The Australian Privacy Principles

We will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (“Privacy Act”), which sets out 13 key principles in relation to the collection and treatment of personal information, collectively the “Australian Privacy Principles”.

What is “personal information”?

Personal information held by the Company may include your:

• name and date of birth;
• residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
• bank account and/or credit card details for agreed billing purposes;
• any information that you provided to us during your account creation process or added to your user profile;
• preferences and password for using this site and your computer and connection information; and
• any information that you otherwise share with us.

Information provided to PayPal, Stripe or any other third-party payment process

All purchases that are made through this site are processed securely and externally by PayPal, Stripe or POLI Payments. Unless you expressly consent otherwise, we do not see or have access to any personal information that you may provide to PayPal, Stripe or POLI Payments, other than information that is required in order to process your order and deliver your purchased items to you (e.g., your name, email address and billing address).

How we may collect your personal information

At this site, we only collect personal information that is necessary for us to conduct our business providing solutions for IP transit, Ethernet, colocation and DDoS mitigation.

Information that you provide to us

We may collect personal information that you provide to us about yourself when you:

• use this site, including (without limitation) when you:
• create a user account;
• add information to your user profile;
• purchase any services through this site;
• add reviews, forum or chat room messages or comments in any elements of this site that permits user-generated content;
• register for access to premium content or request certain premium features; or
• complete an online contact form to contact us;
• provide information to us by telephone or through marketing or competition application forms; or
• send us an email or other communication.

IP addresses

This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.

Cookies

This site uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

Why we use cookies

This site uses cookies in order to:

• remember your preferences for using this site;
• manage the signup process when you create an account with us;
• recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
• facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
• show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and
• remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc.).

Third party cookies

In some cases, third parties may place cookies through this site. For example:

• Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies to collect de-identified data about how long users spend on this site and the pages that they visit;
• Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
• third party social media applications (e.g., Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc.) may use cookies in order to facilitate various social media buttons and/or plugins in this site.

How we may use your personal information

In some cases, third parties may place cookies through this site. For example:

• security and verification purposes;
• delivering customer or technical support to assist you to place orders through this site, providing our products or services and communicating with you;
• process any purchases of services that you may make through this site, including charging, billing and collecting debts;
• make changes to your account;
• respond to any queries or feedback that you may have;
• conduct appropriate checks for credit-worthiness and internal investigations to prevent and detect any misuse of, or fraudulent activities involving, this site;
• developing, operating and improving our services and business processes;
• understanding your communication needs or obtain your feedback or views about our services in order for us to improve them;
• maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
• providing disclosure as required by certain third-parties in order to provide certain services, including domain registration and ICANN requirements;

When we may disclose your personal information

The Company may need to disclose your personal information to third-party organisations in order to provide the services you require, or for the purposes set out above. We will take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may carry out or provide:

• customer enquiries;
• mailing systems;
• billing and debt-recovery functions;
• information technology services;
• domain registration when requested by you;
• marketing, telemarketing and sales services;
• market research; and
• website usage analysis.

• your authorised representatives or legal advisers (when requested by you to do so);
• credit-reporting and fraud-checking agencies;
• credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
• our professional advisers, including our accountants, auditors and lawyers;
• government and regulatory authorities and other organisations, as required or authorised by law;
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email to privacy@globalsecurelayer.com or by post.

Access to your personal information

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

• be unlawful (e.g., where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
• have an unreasonable impact on another person’s privacy; or
• prejudice an investigation of unlawful activity.

Correcting your personal information

We will amend any personal information about you that is held by us and is inaccurate, incomplete or out of date, if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Storage and security of your personal information

We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all of our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.

Third party websites

You may click-through to third party websites from this site, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only and the Company assumes no responsibility for the content of any third-party websites.

Redirection to PayPal, Stripe or POLI Payments

In particular, when you submit an order to us, you may be automatically redirected to PayPal, Stripe or POLI Payments in order to complete the required payment. The payment page that is provided by PayPal, Stripe or POLI Payments is not part of this site. As noted above, we are not privy to any of the bank account, credit card or other personal information that you may provide to any third-party payment processor, other than information that is required in order to process your order and deliver your purchased items to you (e.g., your name, email address and billing address). We recommend that you refer to PayPal’s, Stripe’s or POLI Payments’ privacy statement if you would like more information about how they collect and handle your personal information.

Re-marketing

We may use the Google AdWords and/or Facebook re-marketing services to advertise on third party websites to previous visitors to this site based upon their activity on this site. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.

You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this site.

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see www.privacy.gov.au).