1. We respect your privacy
1.1. Flight Lab Pty Ltd (Our Wide Sky) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the National Privacy Principles established by the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information. We are also compliant with the EU General Data Protection Regulations.
1.2. "Personal information" is information we hold which is identifiable as being about you as an individual or data subject.
1.3 We approach data privacy with the following principles
- We collect only what is needed to provide you with the information you requested.
- We seek consent for all activities we undertake.
- We inform you when your data is being collected.
- We use “privacy by design” as a principle in developing procedures, products, offers, marketing programs and content distribution.
- Our intent is to provide information of value to you, that you have consented to receive or that complies with GDPR legitimate interest tests.
2. Collection of personal information
2.1. Flight Lab Pty Ltd (Our Wide Sky) will, from time to time, receive and store personal information you enter onto our website, provide to us directly or give to us in other forms.
2.2. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
2.3 This information will be the minimum require to fulfil our commitment to you.
2.3. Additionally, we may also collect any other information you provide while interacting with us.
3. Lawful Basis
We have undertaken a Lawful Basis assessment in accordance with the GDPR. The results of this assessment are available upon request by emailing email@example.com . We have ascertained that we have a lawful basis to use your personal data to communicate with you on the following grounds:
Where you have provided active and clear consent to receive our communications this may consist of:
- Consent compliant with GDPR.
- Double-opt in to a request for information such as a checklist or newsletter.
- Opt-in to a checklist and newsletter where we can reasonably assume that you are not an EU data subject.
- Consent revoked by un-subscribing from our list. In this case no email communication will be sent to you.
You will always have the right to revoke consent. This is achieved by unsubscribing from any of our email communications.
3.2 Legitimate interest
Where you have provided consent for communications about astronomy from we may send you further communications because you have expressed interest in this subject. This communications will be of the type we promised when you first signed up and is likely to consist of:
- Astronomy checklists.
- Astronomy email lessons.
- Monthly astronomy newsletters with news about Our Wide Sky and astronomy, and suggested astronomy activities.
- Special communications relating to astronomy and Our Wide Sky.
Our assessment has determined that you should reasonably expect to receive some follow up communications with additional free astronomy information or offers for paid astronomy courses, tools, memberships, and other astronomy related products and services delivered by Our Wide Sky.
You always have the right to revoke consent. We will not send you any communications if you have revoked consent by un-subscribing from our list.
We have assessed our communications and marketing processes in the “three stage test” and have determined the following:
- Purpose. All our follow up communications will be astronomy related.
- Processing. In order to send these we process your email address and name through our Customer Relationship Management system. In order to improve your experience and reduce the number of emails sent, we record and analyse the actions you take within the emails we send (such as open, click on links)
- Balancing. We believe that you consent to us sending you a free astronomy tool, document, or email course and we have no desire to overwhelm you with information. We believe our emails are targeted (to your expressed interest) and proportionate (that is, not too many)
We currently have not offer that requires a contract and therefore contract is not a lawful basis. We will shortly be creating offers that require a contract to fulfil and will assess the legal basis of contract at that time.
4. How we collect your personal information
4.1. Flight Lab Pty Ltd (Our Wide Sky) collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you.
4.2 We use the following categories of third parties. Some of these collect and manage your information on our behalf. We have agreements with each of these services that comply with GDPR:
- Customer Relationship Management System, for email distribution and data storage.
- Website Hosting, for hosting our website on their servers.
- Content Management System, to design and deliver our website to you. This includes a variety of plugins for specialist functions to improve the website experience, such as delivering training or social sharing.
- Email, data and document processing and storage, for managing emails, business documents and document distribution.
- Survey design, data collection and analysis.
- Website performance and audience analysis.
- Social media platforms for communication, marketing and advertising.
- Accounts and financial management services.
- Payment processing services.
- Webinar and video presentation services.
- Backup services for data protection and security compliance.
5 Use of your personal information
5.1. Flight Lab Pty Ltd (Our Wide Sky) may use personal information collected from you to provide you with information, news and updates about our services. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
5.2. Flight Lab Pty Ltd (Our Wide Sky) may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
5.3 We perform functions listed in this clause within the context lawrful basis described in section 3.
5.4 We may use your data to enhance your experience on our website, or within social platforms or advertising platforms. When this is done through social or advertising platforms these platforms are the data controller and the data we use has been collected and agregated by the platform, and is provided to us in an anonymised form. That means that Facebook may target you with an advertisement because you visited our website. This does not mean that we know that it was you specifically that visited our website and was then targeted.
6. Disclosure of your personal information
6.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.
6.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
6.3. We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Flight Lab Pty Ltd (Our Wide Sky), its customers or third parties.
6.4. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia. These may include, but are not limited to Australia, USA, Singapore.
6.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
7. Security of your personal information
7.1. Flight Lab Pty Ltd (Our Wide Sky) is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
8. Access to your personal information
8.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at firstname.lastname@example.org.
8.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Australian Privacy Act.
9. Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access: you have the right to request a copy of the information that we hold about you.
- Right of rectification: you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten: you may, in certain circumstances, ask for the data we hold about you to be erased from our records.
- Right to restriction of processing: in some circumstances, where certain conditions apply, you have a right to restrict the way we process your data.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object, and withdraw consent, to certain types of processing.
- Right to object to automated processing, including profiling: you have the right to object to automated processing or profiling.
- Right to judicial review: in the event that Flight Lab Pty Ltd refuses your request under rights of access, we will give you with a reason why we refuse. You have the right to complain as outlined in clause 10 below.
10. Complaints about privacy
In the event that you have a question or complaint about the way we are implementing privacy, or how you believe us to be processing and managing your data, please contact us first. We would like to be able to provide you with the information you need, or to resolve anything before you take formal action. We believe that this is the most reasonable approach.
10.1. If you have any complaints, or seek information about our privacy practices, please feel free to send in details of your complaints to PO Box 367, Oatley, NSW 2223, Australia. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
12.1. When you visit our website
When you come to our website (www.ourwidesky.com) we may collect certain information to improve your experience. This includes actions such as serving the mobile version of your website when we recognise that you are browsing from a mobile device. This information is used in an anonymous and aggregated manner to analyse how people use our site, such that we can improve our service.
Cookies are not malicious programs that access or damage your computer.
The following categories of cookies are used on our site:
- Analytics – to provide us website traffic and anonymised audience behaviour.
- Marketing – To provide the advertising services we use with the ability to present you with the highly relevant advertisements that meet your interest requirements.
- Performance – to help us to improve website performance and usability.
12.3. Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. We cannot guarantee the privacy compliance of these sites.
We may use affiliate links when directing you to purchase items from other sites. These may provide us with some income in the event that you make a purchase. We are not responsible for the privacy compliance of these destination sites and your purchase relationship will be with them. You will have not contractual relationship with Flight Lab Pty Ltd.
Please be aware that Flight Lab Pty Ltd (Our Wide Sky) is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
10 June 2018