If there are any inconsistencies between the localized version and the English source, the English source takes precedence.

1. Protecting your privacy

The Deswik group of companies (collectively, We, Us, Our) is committed to protecting your privacy. This policy outlines how we collect, hold, use and disclose your personal information and your rights in relation to the personal information we hold about you.

By providing us with your personal information, you consent to the collection, storage, use and transfer of your personal information as provided for in this Privacy Policy and to enable us to provide our products or services. By continuing to use our website or deal with us, you agree to be bound by this Privacy Policy and any changes made to the policy from time to time.

In relation to personal information for citizens of the Russian Federation, the relevant Deswik group company is Limited Liability Company «DESWIK RUS» (Primary State Registration Number 5147746237964).

In this document ‘Affiliates‘ means other companies within the Deswik group, and our and their officers, employees and other personnel, agents, contractors, partners, principals, licensors, service providers and members.

2. Personal information

Personal Information means 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 who is reasonably identifiable.

3. Why do we collect your personal information?

We collect and hold a range of personal information necessary for conducting our business, providing our services and allowing you to access our products. We may collect personal information to allow us to:

a. provide our products and services as described on our website;

b. establish your identity and assess your application for a licence to use our products;

c. enable you to download products from our website.

d. provide maintenance and support services to you;

e. process your inquiries and improve our products and services;

f. maintain and update our business infrastructure and systems;

g. design, price and develop existing and new products and services;

h. promote and advertise our other products and services to you;

i. advise you of additional products or services which may be of interest to you;

j. provide your contact details to any Affiliates who may from time to time agree to offer or provide you with the products and services described on our website; and

k. improve your (and other users’) experience with Deswik software, such as customizing workflows, toolbars, images and icons; creating sector or role-specific tools and functionalities; and implementing a more streamlined user experience.

If we do not collect this personal information we may not be able to provide you with the products, services, offers or assistance you have requested.

At any time, if you no longer want to receive any direct marketing material from us, you can unsubscribe from those services on the newsletter or through our website. Alternatively, you can contact our Privacy Officer at the details below.

4. What personal information do we collect?

We may collect the following types of information from you:

a. your name, job title and contact information such as email address, facsimile number, telephone numbers, residential or business address;

b. payment information such as credit card or banking details;

c. information provided in communications between you and us;

d. information collected to establish your identity, assess your application and open a user account, including gender, date of birth, your employer and your areas of specialisation or interest;

e. usage information and analytical data about how you use our software products.

We collect the following types of information from you when you use our website or access our materials otherwise available online:

a. information you provide when logging onto our website;

b. information about your usage (for example, by way of cookies) including when you use our website, the services used, other websites you access or connect with from our website, content uploaded and downloaded;

c. your Internet Protocol (IP) address and your browser type and language; and

d. whether direct marketing emails or electronic newsletters that we send you are suitable for your interests and are received by you.

We may also collect personal information which you have allowed to be disseminated publicly, for example from public registers, third party websites or social media.

5. How do we collect the personal information?

In most cases, we will collect personal information directly from you. We collect personal information from you when you deal with us in person, via telephone, email or other electronic communication channels. When you use our website or software applications our server automatically records information your browser sends when it connects to a website. Some of this information we collect using Cookies. (Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. For further information, visit allaboutcookies.org.)

We may use an email management system that tracks direct marketing emails or electronic newsletters that we send to you, such as whether you received the email, opened it and whether you clicked through any links provided in the email.

We may also collect personal information about you from third parties such as the organization of which you are an employee or contractor, public registers, or service providers with which you have dealings, subject to any applicable legal or regulatory restrictions.

6. When and how do we process your personal information?

We process your personal information in strict accordance with the law. Personal information may be processed in the following cases:

a. You have given explicit consent to process your personal information for one or more specific purposes.

b. Processing is necessary for the performance of a contract concluded with you, or which is in your interests, or which is with the legal entity whose interests you represent.

c. Processing is necessary to fulfill legal obligations imposed on us.

To carry out the actions described above, we may take one more of the following actions/operations to process personal information: collection, recording, systematization, structuring, accumulation, storage, refinement (such as updating, amending, or additional processing), search, selection, extraction, use, examination, disclosure by transfer (such as distribution, provision, mail-out, or other means of providing access), grouping or combining, selecting, depersonalizing, blocking, deleting, erasing or destroying.

In addition, we may carry out any other actions stipulated by applicable laws or regulations, using automation tools (including information and telecommunication networks), or without using such means, as appropriate.

7. How do we hold and secure your personal information?

We take reasonable steps to protect your personal information, to prevent unauthorized access or modification and to destroy or de-identify it when it is no longer required. We hold personal information in electronic form and hardcopy files.

We store electronic records on our own system and through third party data storage providers. Personal information on our system is password protected and our system has firewalls and antivirus software. We store hardcopy materials in files, cupboards and offices within our premises to which access is controlled and protected by alarms.

Our third-party storage providers are required to protect personal information against unauthorized access or misuse with appropriate technological measures and organizational procedures. We may send information overseas to third party storage providers (including to our Ireland, Australia, Canada, or the United States) but we ensure appropriate data handling and security arrangements are in place.

We will transfer your personal information to our third-party storage providers only where legally permitted.

The open nature of the internet is such that information exchanged via the internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including your personal details, email address and other information, it is sent and received by us at your own risk. You should always ensure you log out and close your browser when you have finished accessing our system online.

We keep your personal information for no longer than the purpose of processing the information requires, if the storage period for the information is not established by (i) law, or (ii) an agreement concluded with you; or it is otherwise in your interest for us to keep it. After the expiration of the storage period, personal information is subject to destruction or depersonalization.

8. Who will see or have access to your personal information?

Unless we are required to provide your personal information to others by law, by court order or to investigate suspected fraud or other unlawful activity, your information will only be seen or used by persons working in or for us and any Affiliates who offer the services, promotions and products described on our website.

We will only share personal information with Affiliates when we are legally permitted to do so, and where it is necessary for administrative purposes or to provide you with our products or services.

When we share information with Affiliates, we ensure appropriate contractual arrangements and security mechanisms are in place to protect the information and to comply with our data protection and confidentiality obligations, and security standards.

Persons accessing your personal information may include our own and our contract personnel (for example, customer service staff, sales agents, marketing people, insurers, and advisers), our subsidiaries, advertisers, and our Affiliates (who offer the services, promotions and products described on our website). Some of these people may be located in countries outside your home country (for example, outside Russia for Russian citizens).

Cross-border transfers of personal information to countries that, in the opinion of the relevant government body or regulator, does not provide an adequate level of protection for your personal information, will occur only (i) with your written consent, (ii) to execute a contract to which you are a party, or (iii) in other cases permitted by the applicable laws on personal data.

We have taken steps to ensure that all personal information is provided with adequate protection and that all transfers of personal information are done lawfully.

We endeavor to keep our information systems and files secured from unauthorized access and our staff and contracted agents and service providers have been informed of the importance we place on protecting your privacy and their role in helping us to do so.

9. Your rights

We respect your rights and aim to make sure that you are aware of your rights. As a person whose personal information is being processed by us, you have the following rights:

a. To request confirmation of processing activities involving your personal information, such as obtaining details of the personal information being processed, the purposes for which it is being processed, the categories of information being processed, the actions to be taken with the information, the names of third parties who will have access to your personal information, protection to be provided when information is transferred to third parties, the period of processing, and the sources of the personal information.

b. To revoke your consent to processing, in cases when consent was required.

c. To require changes to your personal information if there are inaccuracies in the personal information we hold or which we are processing.

d. To require limitations on the processing of all, or a part of, your personal information if one of the following conditions is met:

 – you challenge the accuracy of the information;

 – unlawful processing has been revealed, but you choose not to request deletion of the personal information and instead require limiting its use;

 – we no longer need the personal information for processing, but you require us to retain your personal information for the purposes of substantiation, contract performance or as part of legal proceedings;

 – you have other legal grounds to oppose processing.

e. To require deletion of your personal information from our systems or other existing tangible media, if one of the following conditions is met:

 – the personal information is no longer required for the purposes for which it has been obtained;

 – you withhold or revoke consent to the basis for which the processing has been or is proposed to be carried out, if there are no other legal grounds for processing;

 – you oppose processing (if there are no prevailing legal grounds for processing to occur);

 – the personal information is being processed unlawfully;

 – the personal information must be deleted to ensure compliance with a legal obligation in accordance with legislative requirements;

 – at the moment of personal information collection you are a minor, and the personal information has not been obtained with the consent of your legal representative.

f. To require a list of your personal information provided to us for processing be supplied to a third party (where we can technically do so) in a structured, uniform, and machine-readable format. In this case we are not responsible for any further actions taken by the third party related to the personal information.

g. To oppose processing of all, or a part of, your personal information for the purposes indicated when the information was provided, except for cases where the legal grounds for processing prevail over your interests, rights, and freedoms; or where processing is necessary for substantiation, contract execution, or defence in legal proceedings.

h. To require we limit processing of your information for our marketing activities.

i. To file a claim with a supervisory authority in case we have somehow violated your rights in relation to personal information processing.

Please contact our Privacy Officer using the details below if you would like to request access to your information or to exercise one of the other rights set out above.

We will acknowledge receipt of your complaint and endeavor to investigate and respond to your complaint within 30 days.

10. What if you have a complaint?

If you believe we have failed to comply with this Policy, you may contact our Privacy Officer at the details below.

We will acknowledge receipt of your complaint and endeavor to investigate and respond to your complaint within 30 days.

You may have other rights available to you at law.

11. How can you contact our Privacy Officer?

If you would like more information about how we manage your Personal information please contact our Privacy Officer by:

Email:  privacy.officer@deswik.com

Telephone: +61 7 3292 2700

Post: Level 9, 348 Edward St, Brisbane, QLD, 4000, AUSTRALIA

For Brazil enquiries only: Angelo Pimental, +55 31 997397114

For Russian enquiries only: Maria Samundjan, +7 495 956 55 57

12. Where can you view changes to our Privacy Policy?

Our Privacy Policy will be updated from time to time and we will notify you about any changes to this Privacy Policy by uploading a revised version on our website. You should review our Privacy Policy each time you visit our site or provide us with Personal information.

13. Where can you obtain further information?

We would be happy to provide you with a copy of our Privacy Policy should you require it. If you would like further information on our Privacy Policy or if you have any concerns over the protection of the information you have given to us, or that we have collected from others, please contact our Privacy Officer.

 

Updated: October 2021