Privacy Policy

1. This privacy policy relates to how Meisterline Analytics Pty Ltd (ACN 633 463 886) of Suite 502,
585 Little Collins St, Melbourne VIC 3000 Victoria, Australia (Meisterline) collects, uses, discloses,
retains, and protects your personal information. In this policy “we”, “our” and “us” refers to

2. We take our obligations very seriously and have implemented practices, procedures and systems to
ensure we comply with applicable laws. We are committed to maintaining the confidentiality and
security of your personal information and managing it in an open and transparent way.

3. We review our privacy policy regularly to ensure it is up-to-date so we encourage you to review it from
time to time via the link on our website at (Website). When we do change this
privacy policy we will notify you of such changes as required.

What is Personal Information

4. For the purposes of this policy, "personal information" is information relating to an identified natural
person or an individual who is reasonably identifiable. An identifiable natural person is one who can be
identified, directly or indirectly, by reference to an identifier such as a name, an identification number,
location data or an online identifier, amongst other things.

5. We do not consider personal information to include information that has been anonymised or
aggregated so that it can no longer be used to identify a specific natural person, whether in
combination with other information or otherwise.

Information we collect

6. We collect personal information from you and from other sources when you use our services. If you do
not provide us with the information we request or if we cannot collect this information from other
sources, we may not be able to provide you with our services.

7. In order to provide our services, we may collect the following types of personal information: your full
name, telephone number, email address, other contact details, web analytics such as IP address, and
browsing history, education information, work experience and username for the Website.

8. Wherever it is lawful and practical, you have the option of using a pseudonym or not identifying
yourself when dealing with us. However, by doing so you acknowledge that it may affect our ability to
provide our products and services to you.

9. We also use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers.
We may also allow our business partners to use these tracking technologies on our Website or engage
others to track your behaviour on our behalf. You can disable the usage of cookies through your
browser settings. For more information on our use of these technologies, see our Cookie Policy.

How we collect personal information

10. We collect personal information directly from you when you provide it to us, automatically as you
navigate through the Website, or through other people when you use services associated with the

11. You will provide personal information to us when you complete registration, buy services on our
Website, subscribe to a newsletter or email list, submit feedback, enter a contest, fill out a survey, or
send us a communication.

Your sensitive personal information

12. Some personal information (e.g. ethnicity, religion, political opinions) is sensitive and requires a higher
level of protection under applicable laws. We will only collect your sensitive information under one or
more of the following circumstances: (i) when we have your consent; (ii) the collection is reasonably
necessary for us to carry out one or more of our functions or activities; or (iii) is required or authorised
by law.

Personal information we collect about you from others

13. Although we generally collect personal information directly from you, on occasion, we also
collect certain categories of personal information about you from other sources. In particular:

(i) financial and/or transaction details from payment providers located in the United Kingdom,
Australia and the USA in order to process a transaction; and

(ii) other third-party sources/ and or partners located in the United Kingdom, Australia and the USA
whereby we receive additional information about you (to the extent permitted by applicable law),
such as demographic data, and combine it with information we have about you. We also receive
information about you and your activities on and off the Meisterline platform through partnerships,
or about your experiences and interactions from our partner ad networks.
Dealing with unsolicited personal information

14. If we become aware that a third party shared your personal information with us without first obtaining
your consent, or meeting the necessary requirements under applicable law, then as soon as practicable
we will destroy the information; or ensure that it is de-identified.

Use and disclosure of personal information

15. We will only use and hold your personal information:

(i) for the purpose of conducting our business, to fulfil a contract, or take steps linked to a contract,
in particular providing the services, and facilitating and processing requests and transactions that
take place on our Website.

(ii) where you give us consent to provide you with marketing information about services and
products which we believe may interest you, and customising our Website and services like
advertising on our Website, where this involves the use of cookies or similar technologies.
(iii) where this is necessary for purposes which are in our, third parties, and other parties’ legitimate
interests. These interests are:

a. operating the Website, and providing you with the services described on the Website;

b. updating you with operational news and information about our Website and services e.g.
to notify you about changes to our Website, any disruptions to the Website, or security

c. helping to facilitate the resolution of any disputes;

d. carrying out technical analysis to determine how to improve the Website, and the
services we provide;

e. managing our relationship with you e.g. responding to any comments or queries
submitted to us on the Website; asking for your feedback; or whether you want to
participate in a survey;

f. monitoring activity on the Website e.g. to ensure compliance with the Terms of Use that
apply to the Website and to identify any potential fraudulent activity;

g. to manage our legal and operational affairs;

h. training Meisterline staff on how best to assist our users; and

i. providing general administrative and performance functions and activities.

(iv) for purposes which are required by law, if we reasonably believe it is necessary to respond to
requests to law enforcement authorities conducting an investigation or by government.

16. We will only disclose your personal information to the following recipients:

a. our respective company representatives;

b. service providers and subcontractors who assist us in connection with the ways we use
personal information as set out in clause 15 above, in particular: web hosting providers
located in the United Kingdom, Australia and the USA; technical support located in the
Australia; marketing and analytics services which are located in United Kingdom, Australia
and the USA; security and fraud prevention services which are located in United Kingdom,
Australia and the USA; payment processing services which are located in United Kingdom,
Australia and the USA. Noting that our subcontractors and services providers may also
transfer and access such information from other countries in which they have operations;

c. our professional advisers (lawyers, accountants, financial advisers etc.) which are
located in the United Kingdom, Australia, and the USA;

d. regulators and government authorities in connection with our compliance
procedures and obligations;

e. a purchaser or prospective purchaser of all or part of our assets or our business,
and their professional advisers, in connection with the purchase; and

f. other recipients where we are authorised or required by law to do so.

Marketing regarding your personal information

17. How we use your personal information for direct marketing is controlled by applicable laws. We will
follow those laws to ensure that you only receive direct marketing in circumstances where you have
provided proper consent.

18. We will use your personal information for the purposes of direct marketing where we have your
consent to do so. We will send you marketing communications about products and services that we
deem are of interest to you.

19. If at any time you want to know who provided us with your personal information, then please send a
request to us at [email protected]. We will provide the details of that third party within a
reasonable time and without charge.

20. We will not use your sensitive information for the purposes of direct marketing unless you have
given us permission in writing.

21. We will always provide a simple means for you to “opt-out” from receiving direct marketing, which
typically involves an “opt-out” or “unsubscribe” link on emails, or through a pop-up on your screen
when you provide personal information online. Alternatively, if at any time in the future you do not
want us to send you direct marketing material or you wish to cancel a previous consent, please inform
us by contacting us at [email protected]. We will affect the change without charge.

22. We will not use or disclose your personal information for the purposes of direct marketing if you have
previously told us not to.

23. You can modify your browser preferences in relation to cookies. You have the choice to accept all
cookies, to be notified when a cookie is set, or reject all cookies. If you choose to reject all cookies then
some parts of our Website may not work properly. For more information, see our Cookie Policy.

Cross-border disclosure of personal information

24. Meisterline may transfer personal information to countries outside of Australia, including (amongst
others) the United Kingdom and the USA, but we will only do so in compliance with the law. Where we
transfer your personal information outside of Australia, we will take reasonable steps to ensure that
your information is treated securely, and the means of transfer provides adequate safeguards.

Security of personal information

25. We implement appropriate physical, administrative, and technical measures and safeguards as
appropriate under the circumstances to protect your personal information from misuse, interference,
loss, unauthorised access, modification or disclosure. We store personal information on secure servers
that are managed by us and our service providers. Personal information that we store or transmit is
subject to security and access controls, including username and password authentication and data
encryption where appropriate.

Your rights concerning personal information

26. We will take such steps as are reasonable in the circumstances to ensure that your personal information
that we collect, use or disclose is accurate, up-to-date, complete and relevant. You have the right to
make a request to access your personal information to request corrections of any errors in that data.
You may also close the account you have with us at any time.

27. You are entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly
used and machine-readable format, to you or another data controller), to erase it, or restrict its
processing. You also have the right to object to some processing that is based on legitimate interests,
such as profiling that we perform for the purposes of direct marketing and where we have asked for
your consent to process your data, to withdraw this consent as described below.

28. Your rights are limited in some situations – for example, if we can demonstrate that we have a legal
requirement to process your personal information. In some instances, this means that we can retain
data even if you withdraw your consent.

29. Where we require your personal information to comply with legal or contractual obligations, then
provision of such data is mandatory. If such data is not provided, then we will not be able to manage
our contractual relationship with you, or meet obligations placed on us.

30. If you have unresolved concerns you also have the right to complain to data protection authorities. The
relevant data protection authority will be the data protection authority of the country: (i) of your
habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has

Retention of personal information

31. Meisterline takes steps to ensure that it retains personal information for as long as is necessary to fulfil
the purposes described in this policy, deal with disputes and comply with our legal obligations. When
we no longer need your personal information for a permitted purpose and we are not required to keep
it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy
your personal information or to ensure that the information is de-identified.

32. If you no longer want us to use your personal information or to provide you with services, you can
request that we erase your personal information and close your Meisterline account. Please note that if
you request the erasure of your personal information, we will retain information from deleted accounts
as necessary for our legitimate business interests. The information we retain will be handled in
accordance with this Privacy Policy.

Cookies and web analytics

33. When you visit our Website, there is certain information that is recorded which is generally anonymous
information and does not reveal your identity. If you are logged into your account some of this
information could be associated with your account. We are referring to the following types of details:
your IP address or proxy server IP address; the date and time of your visit to the Website; the length of
your session; the pages which you have accessed; the number of times you access our Website within
any month; and the operating system which your computer uses.

34. Occasionally, we will use third party advertising companies to serve ads based on prior visits to our
Website. For example, if you visit our Website, you may later see an ad for our products and services
when you visit a different site.

35. For more information about how we use cookies, web beacons and similar technologies see our Cookie

Information about children

36. Our Website is not suitable for children under the age of 16 years. If you are from 16 to 18
years, you can browse the Website but will need the supervision of a parent or guardian to
become a registered user.

Contacting Meisterline

37. If you have a concern or query relating to our handling of your personal information or any breaches of
the applicable data protection laws, please notify us at [email protected] by outlining the
nature of the complaint. If unresolved, the complaint may be referred to an external complaints
resolution entity and finally, if necessary, taken to applicable data protection authority in your

This Privacy Policy was last updated December 2020