Privacy Policy

1. Who are we?

In this policy, 'Cobber', 'we', 'us' and 'our' refer to Cobber Software Pty Ltd and its Related Entities and Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)). Our headquarters are in Australia. If you have any questions about this policy, please contact us at:

Email: privacy@cobber.com.au

2. What does this policy cover?

This policy describes how we collect, use, keep secure and disclose Personal Information. 'Personal Information' means any information or an opinion about an identified individual, or an individual who is reasonably identifiable. Personal Information includes, without limitation, your name, email, address, phone number, bank account details, payment information, support queries, community comments. In some countries, Personal Information can also include data about your device, such as your IP address and device type.

This policy applies to Personal Information we collect:

  • across all our websites, software and apps, in connection with our products and services; and
  • from third party data sources, or through surveys, events, customer support interactions, promotional activities, and training.

3. How do we collect your Personal Information?

We will collect your Personal Information:

  • directly from you as much as possible, including when you visit our websites, use our apps, products or services, or engage in conversations with us (eg we will collect your contact information and any other details you share when you request support). If you do not provide certain details, you may only be able to use parts of our products and services;
  • automatically when you visit our websites, or use our apps, products and services (eg data about the pages you look at and the links you click on);
  • from third parties, including your organisation or representatives, and our trusted service providers (eg providers of email, marketing, analytics, financial, credit and payment services), related companies, and social media platforms;
  • when we are required to do so by law; and
  • from our own records of your usage of our services.

If we inadvertently collect Personal Information about you, in circumstances where we have not requested it and we consider it is not required, we will destroy or de-identify that information.

4. What kinds of Personal Information do we collect?

The type of Personal Information we collect depends on how you interact with us. Some common examples are listed below:

General

If you are a customer, or user of our customer's platform, we may collect:

  • contact information such as your name, organisation name, address, email address, or phone numbers;
  • account information such as your login and profile information;
  • transaction sales information such as credit or debit card details, billing address, billing contacts, subscription details, and other details of services you receive from us;
  • ID verification information including government-issued identification documents (passport, driver's licence), residency details, and date of birth;
  • communications information such as feedback on our services, information you provide to us as part of your communications with us or our service providers, survey entries, chat, email or call history;
  • marketing and advertising information such as interests based on your use of our services, survey responses, communication preferences, and subscription details;
  • service usage information such as information about your subscription, use of and interaction with our services, integration of third-party services, and management of invited users within your subscription;
  • social media information posted or uploaded to our social media profiles (or to your social media activities pertaining to us) including 'likes', comments, feedback, photos, and other information that contain Personal Information;
  • device information including your internet protocol (IP) address, internet service provider (ISP), web browser, device type, operating system, and device identifiers; and
  • uploaded content such as any Personal Information in photographs, videos or audio recordings that you upload to our websites or apps.

Platform-specific

In addition to the types of information listed under the 'General' heading above, specific types of information are collected from users of our platform:

  • Member & Supporter Management: contact details, membership status, donation history, volunteer information, communication preferences, and electorate/location data;
  • Email Campaigns: email engagement data including opens, clicks, and unsubscribes;
  • Donation Processing: payment information, donation amounts, and related transaction details;
  • Public Pages: form submissions, petition signatures, volunteer signups, and other data submitted through organisation-hosted pages.

5. How do we use your Personal Information?

We use your Personal Information to operate our services, and to manage our relationship with you. Otherwise, we will only use your Personal Information for:

  • the purpose for which it was collected (as detailed in this policy or as explained to you when we collect your Personal Information); and
  • related purposes, where permitted by law.

At or around the time we collect Personal Information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information.

This list details the specific purposes for which we use your Personal Information:

  • to provide products and services to you (e.g. to manage your subscription, facilitate your purchases, and provide, maintain and deliver our products and services in accordance with the applicable Terms of Use). This includes monitoring, troubleshooting, data analysis, testing, system maintenance, reporting, and data hosting;
  • to collect payments and to administer your account (e.g. to send you service updates, invoices, technical notifications, security alerts, support messages, and enquiry responses). We may contact you by email, telephone, SMS, and social media;
  • to maintain and update our business infrastructure and security systems (e.g. we use malware and other monitoring tools to detect suspicious activity and block unauthorised access). We do this to address threats and fraud, and to protect you and our business;
  • to improve and develop our products and services (eg to inform business decisions by understanding customer behaviour);
  • to promote our products and services to you (eg to contact you about products, services, and events we think may be of interest). We or our partners may contact you by email, telephone, SMS, or social media. You give your express and informed consent to us and our partners using your Personal Information in relation to direct marketing and sales as set out in this paragraph. We will give you the ability to opt-out from receiving any direct marketing messages from us or our partners that you no longer wish to receive;
  • to personalise content (eg to provide local or otherwise targeted information for customers, and to tailor the content served on our websites and apps);
  • for quality assurance, training and record-keeping (eg to review communications with you for customer support quality assurance and training, and related record-keeping);
  • to conduct surveys;
  • for research and related purposes (eg we may personalise, target, and deliver advertising on our websites and apps, and via third party websites and services);
  • for compliance management (eg to investigate any suspected breach of the applicable Terms of Use, or unlawful activity engaged in by you);
  • for legal and regulatory compliance (eg to respond to requests under privacy or other applicable laws);
  • for processing information when undertaking mergers, acquisitions, reorganisations, or disposals, as permitted or required in accordance with applicable law; and
  • to manage legal claims (eg to preserve our legal rights, and investigate, defend, and bring claims to protect our interests).

6. How do we disclose your Personal Information?

There will be situations where we need to share your Personal Information with third parties outside of Cobber. In the normal course of business and in order to provide your services, we may need to disclose your Personal Information to organisations including:

  • our related companies who enable us to provide you with our services, or who otherwise use Personal Information for the purposes in this policy;
  • our service providers (eg providers who are carefully selected to assist us with billing, customer support, hosting and storage, data analytics, security, marketing and email services);
  • your legal, accounting, financial or other professional advisors;
  • third party providers of software that integrate with our websites and apps;
  • our legal representatives, accountants, professional advisors, bankers, and other organisations involved in managing our business and financial affairs;
  • regulators, law enforcement bodies, government agencies, courts or other authorities where we think it is necessary to: comply with applicable laws or regulations; exercise, establish or defend our legal rights; or protect your interests or those of any other person. Where possible and appropriate, we will notify you of this type of disclosure;
  • actual or potential buyers (and their agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business;
  • your organisation, where you are a member, supporter, or volunteer of one of our customers, and you have been invited to use our services by that organisation; and
  • other people where: we have your consent; or permitted by law.

You will not be notified of the disclosure of your Personal information to the parties identified above, and you may be contacted by these parties.

7. Sensitive information

We may also collect sensitive information that you provide to us (eg health information, racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, trade union membership details, or biometric information).

Given the nature of our services as a platform for political organisations, we may need to collect sensitive information from you (and our customers may need to collect sensitive information from their members and supporters).

We will only collect sensitive information from you or use sensitive information to send you direct marketing communications, with your express consent (obtained at or around the time we collect sensitive information).

8. Cookies and similar tracking technology

A 'cookie' is a small text file that is placed on your computer or mobile device when you visit one of our websites. We may use cookies to: monitor traffic patterns or trends; perform analytics; and enhance and customise your experience. We may also gather your IP address as part of our business activities and to assist with operational difficulties or service support issues.

Although this information does not identify you personally, it may identify your ISP. If combined with other sources of Personal Information, it may enable us to identify you. You can accept or reject cookies through your web browser controls. They are often important, so our websites and apps may not work as intended (or at all) if you decide to reject our cookies.

9. Anonymity

Given the nature of our products and services, it is not practicable for us to provide you with the option of dealing with us on an anonymous basis or through the use of a pseudonym.

Your Personal Information is required in order to provide you with our products and services or to resolve any issue you may have.

10. Cross border disclosure

Any Personal Information collected and held by us may be disclosed to, and processed in, a country outside the country you live in. For example, we currently use third party service providers and infrastructure located in the United States of America.

These countries may have privacy laws that are different to the laws that apply in your country of residence. When we transfer data to another country, we put safeguards in place to protect your Personal Information.

11. Security of your Personal Information

We take reasonable steps to ensure that your Personal Information is protected from misuse, loss, unauthorised access, modification or disclosure.

No method of transmission over the internet, or method of electronic storage is 100% secure.

You can help to keep your Personal Information secure by maintaining the confidentiality of any login credentials used to access our products and services.

12. Data retention

We will retain your Personal Information for as long as we have a relationship with you, and for a period of time afterwards where we have an ongoing business or legal need to keep it (eg to comply with legal, tax, or accounting requirements).

After that, we will make sure your Personal Information is deleted or de-identified.

13. Access to and correction of your Personal Information

Please notify us of errors, omissions or changes in your Personal Information, so we can check our records are accurate and up-to-date. This is especially important for information we need to communicate with you (eg a change in name, email address, or phone number).

You can ask us to stop sending you marketing communications at any time, by following the unsubscribe instructions in the marketing communication.

Subject to certain exceptions permitted by law, you also have the right to:

  • know what Personal Information we hold about you, and correct any that is inaccurate or out-of-date;
  • request a copy of your Personal Information we hold;
  • ask us to delete or restrict processing of your Personal Information;
  • request erasure or de-indexing of online search results which contain your Personal Information; and
  • object to our continued processing of your Personal Information.

You can exercise these rights at any time by contacting us at the details above. We reserve the right to charge a reasonable fee for the provision of this information.

14. Resolving privacy concerns

If you have any concerns about how we are processing your Personal Information, please contact us at the details above. We will review and investigate your complaint, and get back to you within a reasonable timeframe.

You can also contact the Office of the Australian Information Commissioner (www.oaic.gov.au), or your local data protection authority, who will be able to advise you how to submit a complaint.

15. Updates

We may modify this policy from time to time. If we make a material change, we will take reasonable steps to notify you (eg by email or by notice on our website and apps).

16. Acceptance

By using our website or purchasing a product or service from us, where you have been provided with a copy of this policy or had a copy of this policy reasonably available to you, you are: acknowledging you have been informed of all of the matters in this policy; and agreeing to provide the consents given by you in this policy.