Privacy Policy

IntroductionBenchvote Pty Ltd, (Trading as Campaignware) ACN 622 126 603 and its related bodies corporate (“Benchvote”, “Campaignware” “we”, “our” and “us”) of c/o Metis Law, Level 24 Three International Towers, 300 Barangaroo Avenue, Barangaroo, NSW Australia 2000 respects individual privacy and the rights of individuals to control their personal information. We are committed to protecting your personal information. This Privacy Policy sets out our policies and practices regarding the collection, use and disclosure of personal information that you provide to us and which we collect from you. By accessing or otherwise using the platform at www.campaignware.com,  www.benchvote.com, admin.benchvote.com, admin.campaignware.com (“Benchvote Platform” “Campaignware Platform” or “Platform”), contacting us by email, telephone or any other means, using websites owned or controlled by Campaignware, using services provided by Campaignware (together, the “Service”), or by engaging with us in any other way, you agree to the terms and conditions set out in this Privacy Policy and consent to the processing of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

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Definitions“Data” means all data, in any form or medium that you use the Campaignware Platform to collect, including responses to campaigns or activations, survey responses and personal information.

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“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

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“Personal information” is information or an opinion about you or which is reasonably identifiable as you, whether or not the information or opinion is true and whether or not the information is recorded in a material form. “You” means:A Campaign Creator, which is the person or legal entity that has an account on the Campaignware Platform and who creates campaigns or activations on the Platform.A Fan, which is a person who has participated in a campaign or activation through the Campaignware Platform.Any other person or legal entity that comes into contact with Campaignware from time to time, including a person who uses the Website.Types of personal information we collect and hold and how we collect it

The types of personal information that we may collect includes:

3.1 Information that you provide to us directlyInformation that you provide during the registration process, including: your name, address, email address, telephone number and other contact details; Information that you provide when you apply for a job with Campaignware, including: your current employment status, your occupation and length of employment, level of education, your employment history, your answers to assessment questions;Information contained in messages that you send to us through the Campaignware Platform or by email or other records of our interactions with you; any other personal information that may be required in order to facilitate your dealings with us;any other personal information you may volunteer.

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3.2 Information that we collect automaticallyWhen you use a website, mobile application or other Internet service, certain information gets created and logged automatically. This applies when you use the Campaignware Platform. While we do not use browsing information to identify you personally, we may use cookies, web beacons, and other tracking technologies to collect certain analytics data about your use of the Campaignware Platform such as the pages you visit, the date and time of your visit, your IP address and your interaction with the website and other standard web log information. We may collect this data directly or through third party analytics tools.

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3.3 Cookies
A cookie is a small file containing a string of characters that is sent to your computer or mobile device when you visit the Campaignware Platform. When you visit the Platform again, the cookie allows it to recognise your browser. Cookies may store unique identifiers, user preferences and other information which allows the Campaignware Platform to log you in faster, improve your navigation through the Platform and allow us to ensure that the rules of an activation are complied with, for example, where applicable, Fans can only vote once in a competition. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Platform features or services may not function properly without cookies turned on.

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3.4 Web beacons Web beacons (also known as page tags or clear gifs) are used to unobtrusively allow us to track the content that you have accessed. For example, we may use web beacons to determine whether you have opened an email from us or clicked on any links in the email or to determine how Fans interact with the websites of Campaign Creators.

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3.5 Log data Each time you use the Campaignware Platform, your browser or mobile app automatically sends certain information to our servers such as your IP address, searches, browser type and settings, the number of clicks, the date and time of your request, landing pages, how you interact with the Platform, cookies data and device data. Our servers record this log data. Who we collect personal information aboutWe may collect personal information about: individuals;Fans who have participated in a specific campaign or activation and we provide such personal information to the Campaign Creator. our contractors and suppliers;third parties seeking or using our Services; other people who come into contact with us in the ordinary course of business; andapplicants applying for a job or position with us: we may collect certain information from you (including your name, contact details, working history and relevant records checks) your previous employers and others who may be able to provide information to us to assist in our decision whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.Children’s privacyYou must be over 18 (eighteen) years of age to access and use the Platform. We will not knowingly collect the personal information of any person under this age and the Platform is not directed at persons under this age – except as set out hereafter. If you are younger than 18 (eighteen) and you wish to use the Platform, you must have the consent of a parent or guardian (in which case, a reference to “you” means the child and their parent or guardian). If we believe that we have collected any information of a child under the age of 18 (eighteen) (except as set out here) we will delete that information (including the related account) immediately. How we collect and hold personal informationIn general, we do not collect your personal information, unless you provide it to us voluntarily and knowingly during your dealings with us, including by way of: when you voluntarily use the Services;personal contact with us at a face-to-face meeting or situation;correspondence, chats, social applications or services, mail, email or telephone;when you invest in our business or enquire about a potential acquisition of our business.In some cases, we collect personal information from third parties including public sources, our related companies and our service providers. We may hold your personal information in hard copy files and/or electronic files. SecurityWe take reasonable steps to ensure that all personal information that we collect is kept secure in accordance with industry standard physical, electronic and managerial procedures, specifically we store all your personal data on secure servers using standard encryption.

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.All of our staff are trained to comply with this Privacy Policy. In respect of personal information collected online or stored electronically (including in the cloud) in particular, you acknowledge that no security system is impenetrable and that the security of such networks and systems can never be guaranteed. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information which is transmitted to us is transmitted at your own risk. Where you have chosen a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

Why we collect, hold, use and disclose your personal informationWe will use and disclose your personal information only for the purpose (the “primary purpose”) for which you provide it to us, which may include: where we need to perform the contract we are about to enter into or have entered into with you or your organisation.where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests. Whenever we process your personal data under the ‘legitimate interest’ lawful basis, we make sure that we take into account your rights and interests and balance any potential impact on you (both positive and negative) before we process your personal data for our legitimate interests. We will not process your personal information if we feel that there is an imbalance.where we need to comply with a legal or regulatory obligation.to enable you to access and use the Campaignware Platform;to respond to any query or complaint that you may make or otherwise provide customer support; for internal administration and operational purposes such as preventing fraud and abuse of our systems and to troubleshoot bugs;to operate, protect, improve and optimise the Campaignware Platform and our business - such as to perform analytics, conduct research, evaluation and development and quality control purposes and for advertising and marketing;for all purposes relating to recruiting and assessing your suitability for roles with us and to consider your employment or contractual engagement application.

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Use of campaign and activation Data As part of a campaign or activation, we collect Data on behalf of the Campaign Creator, so Campaignware is only processing that Data on behalf of the Campaign Creator. This Data is controlled and managed by the Campaign Creator.

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We may aggregate and anonymise the Data and use the anonymised Data for other purposes, such as to analyse the Services and to improve the Services. Who we disclose your personal information toWe may disclose your personal information to: where you are a Fan, the Campaign Creator who created the specific campaign or activation. This is because we collect your personal information on behalf of the Campaign Creator. third party contractors engaged to perform functions or provide services relating to the purposes for which we collect personal information (for example customer support and management). If this is the case, we will take reasonable steps to ensure that they comply with this Privacy Policy;third party service providers or affiliates within or outside of Australia who work on behalf of or with us to provide some of our administrative and other services (such as processing payments, email services, hosting and data analytics). We require such service providers to agree not to use such information except as necessary to provide the services to us;professional advisers, dealers and agents;any party to whom our assets or business may be transferred (including a sale of Campaignware shares) or with whom we are merged or any other such corporate action;enforcement or regulatory authorities, within and outside of Australia, if required by law.Secondary purposeWe will not use or disclose your personal information for any secondary purpose, unless you consent to that use or disclosure; or you would reasonably expect the use or disclosure in the circumstances, and that secondary purpose is related to the primary purpose for which we have collected that information. Except as set out in this Privacy Policy (or as required for by any statutory or legal requirements), we do not share, sell, rent or otherwise disclose your personal information to third parties.Managing your personal informationWe will take reasonable steps to ensure that any personal information we collect is up-to-date, complete and accurate, and any personal information that we use or disclose is up-to-date, complete, accurate and relevant. The data protection / privacy laws in different countries allow users to particular rights in relation to their personal information. Accordingly, you may contact us at help@campaignware.com or at c/o Metis Law, Level 24 Three International Towers, 300 Barangaroo Avenue, Barangaroo, NSW Australia 2000:  to seek all or some of the following:Access: You can ask us for a copy of your personal information including a structured electronic version of it.Change or correct information: You can also ask us to correct or update your personal information.Delete your personal information: You can ask us to erase or delete all or some of your personal information (e.g. if you withdraw your consent, or it is no longer necessary to provide the Services to you).  Object to, or limit or restrict, use of personal information: You can ask us to stop using all or some of your personal information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g. if your personal information is inaccurate or unlawfully held).Sometimes we may not be able to provide you with access to some or all of your personal information. If this is the case, we will tell you why. We may need to verify your identity when you request access to your personal information. If you are a Fan, you will need to ask the Campaign Creator to access your personal information.

Overseas disclosures

We may share your personal information with third parties (such as service providers) who are based outside Australia. These parties are contractually required to comply with this Privacy Policy. Except as may be set out elsewhere in this Privacy Policy, we do not otherwise disclose your personal information outside of Australia.Complaints about a privacy breachIf you believe that we have breached this Privacy Policy, you may direct your complaint to us at help@campaignware.com or at c/o Metis Law, Level 24 Three International Towers, 300 Barangaroo Avenue, Barangaroo, NSW Australia 2000. Please include your name, email and/or telephone number. We will review your complaint and liaise with you directly to resolve your complaint within a reasonable time. Links to third party websitesThe Campaignware Platform may contain links to third party websites. If you visit a third party website, then you should read the privacy policy of that third party site to understand how they collect and use your personal information. We are not responsible for how any third party website collects or uses your personal information. This Privacy Policy applies solely to the personal information collected by us. Changes to our Privacy Policy Any changes to this Privacy Policy will be posted onto the website. Unless stated otherwise, changes will be effective immediately upon being placed onto the website. Your continued use of the Platform following such amendments being placed on the website will represent an agreement by you to be bound by the Privacy Policy as amended. Additional applicable terms if you are based in the United Kingdom of Great Britain and Northern Ireland (UK) and Europe

14.1 Important information and who we are

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This Privacy Policy aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase our services.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Campaignware is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy (including any requests to exercise your legal rights) or our privacy practices, please contact our DPO using the details set out below.

DPO: Adam MussaEmail address: adam@campaignware.com

Address: c/o Metis Law, Level 24 Three International Towers, 300 Barangaroo Avenue, Barangaroo, NSW Australia 2000.PO Box K147 Haymarket NSW Australia 1240.
Please keep us informed if your personal data changes during your relationship with us.

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If you use the Campaignware Service and are based in the UK or Europe, then:
our representative is Metis Law Limited, a regulated firm of English Solicitors, who can be contacted at 2nd Floor, 84 Albion Street, Leeds, West Yorkshire, LS1 6AD, United Kingdom;You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) if you are unhappy with how we have used your data. The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. It is important that the personal data we hold about you is accurate and current.

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14.2 Types of data we collect about you

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In addition, we may collect, use, store and transfer different kinds of personal data about youwhich we have grouped together as follows:
Identity Data which includes first name, last name, username or similar identifier.Contact Data includes email address and telephone numbers.Financial Data includes bank account and payment details for you or your  organisation.Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.Profile Data includes your username and hashed password, purchases or orders made by you, your interests, preferences, feedback and survey responses.Usage Data includes information about how you use our website, products and services.Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.Service Data includes data type, data storage, list of attributes of data and the legal basis for processing.Aggregated Data includes data such as statistical or demographic data aggregated for  any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy

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14.3 Third parties & Sub-processors

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The nature of the Campaignware Service means that if you are a ‘fan’ your personal data may be collected by us on behalf of a named third party. That named party will normally be the owner of a particular campaign that you agree to participate in. You acknowledge and agree that we can share such information with that third party campaign creator, who may utilise your personal data for marketing purposes.
In addition, in order to provide the Campaignware Service, we might store or send personal data about you to various third parties as set out below.
Third Party Data Residency/Corporate Location
AutopilotUnited StatesAWSSydney, AustraliaCalendlyUnited StatesChargebeeUnspecified FreshdeskUnspecifiedGoogleAdsUnspecifiedGoogle DriveUnited KingdomHotjarUnspecifiedHubspotUnspecifiedLinkedInUnited StatesMailshakeUnspecifiedSkypeUnited StatesStonlyUnspecifiedXeroUnited States

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14.4 How we use your personal data

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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We may send you marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving marketing. You can ask us to stop sending you marketing messages by contacting us at any time.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Data Elements Lawful basis for processing
Managing returns & refundsTransaction Information, Information and content provided by user, Credit Card details, Email Address, Name, Billing address, Banking informationContractual ObligationsAccounts payableTransaction Information, Information and content provided by user, Credit Card details, Email Address, Name, Billing address, Banking informationContractual ObligationsAccounts receivableTransaction Information, Information and content provided by user, Credit Card details, Email Address, Name, Billing address, Banking informationLegitimate InterestsPromotion of products and servicesInformation and content provided by user, Email Address, Name, Client identifiers, IP Address, Telephone Number, Device identifiers, GPS Location, Device foreground operations, Information others provide about users, Device Information, Occupation, Skills, Bluetooth & Wi-Fi signals, Endorsements, Tracking activities around messaging, Education, Device background operations, Social media usage, Calendar, Social media network/connections, Mouse movements, Work Experience, Activities off website, Cookie identifiers, Address Book, PhotosLegitimate InterestsOnboard new customerInformation and content provided by user, Email Address, Name, Telephone NumberContractual ObligationsCustomer communicationsInformation and content provided by user, Email Address, Name, Telephone Number, Information others provide about users, Occupation, employerContractual ObligationsPayrollTransaction Information, Email Address, Name, Billing address, Banking informationContractual ObligationsLearnings & developmentsEmail Address, Name, Client identifiers, IP Address, Device identifiers, GPS Location, Device Information, Mouse movements, Cookie identifiersLegitimate InterestsTalent attractionInformation and content provided by user, Email Address, Name, Client identifiers, IP Address, Device identifiers, GPS Location, Device foreground operations, Information others provide about users, Device Information, Occupation, Skills, Bluetooth & Wi- Fi signals, Endorsements, Tracking activities around messaging, Education, Device background operations, Social media usage, Calendar, Social media network/ connections, Mouse movements, Work Experience, Activities off website, Cookie identifiers, Address Book, PhotosLegitimate InterestsCustomer Relationship Management (CRM)Email Address, Name, Telephone Number, Information others provide about users, OccupationLegitimate InterestsSupplier relationship managementEmail Address, Name, Telephone Number, Information others provide about users, OccupationLegitimate InterestsApplication DevelopmentEmail Address, Name, Client identifiers, passwordLegitimate InterestsCustomer supportInformation and content provided by user, Email Address, Name, Information others provide about users, passwordContractual ObligationsInternal communicationInformation and content provided by user, Email Address, Name, Client identifiers, Device identifiers, Information others provide about users, Device Information, password, Browser, Preferences & opinionsLegitimate Interests

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14.5 Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.