Privacy Policy2019-02-11T12:30:53+00:00

What is the Privacy Policy?

thinkHoldings Limited, ABN 19 143 106 147 at Level 1, 14 Spink St Brighton Vic, (we, us and our) is a Software as a Service business.

We are an Australian corporation and conduct our Australian operations in accordance with the Australian Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) which form part of that Privacy Act.

This Privacy Policy applies to us and our related entities.

This Privacy Policy sets out how we collect, use and disclose personal information entrusted to us by our customers or otherwise collected and used by us.

To the extent that relevant national privacy laws permit:

  1. this Privacy Policy is a privacy policy, privacy statement, privacy notice or like disclosure under those laws;
  2. this Privacy Policy is to be notice to affected individuals under those relevant laws, or the basis for consent of individuals to the activities described in this Privacy Policy, this Privacy Policy is a notice and disclosure informing consent by individuals to such activities.

We may modify or amend this Privacy Policy from time to time. We will display a notice on our website indicating when any such revisions have been made.  This Privacy Policy was last updated January 2019.

Unless you notify us otherwise, when:

(i) you provide personal information to us or you click ‘I ACCEPT’ to this Privacy Policy, you consent; or

(ii) in the case of where you are a user of our SaaS service, by your use of the system you are deemed to have consented,

to the collection, holding, using and disclosing of all information which is provided to us for use in accordance with this Privacy Policy.


What is Personal Information

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

Sensitive information is subset of personal information and has the meaning given to it in the Privacy Act. Sensitive information means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetic or biometric information. We do not knowingly collect, hold or use sensitive information, except where required to provide services and consent is explicitly given. If we become aware that sensitive information has been inadvertently collected, or is inadvertently held, by us without consent, we will destroy it.


What Personal Information do we collect?

We may collect personal information from you when you become a user of our system.

The information we request could include (but is not limited to):

  • name, address, contact details and banking details where applicable.
  • your age and/or date of birth;
  • your credit card or payment details (through our third-party payment processor);
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party.


When you access and use our website we will record and log for statistical purposes certain information about such access and use, including your IP address, geo-location data, the date and time of your visit, the parts of our website you access during your visit, your actions on our website, and the browser you are using.

Where we collect and use personal information about any identifiable individual from a publicly available source, we assess whether the collection and use is made in a manner both reasonably contemplated and permitted by the provider of that publicly available source.  Where the collection and use is made in a manner both reasonably contemplated and permitted by the provider of that publicly available source, we rely upon that provider to:

  1. comply with relevant national privacy laws applying to the provider’s activities; and
  2. to provide the necessary notices as required by relevant national privacy laws to that identifiable individual and to obtain the necessary consents from that individual to permit collection and disclosure by the provider of that publicly available source of that personal information, including disclosure in a manner reasonably contemplated and permitted by the provider of that publicly available source.

As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. For example, we may collect information from a third party where they purchase products on your behalf. In such instances, we will determine whether we would have been entitled to collect such information from you under this section 3, and to the extent we would not have been entitled to do so, we will destroy or de-identify such information as soon as reasonably practical.

If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.


You do not have to provide us with any personal information if you choose not to, however if you do not provide us with your personal information, we may not be able to provide you with our goods or services.



If you use our website, some of the personal information referred to in section 3 may be collected through the use of cookies.  Most browsers are set by default to accept cookies.  However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies.

Please note that rejecting cookies may mean that some or all of the functions on our Website will not be available to you.  In particular, cookies must be enabled to access and use any part of our Website for placing orders.


We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Purpose
Currency This cookie stores the currency used for the Site (AUD)
Language This cookie stores the language used for the Site (English)
PHPSESSIONID This cookie contains a unique ID to support functions (for example last viewed products) to improve user experience
newsbcsub This cookie is stored once the user has completed or closed the Register Pop Up, preventing it from re-appearing until after 7 days
TLSCookiesEU This cookie tracks when a user has accepted that the site uses cookies preventing the popup from being displayed again during that session
_ga / _gid / _gat These cookies are used by our Google Analytics account to track customer traffic through the website to help us understand how our website is being used by our customers


We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see or any other URL Google may use from time to time.


How is your personal information used?

The personal information that we collect is generally used to provide products or services to you, and, if you use our website, for analytics purposes to track your usage, to evaluate performance of our website, and to keep track of your shopping cart and your account settings.  Information collected by us may also be used for the following purposes:

  1. Assisting with your questions and complaints;
  2. Arranging for services to be provided by third parties;
  3. Enhancing our customer service and product options;
  4. Internal operations such as record keeping, data analytics, auditing or training;
  5. To keep you informed of product releases, service level performances or system outages;
  6. To keep you informed of the range product offerings or services offered by us;
  7. To send you promotional information about third parties that we consider may be of interest to you;
  8. to comply with our legal obligations and resolve any disputes that we may have;
  9. to consider your employment application; or
  10. as otherwise permitted under the Privacy Act.

You may opt out of receiving information by notifying us accordingly or using any unsubscribe facility we provide for that purpose.


Disclosure of personal information

We may disclose personal information to:

  1. third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  2. our employees, contractors and/or related entities;
  3. our existing or potential agents or business partners;
  4. sponsors or promoters of any competition we run;
  5. anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  6. credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
  7. third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and
  8. third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.

Our agreements with such contractors require that they keep your personal information confidential, and that they only use or disclose your personal information for the purposes of providing those goods or services to us.

By providing us with personal information, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

We may disclose your personal information where the disclosure is authorised by the Privacy Act including:

  1. to lessen or prevent a serious threat to life or health;
  2. to protect the personal safety of users of our website or the public;
  3. to courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  4. if we have reason to suspect that unlawful activity has been, is being or may be engaged in;
  5. to enforce the law or where necessary to investigate a suspected unlawful activity; or
  6. you would reasonably expect, or we have told you that your personal information is usually used or disclosed to third parties in this way.


Access and correction of personal information

We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the Australian Privacy Principles (APPs).

If you require access to your personal information, please contact us at Before we provide you with access to your personal information we will require some proof of identity.  For most requests, your information will be provided free of charge, however, we may charge a reasonable fee if your request requires a substantial effort on our part.

If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.  If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

Restrict: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.


How we hold and secure your personal information

The security of your personal information is important to us.  We take reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure.  This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy and we exclude and limit our liability in respect of the same under our “Terms and Conditions” with you, which are accessible at


 Links to other websites

Sometimes our website contains links to other websites.  When you access a website other than our website, we are not responsible for the privacy practices of that site.  We recommend that you review the privacy policies of each website you visit.


How to contact us

If you have any queries or complaints with regard our collection, use or management of your personal information, please contact:

A:           thinkholdings Limited, 19 143 106 147, Level 1, 14 Spink St, Brighton VIC 3183

T:            +61 3 8306 3610

If you wish to make a complaint about an alleged breach of the Privacy Act, we ask that you send us your complaint in writing to the email address listed above.  We endeavour to respond to complaints within a reasonable period (usually 30 days).  If you are not satisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner by phoning 1300 363 992 or by email at