1. About this website policy

 The Klayo website is operated by Ceventas Pty Ltd (ABN 66 128 878 811), owner of the business name “Klayo”.

Klayo is a workforce capability management service.  Klayo is committed to protecting and respecting your privacy and this privacy policy explains how we will handle any personal information that you provide to us when visiting the website, or that we collect from you in connection with your use of the website.

If you subscribe to the Klayo service, you will be required to separately agree to our Terms of Use.  In so doing, you will be linked to an additional privacy policy which describes how we handle personal information collected from users of the service.

Please note this policy also includes some general conditions of use regarding the website.

2. What is “personal information”?

The Privacy Act 1988 (Cth) defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:

a) whether the information or opinion is true or not; and 

b)whether the information or opinion is recorded in a material form or not.

If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.

3. What personal information do we collect?

We collect information which you provide to us directly, and information related to your use of the website. This may include:

a) your name, address, email address, job title and other contact details;

b) information related to an enquiry about the Klayo service;

c) records of your correspondence with us, if you have contacted us; and

d) information collected automatically using cookies and other tracking technologies, such as details of the web pages you have visited on our website and the content that you access.

4. Cookies

When collecting personal information from you via our website, we may use digital cookies to remember your preferences and collect online traffic data and browsing characteristics. 

This information is statistical data about our users’ browsing patterns and is used to understand how the Site is being used. 

Internet cookies are small strings of text placed on users’ hard drive during the data exchange that happens when a browser points to a website.

The browser stores the message in a text file which is sent back to the server each time the browser requests a page from the server. 

Cookies and other information collection technologies can only store information that is explicitly provided by the user or visitor in the first place, or information which is already known to the website such as your IP address. 

You can choose to adjust your browser to reject cookies or to notify you when they are being used, bearing in mind that rejecting cookies can result in a loss of some website functionality.

By using this Site without adjusting your browser, however, you agree that we can store and access the above cookies on your device.

You may also be shown a cookie consent pop-up when you first access the site. Your preferences will be recorded and you do not need to adjust via your browser.

5. Purpose of collection

Depending on how you use the website, your interactions with us and the reasons for which you provide any information, your personal information may be used for the following purposes:

a) to ensure that the website is presented to you in an effective manner;

b) to provide you with information that you have requested from us; and

c) where you have asked us to or consented to us sending you in electronic and/or paper form promotional materials about our services (such as newsletters or other marketing material), unless you tell us not to do so.

We will only use personal information where it is lawful to do so in connection with our normal business activity. Typically, we will use it:

a) because it is necessary to fulfil a request you have made as an existing or prospective customer relating to our provision of the Klayo service;

b) because you have provided your express or implied consent; or

c) because it is in our legitimate interests to explain and promote the Klayo service.

6. Disclosure of personal information

We generally do not share personal information collected via the website with third parties.

However, personal information may be shared with third parties where one of the following circumstances applies:

a) you have consented to us doing so;

b) we are under a legal or regulatory obligation to disclose the information;

c) our company, or substantially all our company’s assets, are merged or acquired by a third party, in which case your personal information may form part of the transferred or merged assets;

d) to provide anonymous statistical information about users of the website and related usage information to reputable third parties; part of our infrastructure is outsourced; or

e) we are using a third party service provider to provide services that involve data processing (for example, hosting the website).

Subject to the foregoing, we only use your personal information in a manner consistent with the original purposes of collection or as otherwise permitted by the Australian Privacy Principles (or, where and to the extent applicable, the GDPR).

7. Direct marketing

If you access our website, you consent to the receipt of direct marketing material.

We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. 

We do not use sensitive personal information in direct marketing activity. 

Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature. 

In the case of electronic marketing material subject to the Spam Act 2003 (Cth), the material will be accompanied by a functional unsubscribe facility.

An alternative means of opting out is to contact us as set out below and simply request that you receive no further such communications.

8. Access and correction

Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions.

If you require assistance in accessing your personal data for this purpose, please contact us as set out below.

9. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. 

All complaints will be carefully considered, and we may seek further information from you to clarify your concerns. 

If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. 

If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

10. Overseas transfer

Your personal information may be transferred overseas or stored overseas for a variety of reasons. 

It is not possible to identify each and every country to which your personal information may be sent. 

If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction. 

If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.

11. GDPR and other foreign legislation

In some circumstances, the European Union General Data Protection Regulation (“EU GDPR”) provides additional protection to individuals located in Europe. 

Similarly, individuals located in the United Kingdom will in some circumstances be protected by domestic legislation which effectively implements the GDPR (“UK GDPR”). 

Where this is the case, there may be additional rights and remedies available to you under the GDPR in the event that your personal information is handled in a manner inconsistent with that law.

Your additional rights may include the right to object to, restrict and/or withdraw your consent to the processing of your personal information, the right to access or erase your personal information, and the ability to receive a machine readable copy of your personal information.

Some countries outside the EU or the UK may also have data protection legislation with extra-territorial effect which replicates the GDPR in whole or in part.

Please contact us at this link if you require any further explanation in this regard.

12. Amendments to this policy

We reserve the right to change and modify this privacy policy at any time without prior notice. Your continued use of our services following the posting on our website of changes to these terms means you accept these changes. You will always have access to the most recent policy at klayo.com/privacy-policy.

13. How to contact us about privacy

If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us on [email protected].

14. Other important information about this website

In addition to the privacy issues outlined above, you should note the following:

a) we endeavour to keep the website accurate, up to date and available at all times. However, we disclaim all responsibility and liability, to the extent permitted by law, regarding the accuracy and/or availability of the material on this site;

b) the intellectual property rights in all materials on this website are owned by or licensed to Ceventas Pty Ltd, including, without limitation, those subsisting in all photos, graphical works and text (including publications). You may reproduce such materials for your personal review only. You may also copy materials on this website to others provided that any such copy is accurate and not misleading, is provided free of charge, and acknowledges Klayo as its source;

c) any materials on our website are for information purposes only, and to the fullest extent permitted by law, we disclaim all liability and responsibility for any reliance on the materials on our site; and

d) any links provided by our website to any third party sites are provided for information purposes only. We are not responsible for the content, and have no control over, the third party sites to which we provide links.