Last Updated: October 24, 2023
This Supplemental Privacy Terms for Certain Regions (the “Supplemental Notice”) augments the information contained in ChurnZero’s Global Privacy Policy and applies solely to all visitors, users, and others who reside in the relevant countries referenced herein. To learn more about ChurnZero’s privacy principles, visit our Trust Center.
Australia. Personal information collected, stored, used and/or processed by us, as described in this Supplemental Notice, is collected, stored, used and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth). Specifically, the Privacy Act establishes the Australian Privacy Principles (APPs) (effective from 12 March 2014) that sets out these key obligations, to include:
- APP 1 (open and transparent management of personal information) provides that entities must take reasonable steps to implement practices, procedures and systems that ensure compliance with the APPs and publish their privacy policy;
- APP 5 (notification of collecting personal information) requires entities to ensure that at before, at the time of, or as soon as practicable after, an entity collects personal information from an individual the entity must take such steps as are reasonable in the circumstances to notify the individual of the collection of the personal information.
- APP 7 (direct marketing) restricts the use or disclosure of personal information for direct marketing unless an exception applies; and
- APP 8 (cross-border disclosure of personal information) requires that before an entity discloses personal information about an individual to a person or entity overseas, the entity must take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles.
Personal Information is defined as any information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
This information can include Customer’s name and contact information including postal address, email address and telephone number, billing information, credit or debit card information, and transaction information for any products that may have been purchased.
We adhere to the Australian Privacy Principles for all personal information that we collect from our Customers (i.e., the companies that utilize and pay for our Services) and from any other individuals that we may receive or collect personal information from. In particular:
- We only collect personal information of the individuals who have registered or signed up for our Services (such as credit card information). Where we collect unsolicited information, we deal with this according to the APPs and this Supplemental Notice;
- We only use personal information for the purposes set out in this Supplemental Notice and we only disclose such personal information to third-party vendors to whom Customers link from our Services; and
- Where it is reasonably practicable, we will give our Customers access to their personal information, delete the personal information if requested, and retain it only as necessary to provide our Services to our Customers.
If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.
Brazil. Personal information collected, stored, used and/or processed by us, as described in this Supplemental Notice, is collected, stored, used and/or processed in accordance with Brazilian Law No. 13,709/2018, as amended (LGPD). Those individuals who use or access our Website or Services expressly consent to the collection, use, storage, and processing of their personal information by us for the purposes described in this Supplemental Notice.
Canada. Personal information (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”) will be collected, stored, used and/or processed by us in accordance with our obligations under PIPEDA.
Japan. Personal information collected, stored, used and/or processed by us, as described in this Supplemental Notice, is collected, stored, used and/or processed in accordance with Japan’s Act on the Protection of Personal Data.
New Zealand. Personal information collected, stored, used and/or processed by us, as described in this Supplemental Notice, is collected, stored, used and/or processed in accordance with New Zealand’s Privacy Act 2020 and its 13 Information Privacy Principles (“NZ IPPs”). Specifically, New Zealand law lays out 12 information privacy principles (NZ IPPs) for the proper handling of personal information of Kiwi citizens, and these principles can be found at http://privacy.org.nz/information-privacy-principles. The Act and 12 IPPs presume that trans-border data flows are permissible provided the IPPs are preserved. As is the case with Australian privacy laws, ChurnZero acts as the processor, not collector of the data, of its New Zealand’s Customers’ customers. In addition, our handling of personal information under this Supplemental Notice is perfectly aligned with the 12 NZ IPPs, including those directing that personal information be collected for lawful purposes (e.g., for processing customer service issues), that data should be collected directly from individuals (e.g., Users using the Services), that notice of collection of data and purpose of the data collection is provided, that data be collected in a legal manner, or that individuals have right to access and correct their data.
If you wish to make a complaint about the way we have handled your personal information (including if you think we have breached any applicable privacy laws), you may do so to our Privacy Officer in writing, by mail or email to the address or email address set out in the ‘Contact Us’ section of this Supplemental Notice. Please include your full name, contact details and a detailed description of your complaint. Our Privacy Officer will acknowledge your complaint and respond to you regarding your complaint within a reasonable period. If you consider that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
United Kingdom. Personal information collected, stored, used and/or processed by ChurnZero, as described in this Supplemental Notice, is collected, stored, used and/or processed in accordance with our obligations under the UK Data Protection Act 2018 and the UK GDPR (Regulation (EU) 2016/679).
ENGLISH VERSION CONTROLS. If applicable, non-English translations of this Supplemental Notice are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.