(Last updated: 24 May 2017)
Cavalry Freelancing Pty Ltd (ACN 616 915 667) and its related bodies corporate (‘Cavalry Freelancing’, ‘us’ or ‘we’) recognise and value the importance of protecting the privacy of our customers.
Users of the Website will, generally speaking, fall into the following categories:
- freelancers who are seeking to be engaged by third parties to perform freelancing services (‘Freelancers’); and
- companies who are seeking to engage Freelancers to perform services for them (‘Clients’).
What is personal information?
In Australia, the collection, storage, use and disclosure of ‘personal information’ is regulated by the Privacy Act 1988 (Cth) (the ‘Act’). The Act defines ‘personal information’ as:
‘…information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.’
The definition of ‘personal information’ is therefore extremely broad, but good examples would include your full name and your address.
Why do we need to collect your personal information?
The Website is more complicated than a traditional market place, because we offer a talent management system that streamlines the way Clients and Freelancers find each other and work together. Our system is designed to handle freelance engagements from end-to-end, including allowing Clients to undertake searches for freelancing talent, to view and organise rosters, facilitate interaction between Freelancers and Clients and to allow for the booking and invoicing of freelancing services.
For the above reasons, we need to collect, store, use and disclose your personal information as part of the normal operation and functioning of our Website.
How will we collect your personal information?
We will always interact with you in an open and transparent manner, including by informing you:
- when we collect your personal information; and
- how we will manage your personal information.
When do we collect personal information?
Visitors to Cavalry Freelancing’s website choose to interact with Cavalry Freelancing in ways that require Cavalry Freelancing to gather personal information. The amount and type of information that Cavalry Freelancing gathers depends on the nature of the interaction. We collect personal information in a number of ways, including:
- when you visit and interact with our website and related software (including any mobile applications);
- when you sign up for a client account, submit form on our Website or sign up for our newsletter;
- when you engage in transactions with Cavalry Freelancing;
- when you submit your application to join as a Freelancer;
- through cookies and other technologies that allow us to give you a better experience on our website; and
- when you contact us independently of the Website, such as by email, phone or in person.
What personal information will we collect?
In order to operate the Website, we need to collect a sufficient amount of your personal information to allow us to undertake our functions, and to allow any transactions between us to take place efficiently and securely.
You may be able to browse certain pages of our Website anonymously. However, in order to engage in the freelance process using our Website, you will need to create an account with us and it is not practical for you to transact with us anonymously or using a pseudonym. When creating an account, we will request that you provide us with personal information. This may include, but is not necessarily limited to:
- your full name and prefix (e.g. Mr or Mrs), so that we can identify you;
- your photograph/s;
- your primary telephone number, so that we can contact you if there is a problem;
- your postal address (business and/or home);
- your email address, so that we can correspond with you electronically and administer your account (e.g. password resets);
- credit card and account details; and
- details of the company you represent (eg company name, address and contact details) and the title of your position at that company.
If your personal details change, it is your responsibility to update your Cavalry Freelancing account with those changes, so that we can keep our records complete, accurate and up to date.
We will never collect ‘sensitive’ information about you and you must not disclose sensitive information to us. Sensitive information includes certain kinds of information about you, such as your political opinions or your racial or ethnic origin.
What will we do with your personal information?
We will use your personal information for a number of purposes associated with the operation of the Website or as otherwise required or authorised by law.
The primary purposes for which we will use your personal information are to allow us to:
- provide you with functional access to the Website, including the ability to participate in various stages of the freelance search process with a view to engaging a Freelancer if you are a Client or propose to provide freelancing services to a Client if you are a Freelancer;
- to put Freelancers in communication with Clients (and vice versa);
- identify you and authenticate your identity;
- contact you in respect of the Website, and the freelance process;
- ensure that Cavalry Freelancing receives payment of any fees due to it;
- facilitate payment by Clients to Freelancers;
- send you service or promotional communications, including surveys and information about security updates;
- create or distribute marketing material that is relevant to you;
- permit content on the Website (such as postings or third party advertisements) to be targeted, on an aggregate basis, to the users for whom it is most likely to be relevant;
- undertake quality assurance and training;
- conduct research;
- develop new Website features;
- customise the content on the Website and any advertising on the Website;
- develop relationships with affiliate service providers;
- for statistical reporting purposes, on an anonymised and aggregated basis;
- act in a way that is required or authorised by or under law
- undertake any other uses identified at the time of collection of your personal information.
If you are a Freelancer, certain of your personal information included in your professional profile to may be visible to Clients, depending on the extent to which you have opted in to share your personal information via your account settings.
Cavalry Freelancing may also offer a profile feature that allows portions of a Freelancer’s profile to be published to the Internet. If you are a Freelancer, certain portions of your public profile may be indexed and displayed through public search engines such as Google when someone searches for your name, and allow them to click through to your Cavalry Freelancing profile. You may opt out of this feature entirely in your account settings. However, you should be aware that third-party search engines may not automatically update their caches, which may contain old public profile information.
You may be able to browse certain sections of the Website without providing us with any personal information. However, if you do not provide us with the requested personal information and agree to us using it for the above primary purposes, you will regrettably not be allowed full access to our website and will not be able to participate in the freelance process.
The secondary purpose for which we will use your personal information is to allow us to send you direct marketing in relation to our respective goods and services or the respective goods and services of trusted third parties. If you do not agree to us using your personal information for this secondary purpose, you should just notify us of this at the time you create a user account. You can also change your mind at a later date by notifying us.
Where relevant you consent to Cavalry Freelancing posting and using any photographs, content and/or personal information you might upload on our website or have otherwise provided consent to publish on our website, blog, in our marketing collateral or social media channels, which we may use in order to provide our services, the marketing of our services or for the purpose of our functions and/or activities.
Who will we disclose your personal information to?
We may disclose (and you are deemed to consent to us disclosing) your personal information:
- for the purposes for which it is collected and for any related purposes, including:
- to any person where necessary or desirable in connection with the provision of the Website, and the services to you;
- to any person where necessary or desirable in connection with the management of our relationship with you; and
- to our external advisors, service providers, subcontractors and suppliers, so that they can provide professional, financial, technical, administrative or other advice and services in connection with the operation of our business;
- if you are a Freelancer, to Clients or, if you are a Client, to Freelancers;
- to Cavalry Freelancing’s affiliated entities for the purpose of such affiliated entities contacting you about their products and services or the products and services of trusted third parties;
- to any person who acquires or expresses an interest in acquiring all or any part of Cavalry Freelancing’s business;
- to facilitate payments in relation to the freelancing process;
- to any person as required or authorised by or under law, and to any other person to which you subsequently consent from time to time.
When you use the Website to participate in the freelance search process or otherwise communicate in a public forum on the Website, your user ID and all or some of the material you post may be visible to other users on the Website and may be publicly available to other internet users. We therefore suggest that you use discretion and caution when posting information to the Website. We do not in any way control, and do not accept any responsibility or liability whatsoever for, the disclosure or use of personal information which is voluntarily posted by you in any publicly accessible area of the Website.
We will never sell your personal information.
Direct marketing is where we contact you directly to offer you goods and services, using the personal information you have supplied to us.
By registering with Cavalry Freelancing, you agree to receive direct marketing materials from us. You can opt-out of receiving direct marketing materials or ‘unsubscribe’ at any time in a number of ways. Firstly, you can log on to your user account at the Website and change your preferences and settings. Secondly, you can in many cases unsubscribe via the marketing materials themselves. For example, any direct marketing emails we send to you will contain a functional ‘unsubscribe’ feature which will always be valid for at least 30 days from the date of the communication. Finally, you can always change your marketing preferences by contacting us using the contact details provided below.
We will never use or disclose your personal information for the purpose of sending you spam, that is, unsolicited commercial messages which offer or advertise goods or services.
General tips on security
We urge you to take your own privacy seriously and to take steps to protect it. You must never share your account details or password with anyone, as they are both unique to you.
You must always remember to close your browser window when you have finished communicating with us, especially when you share the computer or device with others.
How will we hold your personal information?
We are committed to storing your personal information as securely as possible.
We will take all reasonable to steps to protect your personal information from misuse, loss, interference and unauthorised access, modification or disclosure.
We regularly review and monitor the adequacy of our security measures, and would welcome any feedback you may have.
Most browsers are automatically set up to accept cookies. The storage of cookies can be deactivated or the browser can be configured in such a way that it sends a notification when cookies are sent. You are always free to decline our cookies, however doing so may significantly interfere with your use of the Website.
Access to your personal information
You are entitled to access the personal information we hold about you, on request, subject to a limited number of exceptions. If for some reason we are unable to provide you with access to your personal information, we will provide you with our reasons in writing as well as your further options for complaint.
You may make an access request via the contact details below and we will respond to your request within a reasonable period. Ordinarily, we will require you to attend our office to access your personal information in secure circumstances, however we will give reasonable consideration to any other access procedure you may suggest in writing where it is practicable to do so (in whole or in part). We will not ordinarily charge you for gaining access to your personal information.
What if your personal information is wrong?
We will take reasonable steps to ensure that the personal information we hold, use and disclose is accurate, up to date and complete. However, we will not take any administrative steps to verify the accuracy or completeness of the information you provide to us at the time of collection (for example, if you make a mistake when typing in your details).
If you suspect or believe that the personal information we have is not accurate, complete or up to date, please either (a) log in to the Website and update your personal information as appropriate, or (b) contact us at the details below and we will respond to your request within a reasonable period. When responding, we will take reasonable steps to correct that information and to ensure that it remains accurate, complete and up to date in the future. If for some reason we are unable to correct your personal information, we will provide you with our reasons in writing and your further options for complaint. We will not ordinarily charge you for requesting the correction of your personal information.
How long will we keep your personal information?
We will also take such steps as are reasonable to destroy or anonymise/de-identity any personal information we hold about you where we no longer need that personal information for the purposes for which it was disclosed. Particularly where you have used our services, we will need to keep your personal information for a relatively significant period of time.
If you believe that there has been a breach of the Australian Privacy Principles, you may lodge a complaint with us via the contact details below. We will review your complaint and gather any relevant paperwork or documentation before responding which will ordinarily be within 30 days of receipt of your complaint. When we respond, we will give you written reasons for our decision. If you remain dissatisfied with our response or the reasons given, you may lodge a formal complaint via the Office of the Australian Information Commissioner at www.oaic.gov.au.
How do you contact us?
- Attention: Privacy Officer,
- Cavalry Freelancing Pty Ltd
- 37-38 East Esplanade, Manly, 2095, Australia
- Telephone: 1300 162 140
- E-mail: firstname.lastname@example.org
Changes to this Policy