we work very hard to protect your privacy, we cannot promise that your private communications or personal information will always remain private.
3. How We Use and Share Information
A. How We Use Information
We collect personal information from you in order to provide our products and Services , to process or facilitate payments and refunds or collect payment for our Services, to verify your identity and personal information, to maintain and update our records, to communicate with you in your interactions with us, to respond to you regarding the reason you have contacted us, to provide registration for client events, to provide technical support to you as a customer, to inform you about product development and new features, to verify customer requests, to manage our relationship with you, to comply with applicable laws and regulations, to troubleshoot problems, customize, measure and improve our services, to train and manage our people and to protect our lawful interests.
We may also collect internet and other network activity information from website visitors, devices and platforms used to access our Websites, in order to provide information about services online, to monitor website traffic, to deliver marketing communications and advertising, and to identify the devices used to access digital content.
We may not be able to do these things without your personal information. For example, we may not be able to communicate with you or provide our services to you without your personal information.
B. How We Share Information
- Within the RWC Services and with the RWC family of brands. Where permitted by law, we may share information we collect about you within the RWC corporate family so that we can provide you with information about products and services that might interest you. Banks or Other Organizations In Connection with a Business Transfer. We may share your information in connection with a substantial corporate transaction, such as the sale of a Service, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- Regulators, Courts, Law Enforcement, and Other Governmental Authorities. We may disclose information about you to respond to subpoenas, court orders, legal processes and other law enforcement measures, and to comply with other legal obligations. There may be circumstances where the law requires us to disclose the information, or where disclosure is required to prevent a risk to health or safety, or for law enforcement purposes.
- Authorized Service Providers. We share your contact information with third-party vendors who help us with Services, including customer support, email and text message deployment, analytics, marketing, suppression list management and data processing. These service providers are under contractual restrictions to protect your information and are only allowed to use your contact information to help us provide our Services and not for any other purpose.
- Sponsors and Other Partners for Sweepstakes, Contests, or Giveaways. When you choose to enter a sweepstakes, contest, or other promotion, and in accordance with the terms and conditions of the promotions, your personal information may be disclosed to our sponsors and others who help design, administer and implement the promotion, including in connection with winner selection, prize fulfillment and aggregated data analysis. Your information also may be disclosed as required by law, such as on a winners list. Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.
In addition to authorized service providers that offer customer service support, we may also exchange your personal information with our affiliates or related corporate entities, your and our representatives and with our service providers that assist us with customer contact, legal, business consulting, banking, payment, archival, auditing, accounting, debt collection, delivery, information broking, research, investigation, insurance, data processing, data analysis, document management, website or technology services. In the event we were to merge or be acquired by another entity, or consider doing so, we may share your information with that entity or its advisers.
The third parties described above may be located in Australia, the United States, Canada, the United Kingdom, New Zealand, Spain, South Korea, and other countries across our various business divisions.
4. Your Access to and Control Over Information
You have certain options and rights related to the information we collect and how that information is used and shared. While we must continue to collect and store certain information required to allow you to take advantage of our products and services, to fulfill transactions with you, or to comply with legal, financial or other operational or regulatory requirements, your options for managing your information and privacy choices include:
- If you have a user or trading account, you can review and update your registration information through the applicable account settings.
- You can opt out of receiving emails or text message by following the instructions contained in such message or by contacting us directly. Please note that even if you unsubscribe to marketing messages, we may still need to send you communications relating to your use of our Services.
- You can deactivate web and mobile push notifications by changing the notification settings on your device.
To better understand your options for managing Personalized Advertising, see Information Collected Automatically Through Cookies and Other Online Tracking Technologies, above and here.