CTS Software Pty Ltd – Privacy Policy and Collection Statement

CTS Software Pty Ltd (‘CTS’, ‘we’, ‘our’, ‘us’) regards personal privacy as an important part of our relationship with every person with whom we interact in our business, including customers, Website users, suppliers and business partners.

Please read and review this Privacy Policy which sets out how we collect, use, store and disclose your personal information. This includes information that we may collect via the website and e-commerce store located at www.commoditytradingsolutions.com.au and www.agcrm.com.au (including all password protected areas) and subdomains of such website and all related top-level domains, mobile sites, apps, applications, APIs and widgets (‘Website’).

‘Personal information’ has the meaning in the Privacy Act 1988 (Cth) and includes information about an identifiable individual, and includes names, addresses, telephone numbers, email addresses, dates of birth and credit and banking details.

When you provide information to us, or sign up as a customer on our Website to purchase, view or otherwise browse any of the products, services or content offered by us, you agree and consent to the collection, use and disclosure of your personal information in the manner set out in this Privacy Policy.

This Policy only applies to CTS’s collection and handling of your personal information. It does not apply to, and we are not responsible for, the use of, or the protection of information provided to, other websites linked to our Website or to third parties whom you have connected with as a result of using our Website.

What kinds of personal information do we collect and how do we collect your personal information?
We may collect different personal information from you depending on the circumstances in which that information is collected, including as set out below.
We may collect the following types of personal information:
(a) name;
(b) mailing or street address;
(c) email address;
(d) telephone number and other contact details;
(e) profession, occupation or job title;
(f) your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
(g) any additional information relating to you that you provide to us directly through our Website or indirectly through your use of our Website or online presence or through other websites or accounts from which you permit us to collect information;
(h) information you provide to us through customer surveys or in telephone conversations from time to time; or
(i) any other personal information that may be required in order to facilitate your dealings with us.

During our relationship with you, we may collect personal information from you. We collect personal information in circumstances including:
(a) when you visit our Website;
(b) when you telephone us or visit our Website and make an enquiry and to do so requires your contact details;
(c) when you become a customer and we need to communicate information such as software releases or software changes to AgCRM;
(d) when evaluating job applicants and personnel, including their contact details, employment history and educational qualifications. This may include “sensitive information” as defined in the Privacy Act;
(e) you enter into an agreement or other document with us or for our benefit (including but limited to a Software Master Sales Agreement or Consulting Agreement, whether as a licensee or guarantor); and
(f) when you voluntarily submit your personal information to us for any reason.

CTS may also be privy to the personal information of individuals if such information is incorporated or included in data or files provided by its third party suppliers.

Other than as indicated above, in most circumstances we do not collect sensitive information about you. The Australian Privacy Principles regulate the handling of sensitive information but may allow us to collect that information in some circumstances such as where you consent to us collecting it or it is reasonably necessary for the performance of our functions or activities.

We may use ‘cookies’ to collect data (typically not personal information) relating to your general internet usage. This data may include browser versions, number of visits and similar such data relating to your navigation of our Website. Cookies help us to improve our site and to deliver a better and more tailored service, for instance by storing information about your preferences to analyse trends, to track your navigation history within our Website and to gather broad information and allowing us to recognise you when you return to our Website.

Search terms that you enter when searching our database engine may be collected, but are not associated with any other information that we collect, hence the user is not identifiable. We may use these search terms to ascertain what users are looking for on our Website, and to improve the services that we provide, as well as for the purpose of statistical usage analysis or systems administration.

How will your personal information be used?
CTS uses and discloses your personal information and the information you supply in ways necessary for us to operate our business including our Website, to provide any products and services and, if the case requires, to share any of your personal information with third party suppliers on behalf of whom CTS acts as agent, or with any related body corporate of CTS.

We use the personal information collected from you for the purpose it was provided or collected, including the following:
(a) to provide, maintain, protect and improve our technology, products and services, and monitor their effectiveness;
(b) to operate our business, as it applies to you;
(c) to respond to enquiries received from you;
(d) to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
(e) to perform authorised financial transactions with you;
(f) to verify your identity and to assist you if you have forgotten any user name or password;
(g) to communicate with you and provide you with information (whether by email, post or other means) about our products or services, including any changes to them;
(h) to ensure that content from our site is presented in the most effective manner for you and for your computer/device;
(i) to allow you to participate in interactive features of our service, when you choose to do so;
(j) to receive and address feedback or complaints from you;
(k) to engage in advertising, marketing and promotional activities, including by sending you messages and other information that may be of interest to you (including information sent by, or on behalf of, our suppliers, sponsors and business partners that we think you may find interesting);
(l) for planning, product development or research purposes;
(m) to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
(n) to protect our legal interests and fulfil our legal and regulatory obligations (if and to the extent necessary).

CTS may also use your personal information to send you marketing communications about new products and services. A number of laws are in place to limit direct marketing activity and you may notify us at any time that you do not want to receive any marketing communications from us and we will comply with such requests. All our customers and others with whom we interact have the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you.

We may for analytical purposes use and disclose aggregated and anonymised data that contains no information specific to a particular individual.

We hold personal information in our own secure databases, and, to some extent, for marketing purposes in the databases of third parties engaged by us (subject to obligations regarding privacy and confidentiality) to conduct electronic direct marketing subject to all legislative requirements.

Who will your personal information be shared with?
We will provide your personal information to CTS’s related group companies where necessary to carry out our business functions. We may provide personal information to third parties outside our group companies for limited purposes, such as to help us in providing goods and services to our customers.

Those persons and businesses may include:
(o) our employees, consultants, temporary workers or other representatives;
(p) our suppliers, including those on behalf of whom we have been appointed to sell products as agent via the Website;
(q) our conference organisers, sponsors and partners;
(r) organisations who carry out credit, fraud and other security checks;
(s) our professional advisers, bankers and auditors;
(t) third party software providers who store details of customer accounts for us or who provide other IT services;
(u) agents, contractors or service providers who provide operational services to us or who help provide our services to you, such as online cloud storage and processing, fraud detection and monitoring, marketing optimisation, information technology, telecommunications, market research, customer analysis or tracking, security or other relevant services which requires that entity’s collection, use or disclosure of your personal information;
(v) marketing businesses engaged by us to share materials to which recipients have consented; and
(w) any other party to whom you authorise us to disclose your personal information.

We may also disclose your personal information to third parties outside our group of companies:
(a) where we have your express permission to do so;
(b) where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
(c) if substantially all of our assets are acquired by a third party, in which case personal information which we hold about our customers may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
(d) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, to facilitate court proceedings or to protect our rights; or
(e) to protect the rights, property, or safety of our personnel or customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We do not disclose personal information to businesses located outside Australia, except if and to the extent that any aspect of the Website or our products or services is being hosted by a third party service provider located outside Australia constitutes a disclosure.

Security of personal information
CTS takes all reasonable steps to protect personal information including external and internal security, restricting access to personal information, maintaining technology products to prevent unauthorised computer access and regularly reviewing our technology to maintain security.

We treat website and credit card security seriously and endeavour to provide a secure, safe platform through which to conduct transactions.

How can you access or correct personal information we hold about you?
If you have any questions or concerns relating to our Privacy Policy or you wish to access, update or correct the personal information we hold about you, you can do so by contacting us (see below for contact details). Please provide sufficient detail about the information in question in order to help us locate it. We will then use all commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action.

Concerns and complaints
Please contact us as set out below if you have any concerns or complaints about our use of personal information or other privacy issues. Where you express any concerns that we have interfered with your privacy or otherwise breached the Australian Privacy Principles, we will swiftly respond to let you know who will be handling your matter and when you can expect a further response.

If you are not satisfied with the outcome of your complaint or the way we handle it, you may make a complaint to the Office of the Australian Information Commissioner at www.OAIC.gov.au/privacy/making-a-privacy-compliant.

Changes to this Privacy Policy
As part of our efforts to ensure that we properly manage, protect and process your personal information, changes may be made to this Privacy Policy from time to time. Such changes will be available on our Website and you are encouraged to visit the above Website regularly to ensure that you are well-informed of our latest policies in relation to the handling of your personal information.

By continuing to use our Website and/or services after the Privacy Policy has been amended, you hereby agree to be bound by the terms of such amended Privacy Policy. If you do not agree with the terms of this Privacy Policy, as it may be amended from time to time, in whole or part, you must terminate your use of the Website.

Governing law
This Privacy Policy and any use by you of our Website shall be governed in all respects by the laws of Victoria, Australia.

Contacting CTS

Attention: Privacy Officer
CTS Software Pty Ltd
Post: PO Box 68, Diamond Creek, Victoria 3089
Phone: 0402 219705
Email: support@agcrm.com.au

Last updated: 24 June 2022