TurnPoint Software Pty Ltd (“we”, “us”, or “TurnPoint”) values and respects your privacy. This Privacy Notice explains how we collect, use, retain and protect your Personal Data (as we define that term below) when you use our websites and our services.

1. What Personal Data do we collect?

“Personal Data” is any information relating to you or that we can otherwise link to you and in which you are personally identifiable. The Personal Data we collect on this website may include your name, email address, address and other contact information.

We may also collect information about your use of the website when you enter and browse the website through the use of “cookies,” web server logs and other electronic tools.

We may collect the following types of Personal Data about you when you visit our websites or use our services:

  • your name;
  • your email address;
  • your telephone number;
  • your position title and place of employment, if you use our services on behalf of your employer;
  • your payment information, such as your credit card details;
  • your banking details for the purpose of facilitating your employer making payments to you, in connection with the TurnPoint Pay payroll service;
  • your IP address, together with the number and frequency of your visits to the website, the websites accessed immediately before and after you visit the website, and the internet browsers used by you;
  • geolocation data recorded by the device you use to access our websites and/or services;
  • details of the products and services we have provided to you (or the entity or business that employs or engages you as a contractor) or that you have enquired about, including any additional information necessary to deliver those products and services and responses to your enquiries;
  • demographic information;

2. How do we collect Personal Data?

We collect Personal Data that you voluntarily provide to us, such as through forms you choose to submit to contact us to obtain more information about TurnPoint Software Pty Ltd (‘TurnPoint’). We may also collect Personal Data through the use of a cookie, web server logs and other tools on our websites and online services.

This Privacy Notice does not address our privacy practices with respect to any Personal Data we may collect from an investor in funds that we sponsor or manage. We address these practices in separate notices to investors as required by law.

3. How and why do we use your Personal Data?

We use the Personal Data we collect from you on our website for the following purposes:

  • enable you to access and use our applications, products and services;
  • operate, protect, improve and optimise our applications, products, and services;
  • optimise your experience and the experience of our other customers, such as to perform analytics and conduct research;
  • send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • send you marketing and promotional messages and other information that may be of interest to you;
  • administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
  • comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

4. What legal basis do we use to collect and process your Personal Data?

We have a legitimate business interest in collecting your Personal Data and using it for the above purposes, including to ensure that it is possible for you to access and receive the services you obtain from us.

5. Is it necessary to provide Personal Data?

You may be required to submit certain Personal Data in order to use our services, such as your name, contact details, and payment information.  We will explicitly ask you for this information before collecting it from you. 

We may also collect cookies when you use our websites, which do not require your consent.

6. With whom do we share your Personal Data?

We will not share your Personal Data with third parties except in the context of those third parties acting as third party data processors, with whom it is necessary to share your Personal Data in order to provide our services to you. For example, we may use a customer relationship manager software platform to organise our business contacts, and your Personal Data may be stored by that software provider. Where relevant, we will ensure that contractual safeguards are implemented with these third-party data processors to ensure the protection of your Personal Data.

7. How long do we retain your Personal Data?

Your Personal Data will be retained for as long as you are a business contact to us, or longer as required by applicable law, whichever is longer. Your Personal Data may be deleted when you are no longer a customer or business contact of ours, or when you withdraw consent (see below), again within the parameters of applicable law. You may unsubscribe at any time from communications from us, and we will cease sending you further communications.

8. What are my rights with respect to my personal data?

You have the right to:

  • know what Personal Data we process about you
  • obtain specific information about such Personal Data
  • request a copy of your Personal Data, free of charge
  • correct or supplement inaccurate Personal Data, unless the request is excessive or unfounded.
  • request that your Personal Data be deleted if it is no longer necessary for the purposes it was originally collected or processed, subject to applicable law
  • request that we restrict processing of your Personal Data in some circumstances, subject to any legal obligations binding on us.
  • receive your Personal Data in a machine-readable format
  • request a transfer of the Personal Data to another party responsible for data processing to the extent that the processing was carried out by automated means.
  • object to processing your Personal Data for marketing purposes, and the right to opt out of such marketing.; and
  • lodge a complaint with the Office of the Australian Information Commissioner.

9. What security do we have in place over your personal data?

TurnPoint has implemented appropriate technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorised persons. We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your Personal Data obtained through use on this website.

10. What are our procedures in the event of a breach to your Personal Data?

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data, we will notify the relevant regulatory body, depending upon the jurisdiction in which you reside, as soon as is reasonably practicable and in any event within 72 hours of discovering the breach, if the breach may place any individual at risk of serious harm. We will also notify you as soon as is reasonably practicable if the breach presents a risk of serious harm to you. We are not required to notify you of a breach if the breached data is encrypted, if we have taken measures, such as wiping the data remotely, and or if the breach is otherwise unlikely to present a serious risk of harm to any person.

11. Updates to this privacy statement

This Privacy Notice was updated in September 2024. We may amend this notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law.

12. Contact information

If you have any questions about how we process your Personal Data, please contact us at info@turnpointcare.com.au