Privacy Policy

Last Updated: 20 May 2021

IXUP Limited (referred to as “IXUP”, “we”, “our” and “us”) recognises that the privacy of your personal information is important and we are committed to protecting the privacy of any personal information we collect from you.

This Privacy Policy sets out the basis on which we will process any personal information or usage information we collect from you, or that you provide to us, in connection with your use of our website at ixup.com (our “Website”) and in connection with your use of the IXUP software or services (together, the “Services”).

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading the full document.  You can use the hyperlinks below to jump directly to specific sections.

What information do we collect from you?
If you or your employer register an account to use the IXUP platform then we will need some information from you to set this up, including your full name, business title or occupation and contact details.  When you visit our Website we automatically collect the information sent to us by your computer, mobile phone or other device, including your internet address, domain name if applicable, and the date and time of your visit to our website.  If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?
We use your information to administer the Website, and to provide the many functions and services that comprise the Service. We also use your information for account verification, security purposes and to support and improve the Service. We do not share your information with any third parties, except where we need to in order to provide the Service (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the Service) or monitor the success of our marketing and advertising programs, or we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?
We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the Service and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?
Our servers are located in Australia and the United Kingdom. Your information can be accessed from outside of where you live by our staff, support, engineering and other teams around the world, including Australia and the United Kingdom. More Information.

How long do we keep hold of your information?
We generally retain your information for the period during which you maintain an account for the Service, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?
Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?
Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: IXUP Australia  Email: support@ixup.com

UK Representative: UK Data Protection Officer Stephen O’Malley
Email: stephen.omalley@datapowa.co.uk


Welcome to IXUP!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information with your use of our website at ixup.com (our “Website”) and in connection with your use of the IXUP software and services (together, the “Services”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Services. By using the Services you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

The Services have been developed by IXUP Limited (ACN 612 182 368) (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is IXUP Limited. Our registered address is 5-7 Ross Street, Parramatta NSW 2165, Australia.

Our representative in the UK for the purpose of UK data protection laws is the UK Data Protection Officer of dataPOWA Limited, which is a UK company within the IXUP group. The registered address of dataPOWA is Kemp House, 160 City Road, London, United Kingdom and can be contacted at +44(0)20 7867 3800.

Our representatives for data protection purposes in certain jurisdictions are as follows:

UK UK Data Protection Officer +44(0)20 7867 3800 stephen.omalley@datapowa.co.uk

Please reach out to us if you have any questions or concerns regarding the processing of your personal information using the details above.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

  • Account registration information: You give us information about you when you or your employer set up an account to register for the Service: your salutation, your full name, business title/occupation and contact details (address, telephone numbers and business email address).
  • Customer information: You may upload information about you, your customers, business contacts or other persons into our Service for the purposes of conducting secure data analytics.
  • Customer support and feedback information: Relevant information that you provide to us when you communicate with our customer service, when you give us reviews or feedback or otherwise provide information to us through the Service or Website.

2. Information about you generated as part of the Services

We automatically collect certain data from you when you use the Services, namely:

  • your IP address, Open ID and device information, and information regarding your use of the Service, in the form of an activity audit trail.
  • each time you interact with us, for example, if you contact our support team or use the IXUP Support Ticketing system, we collect information including your name, Open ID, and details of the ticket and error. You also have the option of providing your email address and a photo to illustrate the error;
  • when you are using the Service, our security feature collects an audit trail of the Services features that you accessed during the session(s) (in addition to the categories of data listed above)

Cookies
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here.

Children
Children must not use the Service for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.

Country in which the user is located Minimum age of the user
Australia 18
European Economic Area/United Kingdom/Switzerland 16
United States 16

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at support@ixup.com and we will delete such information.

2. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the United Kingdom, the European Economic Area or Switzerland (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information Use Legal Basis ( only relevant if you are located in a Relevant Jurisdiction)
Information you provide to us (either directly or through a third party). 
Salutation, full name, business title/occupation and contact details (address, telephone numbers and business email address). We use this information to create your account for the Service in accordance with your request. Necessary to perform our contract with you to provide the Service.
Information generated as part of the Service
Open ID We use this information to store your Service data with your IXUP platform account. Necessary to perform our contract with you to provide the Service.
IP Address We use this information to allow you to connect to our server. Necessary to perform our contract with you to provide the Service.
Log Data (When you use the IXUP Platform, the system records usage in the form of activity logs. This includes reference to your system username and the relevant action you took on the system) We use this information to:

  • maintain a record of log-in and actions of your account;
  • improve our Service, including the functionality of the Service;
  • for security, audit and verification purposes.
Necessary to perform our contract with you to provide the Service and retain your record of progress and to provide security audit where required.
Customer Support Ticket ID & User Communications with Support: Name, Open ID, email address, details of ticket and error. We use this information to:

  • allow you to use the IXUP Support Ticketing system;
  • improve our services;
  • provide troubleshooting, such as addressing and remediating technical issues and bugs.
Necessary to perform our contract with you to provide and support the Service.

3. How We Store and Share Your Personal Information

The IXUP group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Service are located in:

  • Australia; and
  • the United Kingdom.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Australia and the United Kingdom.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

  • Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, for the purpose of processing support ticket ID and support communication, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
  • Companies within the IXUP corporate group who process your personal information in order to operate the Service. All related group companies may only use your personal information in accordance with this Privacy Policy.
  • Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
    • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
    • detect, prevent or otherwise address security, fraud or technical issues; or
    • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
  • A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either:
    1. sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or
    2. sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

4. Data Retention 

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information Retention Policy
Salutation, full name, business title/occupation and contact details (address, telephone numbers and business email address). Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days.
Personal information uploaded to the Services for secure data analytics Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days.
Customer Support Ticket ID & User Communications with Support Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request)

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

5. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at support@ixup.com.

Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at support@ixup.com.

Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you as described above in the section “How we use your personal information. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction
You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at support@ixup.com.

Erasure
You can edit your account details, or remove certain personal information, by logging into your Service account. You can request deletion of your account and erasure of all personal information by writing to us at support@ixup.com. If there is any other personal information you believe we process that you would like us to erase, please contact us at support@ixup.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection
You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at support@ixup.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at support@ixup.com.Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising
If you have registered to receive updates, personalised advertising or marketing promotions from us, you may choose to stop receiving these updates, personalised advertising or marketing promotions from us when using the Service by clicking the “unsubscribe” link or you can contact us at support@ixup.com.

6. Third Party Links

Our Website may contain links to other online platforms, plug-ins or other applications operated by third parties. We do not control such other sites or applications, and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

7. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to support@ixup.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at support@ixup.com or our service portal  at https://ixup.freshdesk.com/support/login and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.


Supplemental Terms – Jurisdiction-Specific

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.
If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and In-Service purchases.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

  • [Identifiers, such as your name, salutation, Open ID / user ID, IP address, phone number,  email address. This information is collected directly from you or your employer if you choose to sign up for the Services.
  • Internet or other electronic network activity information, such as your information regarding your use of the Service, including date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device and stored as an audit log in the Service.
  • Geolocation data such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.
  • Professional or employment-related information such as your profession if you or your employer chooses to provide it during the on-boarding process. This information is collected directly from you or your employer.

We collect your personal information for the following purposes:

  • To provide you with the Service, maintaining your account and providing customer service.
  • To improve our services, including the functionality of the Service.
  • For security audit and verification purposes, including to prevent and detect fraudulent activity.
  • To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

We disclose personal information to the following types of entities:

  • Other companies within the IXUP group who process your personal information in order to operate the Service.
  • Other companies that provide services on our behalf in support of the Service and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
  • Regulators,  judicial authorities and law enforcement agencies
  • Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident, you have the right to:

  • Request we disclose to you free of charge the following information covering the 12 months preceding your request:
    • the categories of personal information about you that we collected;
    • the categories of sources from which the personal information was collected;
    • the purpose for collecting personal information about you;
    • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
    • the specific pieces of personal information we collected about you;
  • Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
  • Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at support@ixup.com or logging a request in the service portal (https://ixup.freshdesk.com/support/login).