SwiftFox Policies

Definitions

"TRFG" refers to The Red Fox Group, and any subsidiary or related entity.

"The Service" encompasses using a SwiftFox CRM environment, accessing the SwiftFox website, and any professional services provided by TRFG. This may also be referred to as "our Service" or "the Services".

"Client data" refers to the information that our clients submit or collect via the service.

Purpose of this Privacy Policy

We are committed to protecting privacy.

This Privacy Policy applies to the client data and personal data we collect and process in the course of our business.

TRFG’s policies are designed to comply with all state and national legislation, in particular the Australian Privacy Principles (APP).

TRFG commits to:

• only collecting data from clients and individuals in accordance with the APPs;
• being fair and open in the way it collects the data;
• retaining data in a secure environment;
• binding all staff, agents and service providers to its confidentiality agreements and its Privacy Policies;
• not sharing or selling client data to any third-party for marketing purposes and not releasing information unless required by law to do so;
•  allowing clients access to their client data held and inviting clients to advise us if any information is incomplete, inaccurate or out-of-date;
• where possible, amending any data that clients may consider incomplete, inaccurate or out-of-date;
• providing clients with a copy of its Privacy Policy if required;
•  explaining the reasons for collecting data, how it is used and the consequences of not having the data required.

What information do we collect?

Information we process on behalf of clients when they use our services

SwiftFox CRM allows our clients to process data and information for campaigning, business, marketing and other purposes pertinent to their aims. When clients use our SwiftFox CRM product, they may process Personal Data such as first and last name, email address, address, phone number, or other information about you.

We generally store and process information about and on behalf of our clients on our servers as a processor (or service provider) based on a client’s instructions and in accordance with our policies.  Each client controls and is responsible for the information they process using the Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to us for processing purposes.

The types of client data processed may vary, depending on the services we provide.

We will not share, sell, rent or disclose any client data other than as described in this privacy policy.

If you have questions about the Personal Data we process on behalf of a client, please contact the client directly and refer to their policies.

Personal information disclosed to us

We collect personal information that is voluntarily provided to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• passwords
• contact preferences
• contact or authentication data
• billing addresses
• necessary financial information

Sensitive Information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

Financial data

We collect payment and billing information when you request our services.

For example, we may ask you to provide a billing address, or a billing contact for your SwiftFox environment. If you give us payment information, we use it solely as authorised by you in accordance with this Privacy Policy.

Information we collect and process when you integrate the Service with third parties

Third-party integrations may be connected to your SwiftFox environment, which may ask for certain permissions to access data or send information to or from your SwiftFox environment.

It is your responsibility to review any third-party integrations connected to SwiftFox.

We may collect information about the types of integrations you use in your SwiftFox environment.

Any permission(s) granted by you grants these third parties’ access to your data, which may include (but is not limited to) granting third party applications access to view, store, and modify the Client Data in your SwiftFox environment.

We are not responsible for the practices of third-party integrations, so please carefully review the access you grant to third party applications.

Information from social media sites and other publicly available sources

When you provide feedback or reviews about our Service, interact, or engage with us on marketplaces, review sites or social media sites, such as Facebook, X (Twitter), LinkedIn and Instagram through posts, comments, questions and other interactions, we may collect such publicly available information, including profile information, to allow us to connect with you, improve our Service, better understand User reactions and issues, or to reproduce and publish your feedback on our Website.

Once collected, this information may remain with us even if you delete it from these sites. We may also add and update information about you from other publicly available sources or websites.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services.

This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Cookies

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data

Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you accessor use our Services and which we record in log files.

Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports, and hardware settings).

Device Data

We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.

Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data

We collect location data such as information about your device's location, which can be either precise or imprecise.

How much information we collect depends on the type and settings of the device you use to access the Services.

For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address).

Google API

Our use of information received from Google APIs will ad hereto Google API Services User Data Policy, including the Limited Use requirements.

Information about Data-Handling and Processing Practices

We will make information available to clients about the way we handle client data in more specific terms on request. We undertake to ensure that the information provided is meaningful and addresses client concerns.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts

We may process your information so you can create and log into your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user

We may process your information to provide you with the requested service.

To request feedback

We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications

We may process the personal information you send to us for our marketing purposes.

You can opt out of our marketing emails at any time.

To deliver targeted advertising to you

We may process your information to develop and display personalised content and advertising tailored to your interests, location, industry and more.

To protect our Services

We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To identify usage trends

We may process information about how you use our Services to better understand how they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns

We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest

We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

What legal bases do we rely on to process your information?

We may rely on the following legal bases to process your personal information:

Consent

We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of a Contract

We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms.

For example, we may process your personal information for some of the purposes described in order to:

·      Send users information about special offers and discounts on our products and services

·      Develop and display personalised and relevant advertising content for our users

·      Analyse how our Services are used so we can improve them to engage and retain users

·      Support our marketing activities

·      Diagnose problems and/or prevent fraudulent activities

·      Understand how our users use our products and services so we can improve user experience

Legal Obligations

We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third-party, such as situations involving potential threats to the safety of any person.

When and with whom do we share your personal information?

Client Data Disclosure

Employees may view and access client data to perform their duties and provide client services.

We may also disclose client data to:

•               contractors with whom it has a commercial relationship for business where it relates to the services it provides to clients;

•               with clients consent for any organisation for unauthorised purpose.

Except as set out above, we will only disclose client data if this is required by law or as required or permitted under the Privacy Act.  

Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work.

The categories of third parties we may share personal information with are as follows:

• Ad Networks
• Affiliate Marketing Programs
• AI Platforms
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Government Entities
• Order Fulfilment Service Providers
• Payment Processors
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Social Networks
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs

We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device ('cache') your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Do we use cookies and other tracking technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements or to tailor advertisements to your interests.

The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include: Re-marketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.

You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

Do we offer artificial intelligence-based products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Policy govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ('AI Service Providers'), including OpenAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. Your use of those products is also bound by our OpenAI Use Policy (available on our website). You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI applications
• Machine learning models
• Natural language processing

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Policy and our agreement with third parties.This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax,accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information,or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Data Retention and Destruction

Subject to the qualifications immediately below, We undertakes:

• to retain client data only as long as it is required and is consistent with its purpose; and
• to destroy client data when its purpose has expired, and to do so in such a manner that client data is not subsequently capable of being recovered.       

This undertaking is qualified as follows:

• Client data may be retained in logs, backups and audit trails for a 12-month period following the completion of a project to allow for follow up queries and additional requests from the client;
• Client data may be retained beyond the expiry of this purpose if that is required by law, or for the proper running of a software solution provided to the client by We.

In these circumstances, We:

• will take any reasonable steps available to communicate to its clients that its data is being retained, unless precluded from doing so by law; and
• will only retain client data while that provision is current and will then destroy client data.

How do we keep your information safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

We take all reasonable precautions to ensure that client data is protected from misuse, interference, loss, unauthorised access,modification or disclosure using a combination of physical, administrative and technical safeguards.

We commit to the following:

• Store client data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
• Store client data only in jurisdictions where data protections are at least equivalent to those required under the Australian Privacy Act guidelines.
• Only transmit client data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
• Implement appropriate measures to ensure security of client data against inappropriate behaviour by employees and contractors. These include:
  • training for staff in relation to privacy;
  • access control, to limit access to client data to those staff and contractors who have legitimate reasons to access it;
  • particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
  • reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
  • processes to audit, to investigate and to impose sanctions.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal,or modify your information.

Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

What happens if there is a data breach?

We are required to timely report any data breach or eligible data breach to the Office of the Australian Information Commissioner (OAIC),under the Notifiable Data Breaches amendment to the Privacy Act.

Employees have an obligation to promptly report, in confidence, all data or eligible breaches to the CEO. This will allow us to initiate the appropriate procedures and processes in line with its compliance obligations.

If a breach is found to have occurred, that person/s will be provided with an opportunity to explain their conduct. If their explanation is deemed unsatisfactory, they will be the subject of disciplinary action. This may include a warning, suspension, transfer, demotion or termination of employment. Even non-intentional or “one-off” breaches may result in the full range of disciplinary action.

Do we collect information from minors?

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@theredfoxgroup.com.au.

What are your privacy rights?

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right:

1. to request access and obtain a copy of your personal information,
2. to request rectification or erasure;
3. to restrict the processing of your personal information;
4. if applicable, to data portability; and
5. not to be subject to automated decision-making.In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests,or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided below.

Upon the termination of your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems,assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights,you may email us at privacy@theredfoxgroup.com.au.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Do other regions have specific privacy rights?

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided below.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Do we make updates to this notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Policy.

If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

How can you contact us about this Privacy Policy?

We take seriously any complaint about our data handling practices. If a client wishes to lodge a complaint about the way we have handled their data, they may do so by contacting us.

We will respond in writing within 30 days of receiving the complaint, setting out what action we will take as a result of the complaint or alternatively providing an explanation to the client if there has been no breach of the law.

If you have questions or comments about this notice, you may email us at privacy@theredfoxgroup.com.au or contact us by post at:

The Red Fox Group, 40 Stephenson Street, Cremorne, Victoria,3121, Australia

How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you,details about how we have processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please contact us at privacy@theredfoxgroup.com.au

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