Update Note - 1st September 2021 :

As outlined in the Privacy Policy, from time-to-time the Privacy Policy may be updated. Note that this update does not materially impact what information we collect, how we collect it, how we store and use it, when/how we disclose it, or your control of that information. 

The primary changes are the update of the references to the GDPR DPA, and reformatting and reorganization of the Privacy Policy to aid usability.

This note will remain in place until 31st October 2021 AEDT.

 

Thank you for visiting the Cascade Strategy website. We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website, subscription service and associated mobile application (together, our “Services”) to you. In this Privacy Policy “we”, “us” or “our” means Responsis Pty Ltd ABN 26 160 406 100 and Cascade Strategy USA Inc.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to Australian laws, sometimes we contract with business clients that need to comply with the EU General Data Protection Regulation 2016/679 (the “GDPR”). We may assist such business clients by agreeing to comply with the GDPR solely as their data processor and by entering into a data processing agreement (DPA) with them. If we enter into a DPA with a client and the DPA conflicts with or is inconsistent with this Privacy Policy, we will act in accordance with the requirements in the DPA. Note that in such circumstances, we may not be able to assist you in exercising a privacy rights request (such as an access, deletion or rectification request) until we have instructions from our client.

The types of information

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

Sensitive information: is a subset of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

The information we collect and how we collect it

Personal information: The types of personal information we may collect about you include:

Information you provide to us:

  • when you register for or otherwise use our subscription service and/or associated mobile application, including:
    • your name;
    • your contact information, such as your email address, phone number, billing address and/or mailing address;
    • details of the organisation your work for;
    • your role within that organisation;
    • payment details (via our third party PCI-compliant payment processor(s)), for the purpose of payment for our subscription service;
    • any uploads or posts you make to the Services; and/or
    • any support requests, feedback or other information you submit to us;
  • when you otherwise interact with us, including:
    • your name and email address if you request a demo; and/or
    • any feedback, requests, questions or other information that you provide to us and our responses to you, including via email, over our online chat feature and over the phone; and
  • any additional personal information that you provide to us directly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information.

Information we automatically collect:

  • we may automatically collect personal information about you when you use our online Services, including:
    • your browser session, your IP address, geographical location data (i.e. the country your IP address is linked to), internet service provider, clickstream data, device and network information, statistics on page views and sessions (including pages visited and the length of your visit), acquisition sources, search queries and/or browsing behaviour;
    • information about your access and use of our online Services, including through the use of Internet cookies, your communications with our online Services, the access times, type of browser you are using, domain names, the type of operating system you are using, the referral source, and the domain name of your Internet service provider; and
    • any additional personal information that you provide to us indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information.

Information we receive about you:

  • our subscription service allows for:
    • information to be input by users and this may include the input of personal information about you; and
    • information to be exported from other business applications and this may include personal information about you; and
  • any other personal information about you provided to us by a third party (e.g. your employer).

Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent. If we receive or request any sensitive information about you, we will only use it as required or permitted by law.

Why we collect, hold, use and disclose personal information

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access and use our Service;
  • to provide our Services to you, including to create customer accounts and operate, maintain and provide to you the features and functionality of the Services;
  • to enable you to access and use our associated applications;
  • to contact and communicate with you about our Services, including to send you legal notices and updates with respect to our legal documents, such as our terms and conditions and this privacy Policy;
  • for internal record keeping, administrative, invoicing and billing purposes;
  • for analytics, market research and business development, including to operate, personalise and improve our Services, associated applications and associated social media platforms;
  • to offer additional benefits to you (e.g. promotional discounts);
  • for advertising and marketing, including to send you promotional information about our products and services and any other information that we consider may be of interest to you (in accordance with your communication preferences);
  • to comply with our legal obligations and resolve any disputes that we may have;
  • if you have applied for employment with us; to consider your employment application;
  • for another purpose you consent to; and
  • if otherwise permitted or required by law.

Who we disclose personal information to

We will never sell your personal information to a third party. However, we do disclose personal information to third parties for the purpose of providing our Services and related activities, with your consent or where otherwise permitted or required by law.

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, to us and assist us in providing our Services to you, including (without limitation):
    • service providers to help us remove repetitive information from prospect lists or analyse and perform statistical analysis;
    • data storage, web-hosting and server providers to host and store data for us;
    • maintenance or problem-solving providers to help us maintain address issues with the software or the Services more broadly;
    • marketing or advertising providers to assist us in marketing and advertising;
    • professional advisors to provide us with advice, such as financial and legal advice;
    • payment systems operators to process payment;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
  • any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia, including to the United States of America.

We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to ensure the overseas recipient protects your personal information in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details at the end of this Privacy Policy or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you.  We may require further information from you to confirm your identity and/or authorization to make such requests. An administrative fee also may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. In such situation, we will provide you notice and our reasons in writing. Where we are able to and agree to provide you access to your information, we will do so within a reasonable period of your request.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We may require further information from you to confirm your identity and/or authorization to make such requests. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. In such situations, we will provide you notice and our reasons in writing.

Other GDPR rights: If you are an individual using the Services in relation to a business client’s account, you may have other GDPR specific privacy rights. For example, the right to erasure, portability, restriction of processing, etc. To exercise such GDPR based rights, please contact the data controller (i.e. the business client your use is linked to). We will assist in facilitating any such request where we receive instructions from an eligible business client asking us to do so.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. For example, only authorised personnel have access to the personal information we hold and such personnel are required by our policies and contracts with them to maintain the confidentiality and privacy of that information.

Furthermore, where personal information we hold is identified as no longer needed for any purpose for which the information may be used or disclosed or we are otherwise obligated to destroy or de-identify it, we will take reasonable steps to securely destroy or de-identify such information (e.g. by shredding in the case of paper records and other means in the case of electronic records).

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do store data on your hard drive and can recognise you when you return to our online Services. Cookies may also allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Updates

We periodically update this Privacy Policy. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification or displaying an in-service pop-up notification.

While we will notify you of any material changes to this Privacy Policy, we encourage you to review this Privacy Policy periodically.

For any questions or notices, please contact our Privacy Officer at:

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to our Privacy Officer:

By email at:

privacy@cascade.app

By post at:

The Privacy Officer
Responsis Pty Ltd
Level 4 Suite 4.02
59 Goulburn Street
Haymarket
NSW 2000
Australia

Privacy Policy Version v20210901a [Last updated 1st Sep 2021 (AEST)]