(I) 1. Introduction

1.1 We understand that the privacy of your personal details, and the security of your transactions with us, is of paramount importance to you. Interlinked has therefore adopted data protection policies with respect to your privacy and security. Interlinked’s Privacy Policy sets out the rules we will abide by when dealing with personal information we collect from individuals in the course of our business. We have based our policy upon the Internet Industry of Australia’s (IIA) draft Privacy Code of Practice, which adopts internationally recognised Privacy protection standards. The IIA Code also covers the requirements of the new Australian Privacy legislation.

1.2 We may make alterations or additions to this policy from time to time. Should we do so, we will update the policy on our web site. We require that all our customers agree to abide by our Privacy policy as part of our terms of trade. This policy also applies to users of our web site who are not customers of Interlinked.

1.3 Please note that we cannot and do not assume any responsibility for the privacy or security practices of any other web sites which you may be able to access through our site, or for our customers’ level of compliance with our code.

(II) 2. What information do we collect?

Interlinked collects different information about you at different times. There are 4 broad categories of information that we collect from you:

2.1 Information we require to supply our services.

• When you first sign up or contract with Interlinked for our services, or when you make an inquiry about our services, we request information such as your name, address, telephone number, domain name, email details of your primary and secondary contacts, credit card details (if you are paying online). We may also ask for your age and gender.

• We may also monitor and/or record telephone conversations with you from time to time in order to train staff and to improve our service to you, with your consent.

2.2 Non personally identifying information.

• In addition to the information you specifically provide above, Interlinked operates statistics gathering software on its web site to collect information about the number of visitors coming to the site. No identifying information is collected by this software. The software records the IP address of the visitor or the domain only. We use this information to improve our own technical structure and performance, and to determine which areas of our web site are most popular.

2.3 Other demographic information.

• If you respond voluntarily to our surveys or other interactive communications, we collect the responses and use the information to improve the quality and range of Interlinked’s products and services.

2.4 Personal information stored on a web site hosted by Interlinked.

Interlinked will have personal information stored on our servers due to the fact that we host web sites of other organisations. Any information that is submitted to or collected by these organisations will be physically located on a Interlinked server. This information, whether voluntarily provided or not, will not be used or released by Interlinked in any manner, and it will be kept strictly confidential, unless we are required to release the information by law.

2.5 Google Analytics Features

The Google Analytics features Interlinked has implemented based on Display Advertising include Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration and Google Analytics Demographics and Interest Reporting.

Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings.

Interlinked will not facilitate the merging of personally-identifiable information with non-personally identifiable information previously collected from Display Advertising features that is based on the DoubleClick cookie unless Interlinked have robust notice of, and the user’s prior affirmative (i.e., opt-in) consent to, that merger. Google encourages users to visit Google Analytics opt-out browser add-on.

2.6 Remarketing with Google Analytics

Interlinked may use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show Interlinked ads on sites across the Internet. This website and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on someone’s past visits to this website.

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Interlinked’s visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Interlinked’s websites, with the drawback that certain features of Interlinked’s websites may not function properly without the aid of cookies.

2.7 Google Display Network Impression Reporting / DoubleClick Campaign Manager

Interlinked uses cookies to help identify and track visitors, their usage of the Interlinked website, and their website access preferences. Interlinked and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to your site.

2.8 Google Analytics Demographics and Interest Reporting

Interlinked may use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics.

(III) 3. How do we use personal information we have collected?

3.1 We collect and use your personal information to deliver our services to you. We will use your personal information to provide you with: technical support, billing and credit control, sales support, product upgrades and information.

3.2 When you contract with Interlinked for our services or make enquiries of our services, you will be requested to provide your consent to us to send promotional material to you. If you consent to receipt of promotional material, we will use your personal information to provide you with promotional material. You may stop the delivery or “opt out” of future promotional email from Interlinked by following the specific instructions in the email you receive. These instructions will tell you how to remove your name from our promotional email list.

3.3 We may use your personal information to:

• contact you in relation to upgrading your use of our services, special offers (from us, or on behalf of third parties), with newsletters, surveys, and individual service audits, monitor and address complaints, other feedback, and to resolve disputes;

• in the case of credit cards, to bill you for services;

• in the case of ABNs, to verify your identity;

• maintain a technical and account history of your dealings with us, and to re-establish your account with us where you re-join as a customer within 6 months after having terminated your account;

• monitor your compliance with our Acceptable Use Policy and other terms and conditions of supply;

• comply with our reporting and other obligations to third party licensors (such as reporting to software suppliers the number and identity of software licenses we have issued as part of our products).

3.4 We will treat all information we collect from you as strictly confidential. Interlinked does not rent or lease its customer lists to third parties. We will not reveal, disclose, sell, distribute, rent, licence, share or pass onto any third party (other than those who are contracted or supply services to Interlinked including of spam filter operators) any personal information that you may have provided to us unless we have your express consent to do so, other than in the circumstances set out in the next paragraph.

3.5 We will disclose your personal information, without notice or your consent, only:

• if we are required to do so by law or in the good faith belief that such action is necessary to conform with the laws, applicable code of conduct or legal process served on us in relation to our business or web site;

• to protect and defend the rights or property of Interlinked;

• if we consider it necessary to do so in order to enforce or apply the terms of any of our agreements with you;

• if we sell our business or part of it; and

• in extreme circumstances, to protect the personal safety of users of Interlinked’s services, our staff or the public.

(IV) 4. Security

4.1 Interlinked has implemented security features in our database to protect your personal information from unauthorised access. We maintain our servers in a controlled, secured environment. Only staff who need to have access to your personal information in order to perform their job function are authorised to access the database.

Constant changes to the Internet and technology mean that we cannot guarantee that data transmission will be 100% secure, or safe from attack by unauthorised intruders.

(V) 5. Other disclosure by you

5.1 You might provide personal information through your participation in chat sessions, message boards, email exchanges or newsgroups accessed via our web sites, or another service provided by Interlinked. This information is public and immediately available to anyone who has access to such a site; it is not private. Interlinked urges you to enter only information that you are comfortable to share with the public at large in this public domain. This Privacy Policy does not apply to such information.

5.2 You should never reveal your password to third parties. If you lose control of your password, you may lose control over your personal information and may be liable for actions taken on your behalf by third parties using your password and/or personal information. Therefore, if your password has been compromised for any reason, you should immediately change it.

5.3 If you collect personal information which you keep on servers provided by Interlinked as part of our service to you (including email), you alone are responsible for compliance with the Privacy Act 1988 (Cth) in respect of that information. We take no responsibility for your dealings with personal information you collect.

(VI) 6. How to access & correct your personal information

6.1 If you contact us via telephone, you will need to answer a few security questions before any personal information is revealed or amended.

(VII) 7. Children's privacy

Interlinked does not knowingly collect, use or market any information to children without seeking parental or a guardian’s consent. We also urge you to familiarise yourself with your legal responsibilities with regard to children and the Internet, which can be found in our Acceptable Use Policy.

(VIII) 8. Complaints

If you have a complaint about any aspect of our Privacy procedures, please contact us on enquiries@Interlinked.com.au and we will deal promptly with your complaint.