1.0 Introduction

Five Faces Pty Ltd (ABN: 56 126 064 793) is committed to protecting the privacy of all clients accessing our software and services .This Privacy Compliance Plan applies to the Five Faces platform and other services provided by Five Faces (solutions).

2.0 Collection of Information

We will inform you of the purpose for collecting personal information when we collect it and keep it to fulfil the purposes for which it was collected, as required by applicable laws or for legitimate purposes. “Personal information” is any information that can be used to identify an individual, and may include name, address, email address, phone number or payment card number. Data is any information that the Solution requires for its operations or features. Collectively, this is referred to as Information. We collect Information for a variety of reasons, such as processing your order, providing you with a newsletter subscription, enabling the use of certain features of our Solutions, and personalising your experience.

If you choose to provide third party personal information (such as name, email and phone number), we will assume that you have the third party’s permission to provide us with the information. Examples include settings up clients in the Solution to allow suppliers to upload content, or where you are collecting data from your customers. This information will not be used for any other purpose.

In some instances, Five Faces may collect non-personal (aggregate or demographic) data through cookies, web and system logs, web beacons and other similar applications. This information is used to understand better and improve the usability, performance, and effectiveness of the Solution and to troubleshoot. In addition, by using some of our Solutions, anonymous network information may be transmitted to us such as the performance of the Solution and types of devices attached to the network. With this information we can determine how users are interacting with the Solution, to assist us with improving it, to manage your network, and to provide alerts via the Solution about available software updates/upgrades.

3.0  Use of your information

We will only use your Information in the way we specified or intended for use when collected. We will not subsequently change the way your information is used without first asking for your permission. Some of the ways we may use Information includes to deliver a Solution that you have requested, support our Solutions, contact you for support and personalising the Solutions experience.

4.0 Sharing of your information

We do not sell or share your Information to third parties for marketing purposes unless you have granted us permission to do so. We will ask for your consent before we use or share your information for any purpose other than the reason you provided it or as otherwise provided by this Privacy Compliance Plan. We may share Information in the following ways:

*Within Five Faces for purposes of data processing, storage, backup and to provide you with the Solution.

*With business partners, service vendors, authorised third-party agents or contractors to provide a requested service or transaction, including processing orders and credit card transactions, hosting websites, and providing customer support. We only provide these third parties with the minimum amount of Information necessary to complete/provide the requested service or transaction. We do not allow third parties to use your personal information for a different purpose.

*To comply with the law or legal process (such as responding to subpoenas or court orders) and to exercise our legal rights or defend against legal claims.

*To investigate, prevent, or take action regarding illegal activities, suspected or potential fraud, brand protection matters, situations involving potential threats to the physical safety of any person, violations of Five Faces terms of use, or as otherwise required by law.

5.0  Security of Information

We are committed to protecting the personal information you share with us and utilise a combination of industry-standard security technologies, procedures, and organisational measures to help protect your Information from unauthorised access, use or disclosure. We recommend you to take every precaution in protecting your Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords and make sure you use a secure browser. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies.

6.0 Retention/Removal & Re-Instatement of Information

We retain your personal information to fulfil the purposes for which it was collected or as required for legitimate purposes or permitted by law. Data that is deleted from our Solution are archived securely on our servers for 24 months before disposal. This allows for re-instatement of data upon request by the customer to our technical and support departments by authorised staff.

Disposal after 24 months is done by purging all electronic data from our servers.  Upon a formal written request made by the customer to Five Faces from an authorised staff, all information may be purged or de-identified manually to the extent the law allows.

7.0  Use of Cookies & other Web Technologies

Like many websites, Five Faces uses automatic data collection tools, such as cookies, embedded web links and web beacons. These tools collect certain standard information that your browser sends to our website such as your browser type and the address of the website from which you arrived to our website. They may also collect information about your Internet Protocol (IP) address. An IP address is a number automatically assigned to your computer whenever you are surfing the Web, allowing Web servers to locate and identify your computer, which is a unique address assigned to your PC by your Internet Service Provider or Information Systems Department on a TCP/IP network. These tools may also collect information about your clickstream behaviour (for example, the pages you view and the links you click). These tools help make your visit to the Solution more efficient and more valuable by providing you with a customised experience and recognising you when you return.

Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future. We do not respond to “do not track” signals at this time. If we do so in the future, we will describe how in this Privacy Statement.

8.0 Linked Websites

We may provide links to other third-party websites and services which are outside our control and not covered by this Privacy Compliance Plan. We encourage you to review the privacy statements posted on those websites (and all websites) you visit.

9.0 Cross-Border Data Flows

As Five Faces Servers are distributed around the globe via Amazon Web Services, we may transfer your information to servers within our control in Singapore, United States of America, Hong Kong and Australia, or to third parties acting on our behalf for the purposes of processing or storage. By providing any information to us, you fully understand and unambiguously consent to the transfer, processing and storage of such information outside of your country of residence where data protection standards may be different. Our Privacy Compliance Plan and our practices are designed to provide a globally consistent level of protection for information all over the world. This means that even in countries whose laws provide less protection for your information, Five Faces will still handle your information in the manner described here.

10.0 Complaints, Breaches & Contact

Five Faces takes security and privacy matters seriously. Should you have a comment, complaint or suspected breach of your privacy, please contact your account manager to begin investigations or email director@fivefaces.com.au.

11.0       Updates to the Five Faces Privacy Plan

We may update this Privacy Compliance Plan at any time, so please review it frequently. If we change our Privacy Statement, we will submit the revised version to customers, with an updated revision date. Any changes will be compliant with Australian Law.