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Privacy Policy

BPG Investments Pty Ltd as trustee for the Roberts Family Trust, trading as Emote Digital (ABN 20 336 416 194), respects your privacy and is committed to handling personal information openly and responsibly.

This Privacy Policy explains how Emote Digital collects, holds, uses and discloses personal information through https://www.emotedigital.com.au/, our enquiries and business dealings, and the services we provide. In this policy, we, us and our refer to Emote Digital.

1. Who we are

Emote Digital is a brand operated by BPG Investments Pty Ltd as trustee for the Roberts Family Trust. Emote Digital and Bellman Agency are operated by the same legal entity as part of Big Picture Group. Information may be handled by personnel working across these brands where reasonably required for an enquiry, engagement or shared business function.

2. What is personal information?

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

Where practicable, you may deal with us anonymously or by using a pseudonym. In many business situations – such as quoting, contracting, providing services, billing, support or recruitment – we need to know who you are to respond or perform the relevant function.

3. Personal information we collect and hold

Depending on your relationship with us, we may collect and hold:

  • identity and contact details, such as your name, organisation, position, postal address, email address and telephone number;
  • business and professional information relevant to an enquiry, proposal, supplier relationship or engagement;
  • communications, meeting notes, feedback, approvals, support requests and records of our dealings with you;
  • account, quotation, contract, invoicing, transaction and payment-status information;
  • website and device information, such as IP address, browser type, device type, referral source, pages viewed, dates, times and interactions;
  • marketing preferences, event registrations and records of consent or unsubscribe requests;
  • recruitment information, such as a resume, employment history, qualifications, references and work eligibility; and
  • digital and project information supplied for websites, eCommerce, customer relationship systems, analytics, marketing, campaigns, advertising audiences, support or integrations, which may include personal information about customers, users, subscribers or staff.

We do not generally seek sensitive information. If sensitive information is reasonably necessary, we will collect and handle it only where permitted by law, including with consent where required.

4. How we collect personal information

We may collect personal information:

  • directly from you through Website forms, email, telephone, meetings, workshops, proposals, surveys, support requests and other communications;
  • from your organisation, authorised representatives, colleagues or other people involved in a project;
  • from clients when they provide information or access needed for us to perform services on their behalf;
  • from referrals, business partners, service providers, publicly available sources, professional networks and business or social-media profiles; and
  • automatically when you use the Website, through cookies, pixels, server logs and similar technologies.

If you provide personal information about another person, you must be authorised to do so and, where required, make them aware that their information may be handled in accordance with this policy.

5. Why we collect, hold, use and disclose personal information

We may handle personal information to:

  • respond to enquiries, prepare proposals and determine whether and how we can assist;
  • establish, manage and deliver client engagements, projects, campaigns, support and related services;
  • communicate with clients, prospects, suppliers, contractors and other business contacts;
  • administer accounts, contracts, approvals, billing, payments, debt recovery, insurance and business records;
  • operate, secure, analyse and improve our Website, systems, services and customer experience;
  • conduct research, reporting, quality assurance, training and business planning;
  • recruit personnel and manage employment or contractor relationships;
  • send relevant news, insights, event information or service communications where permitted by law;
  • prevent, detect and investigate fraud, misuse, cyber threats, unlawful activity and disputes; and
  • comply with legal and regulatory obligations and protect our rights, personnel, clients and the public.

We may also use or disclose information for another purpose where you have consented or where the use or disclosure is otherwise authorised or required by law.

6. Cookies, analytics and advertising technologies

The Website may use cookies, pixels, tags and similar technologies to operate features, remember preferences, understand Website use, measure performance, improve content, protect security and measure or tailor advertising.

Some technologies are provided by third parties, such as analytics, advertising, social-media, video, mapping or booking providers. Those providers may collect information directly from your browser and handle it under their own privacy policies.

You can manage cookies using your browser settings and any consent controls available on the Website. Blocking some cookies may affect Website functionality. Where required by law, we will seek consent before using non-essential cookies.

7. Who we disclose personal information to

We may disclose personal information, where reasonably necessary, to:

  • our employees, contractors and personnel working across Big Picture Group, Emote Digital and Bellman Agency;
  • information technology, cloud storage, hosting, domain, cyber security, backup, customer relationship management, project management and communications providers;
  • analytics, advertising, search, social-media, email-marketing and content-distribution platforms;
  • payment, accounting, banking, credit, debt-recovery and financial administration providers;
  • printers, production partners, couriers and other specialist suppliers engaged for a project;
  • professional advisers, insurers, auditors and consultants;
  • government bodies, regulators, courts, law-enforcement agencies or other persons where required or authorised by law;
  • a purchaser, investor or adviser in connection with a genuine business restructure, financing, merger or sale, subject to appropriate confidentiality arrangements; and
  • other recipients with your consent or at your direction.

We do not sell personal information.

8. Personal information handled for clients

In providing services, we may handle personal information controlled by a client, for example information contained in a website, customer relationship platform, eCommerce system, campaign audience, research response or other client system. In those circumstances, the client is generally responsible for its own privacy notices, collection authority and instructions.

We handle client-controlled information for the agreed services, in accordance with the engagement and lawful instructions, and may use approved service providers where reasonably required to perform those services.

9. Overseas disclosures

Some of our service providers and specialist contractors operate or store data outside Australia. Depending on the services used for a particular interaction or engagement, personal information may be disclosed to recipients in the United States, United Kingdom, member states of the European Union, India and Singapore, and in other countries notified to a client where relevant.

Before disclosing personal information overseas, we take reasonable steps required by applicable privacy law. However, overseas recipients may be subject to different privacy laws and government-access requirements.

10. Direct marketing

Where permitted by law, we may use contact details to send information about our services, insights, events or opportunities that we reasonably believe may be relevant. You can opt out at any time by using the unsubscribe function in the communication or contacting us. Transactional and service-related communications may still be sent where necessary.

11. Security and retention

We take reasonable technical, physical and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include access controls, authentication, security monitoring, backups, staff and contractor controls, and the use of reputable service providers.

No internet transmission or storage system is completely secure. You should avoid sending sensitive or security-critical information through an ordinary email or Website form unless we have provided an appropriate method.

We retain personal information for as long as reasonably needed for the purposes for which it was collected, to meet legal, accounting, insurance and record-keeping obligations, or to establish or defend legal claims. When information is no longer required, we take reasonable steps to destroy it or de-identify it, subject to lawful backups and archives.

12. Access and correction

You may request access to personal information we hold about you and ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. Contact our Privacy Officer using the details below.

We may need to verify your identity before responding. We will respond within a reasonable period and will not charge for making a request. Where the law permits us to refuse access or correction, or permits a reasonable access charge, we will explain the position as required.

13. Privacy complaints

If you believe we have breached an Australian Privacy Principle or otherwise mishandled personal information, please send a written complaint to our Privacy Officer. Include enough information for us to understand and investigate the issue.

We will acknowledge the complaint, investigate it fairly and aim to provide a response within 30 days. If more time is needed, we will explain why and provide an expected timeframe.

If you are not satisfied after giving us a reasonable opportunity to respond, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au or telephone 1300 363 992.

14. Data breaches

If we suspect a data breach, we will assess and respond to it in accordance with applicable law. Where the Notifiable Data Breaches scheme applies and a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required.

15. Third-party websites and platforms

Our Website and communications may link to or use third-party websites and platforms. We are not responsible for the privacy practices of third parties acting independently of us. Review their privacy policies before providing information to them.

16. Automated decisions

We do not currently arrange for computer programs to use personal information to make decisions that could reasonably be expected to significantly affect an individual’s rights or interests. If this changes, we will update this policy to describe the relevant kinds of personal information and decisions as required by law.

17. Changes to this policy

We may update this Privacy Policy to reflect changes to our practices, services, technology or legal obligations. The current version will be published on the Website with its effective date. We encourage you to review it periodically.

18. Contact our Privacy Officer

Privacy enquiries, access or correction requests and complaints may be sent to:

  • Privacy Officer, Emote Digital
  • Email: hello@emotedigital.com.au
  • Telephone: (03) 9855 2304
  • Post: Suite 6, 13-25 Church Street, Hawthorn, Melbourne VIC 3122

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