Privacy Policy

In this policy, BILLBY.COM PTY LTD (Billby) describes what personal information Billby collects on our site, how Billby uses it, and your options regarding information Billby may collect about you.

---

Last updated: May 23, 2018

Purpose

Billby respects your privacy and feels it is important for you to know how we handle the information we receive via our website at www.billby.com (the “Site”) and through our on-demand subscription management software, our support platform, mobile applications and tools and services offered on the Site and mobile application (the “Service”). This Privacy Policy explains our information practices, the kinds of information we may collect, how we use and share that information, and how you can opt-out of a use or correct or change that information. This Privacy Policy is incorporated by reference into Billby’s Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.

Scope

As used in this Privacy Policy, the term “Personal Information” shall mean any information relating to an identified or identifiable natural person. This Privacy Policy applies to Personal Information that Billby collects and processes in the course of our business, including on the Site  and the Billby platform. This policy also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. The use of information collected through our service shall be limited to the purpose of providing the service for which Billby’s client has engaged us. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Billby complies with the Office of the Australian Information Commissioner (OAIC) Privacy Framework as set forth by the OAIC regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. BILLBY.COM PTY LTD has certified to the Department of Commerce that it adheres to the Privacy Management Framework. If there is any conflict between the terms in this privacy policy and the Privacy Management Framework, the Privacy Management Framework shall govern. To learn more about the Privacy Management Framework program, and to view our certification, please visit https://www.oaic.gov.au/agencies-and-organisations/guides/privacy-management-framework.

This Policy applies to all of Billby’s operating divisions, subsidiaries, affiliates, and branches, including its affiliates certified under the Privacy Management Framework and any additional subsidiary, affiliate, or branch of Billby that we may subsequently form.

Types of Information We Collect and How We Use It

Information Clients Provide

When you create an account, use the Services, respond to surveys, request services or information, or contact us directly, we may ask you to provide some or all of the following types of information:

• Account Information: When you register to use the Service with an email address, we collect your full name, company or organization name, email address and password you create. When signing up for a paid plan, Billby will also collect credit card information and use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information except for the sole purpose of credit card processing on Billby’s behalf.
• User Contacts. You can import your basic contact information from your Google Contacts using Billby’s automated contact import wizard.  You can import other email account address books into Billby using a manual import process. For Google, we authenticate your Google email address book using your Billby user email address. We do not collect the username and password for the email account you wish to import your contacts from.
• Communications With Us. When you contact us inquire about the Services, request customer service or technical support, or request other information, we may collect your name, email address, phone number or mailing address.
• Surveys. We may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
• Posting on the Site. Billby offers a community forum in which you may post information on a publicly accessible site. If post information on the community forum, it will be publicly accessible.
• Registration for Sweepstakes or Contests. Occasionally, Billby may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes/contests entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
• Automatic Data Collection. As is true of most web sites and mobile applications, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, mobile device identifiers, and advertising identifiers. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal information.

Information Related to Data Collected for our Clients

Billby provides customer relationship management services to its clients, and collects and processes information under the direction of its clients. Billby has no direct relationship with the individuals whose personal data it processes.

Cookies and Tracking Technologies

We, as well as third parties that provide content, analytics, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.

• Cookies. Cookies are small text files placed in visitors’ computer browsers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. Pixel tags allow us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement
• Local Storage. We use Local Storage (LS) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LS such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LS.
• Behavioral Advertising/Re-Targeting. We partner with a third party to either display advertising on our Web site or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests.

How Billby Uses the Information We Collect

We acquire, hold, use, and Process Personal Information for a variety of business purposes, including:

To Provide Services or Information Requested by Clients. Billby may use Personal Information to provide the Service, fulfill requests for products, Services, or information, including information about potential or future Services.

• Administrative Purposes. Billby may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in Billby’s Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify individual identity;
  • Send email to the email address a Client provides to us to verify your Account and for informational and operational
  • purposes, such as Account management, customer service, or system maintenance;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms.
• Marketing Billby Products and Services to Clients. Billby may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. sYou may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.
• Research and Development. Billby may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
• Anonymous and Aggregated Information Use. Billby may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Billby’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Billby may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Billby and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Sharing Content with Friends or Colleagues. Billby’s Services may offer various tools and functionalities. For example, Billby allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Billby or any other Third Parties for any other purpose.
• Other Uses. Billby may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

How Billby Shares the Information We Collect

Billby does not sell or otherwise disclose Personal Information about you, except as described in this Policy or as you explicitly consent to. We may share your information as described in this Privacy Policy:

• Vendors and Service Providers. We may share Personal Information we receive with vendors and service providers only as necessary to provide the Services to us. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Billby has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Business Partners. Billby may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Billby may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Billby. Billby requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Billby provided them.
• Displaying to Other Users. If you post content to the community forums, it may be displayed publicly on the Site.
• User Testimonials. We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at team@billby.com.
• Interest-Based Advertising and Third Party Marketing. Billby may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Billby related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost as described below.
• Social Media Widgets. Our web site includes social media features, such as the Facebook Like button and widgets, such as the ‘Share This’ button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our web site. Your interactions with these features are governed by the privacy policy of the company providing it.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Billby policies or contracts; (v) to collect amounts owed to Billby; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Billby will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.
• Privacy Management Framework. With respect to transfers to third parties that process Personal Information pursuant to our instructions, Privacy Management Framework requires that Billby remain liable should its vendors and service providers process Personal Information in a manner inconsistent with the Privacy Management Framework.

Data Transfers

We may store all Personal Information we collect anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers.

Data Retention

Billby will retain your information for as long as your account is active or as needed to provide you services. We will also retain personal data we process on behalf of our clients for as long as needed to provide services to our client. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How to Opt-Out

• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. You will continue to receive transaction-related emails regarding products or services you have requested and administrative communications, such as updates to the Terms or this Privacy Policy.
  We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
• Mobile App Push Notifications and Location Data. Our mobile app may occasionally send you push notifications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Billby may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
• “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com, and www.aboutads.info/choices/ (or if located in the European Union at http://www.youronlinechoices.eu/). Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Rights of Access, Rectification, Erasure, and Restriction

• Clients. You can modify, update, or delete your account information at anytime by clicking on the Settings icon in the global navigation bar at the top right of the screen or by contacting us at team@billby.com. You may inquire as to whether Billby is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate by contacting us at team@billby.com. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. We will respond to any requests for access to personal information within 30 days.
• Data Controlled by Clients. We process information at the direction of our clients. An individual who seeks access, or who seeks to correct, amend, or delete data that is processed by Billby for its client should direct his query to the Billby client (the data controller). If the client requests Billby to remove the data, we will respond to their request within 30 business days.

Children’s Personal Information

The Service and Site are not intended for, nor does Billby knowingly collect any personal information from children under the age of 16.

Protection of Information

The security of your personal information and our clients’ information is important to us. Billby maintains reasonable security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. When you enter sensitive information, such as a credit card number, on our order forms and login credentials on our platform login page, we encrypt the transmission of that information using secure socket layer technology (SSL). These technologies help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. However, no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure due to the nature of the distributed network that is the Internet. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at team@billby.com.

Links to 3rd Party Sites

Our site includes links to other web sites whose privacy practices may differ from those of Billby. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

Single Sign-On

You can log in to our site using sign-in services from Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Accountability

In compliance with the Privacy Management Framework, Billby commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Management Framework policy should first contact Billby at the address listed at the bottom of this privacy policy.

Billby has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Management Framework complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or Swiss FDPIC for more information or to file a complaint. The services of EU DPAs and Swiss FDPICs are provided at no cost to you.

Billby is subject to the investigatory and enforcement powers of the Australian Securities and Investments Commission (ASIC). In certain circumstances, the Privacy Management Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described by the  Privacy Management Framework.

Changes to Privacy Policy

Billby may update this policy from time to time. You can review the most current version of this privacy policy at any time at https://www.billby.com/privacy. Your continued use of the Site or Service constitutes your agreement to be bound by such changes to the privacy policy. Your only remedy, if you do not accept the terms of this privacy policy, is to discontinue use of the Site and Service. If we make any material changes we will notify you or our client by email sent to the e-mail address on your account or by means of a notice on the Site prior to the change becoming effective.

Business Transactions

Billby may assign or transfer this privacy policy, and your user account and related information and data, to any person or entity that acquires or is merged with Billby, you will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Terms of Service

When you access and use the Service, you are subject and bound to the Billby Terms of Service.