Thundercloud Privacy Policy


Thundercloud Pty Ltd (ABN 70 647 561 082) ("we", "us" or the "Company") is committed to privacy protection. We understand the importance of keeping personal information private and secure. This Privacy Policy (“Policy”) explains how and why we collect, use, hold and disclose your personal information, when provided to us or collected by us, offline or online, including through our services, our websites, and our platforms. If you would like more information, please don't hesitate to contact us.

This Privacy Policy forms part of, and is subject to the provisions of, our Platform Terms of Use (https://www.thundercloud.co/terms of use).

The Australian Privacy Principles 

We will treat all personal information in accordance with any and all obligations that are binding upon us under the Privacy Act 1988 (Cth) (“Privacy Act”). The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles” (“APP”).

What is "personal information"?

Personal information held by the Company may include your:

  • name and date of birth;
  • residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
  • bank account and/or credit card details for agreed billing purposes;
  • any information that you provided to us by you during your account creation process or added to your user profile;
  • your clients personal and business information and details of your campaigns;
  • detailed financial information provided via the platform’s accounting software or billing integration;
  • preferences and password for using this platform and your computer and connection information; and
  • any information that you otherwise share with us.

Information provided to payment provider

All purchases that are made through this platform are processed securely and externally by our payment provider. Unless you expressly consent otherwise, we do not see or have access to any personal information that you may provide to the payment provider, other than information that is required in order to process your order and deliver your purchased services to you (e.g. your name, email address and billing address).

How we may collect your personal information

We only collect personal information that is necessary for us to conduct our business of helping advertisers and their agencies to streamline the management of their advertising campaigns, which includes (without limitation) enabling users to oversee:

  • Collection and response to briefs;
  • Creation, implementation and trafficking of campaigns including collection of ad format specifications;
  • Management and optimisation of campaigns;
  • Generation of insertion orders or contracts;
  • Preparation of monthly Invoicing; and
  • Management of workload.

Information that you provide to us

We may collect personal information that you provide to us about yourself when you:

  • use this platform, including (without limitation) when you:
  • create a user account;
  • add information to your user profile;
  • purchase any services through this platform;
  • add campaign details or generate reports  in any element of this platform that permit user-generated content;
  • register for access to additional services or request additional features ; or
  • complete an online contact form to contact us;
  • provide information to us by telephone or through online contact forms; or
  • send us an email or other communication.

IP addresses

This platform may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. The Company may also collect and use web log, computer, location, connection information and technical data (which may include IP address, the types of devices you are using to access the platform, device attributes, browser type, language and operating system) for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this platform.

Cookies

This platform uses "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this platform: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to this platform. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this platform.

Why we use cookies

This platform uses cookies in order to:

  • remember your preferences for using this platform;
  • manage the signup process when you create an account with us;
  • recognise you as logged in while you remain so. This avoids your having to log in again every time you visit a new page;
  • facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
  • show relevant notifications to you (eg, notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and
  • remember details of data that you choose to submit to us (eg, through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).

Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through this platform. For example:

  • Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this site and the pages that they visit;
  • Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
  • third party social media applications (eg, Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this platform.

How we may use your personal information

Your personal information may be used in order to:

  • verify your identity;
  • assist you to place orders through this platform;
  • process any purchases of  services that you may make through this platform, including charging, billing and collecting debts;
  • make changes to your account;
  • respond to any queries or feedback that you may have;
  • conduct appropriate checks for credit-worthiness and for fraud;
  • prevent and detect any misuse of, or fraudulent activities involving, this platform;
  • conduct research and development in respect of our  services;
  • assist in the administration, reporting, processing and management of your campaigns;
  • comply with our legal obligations and assist government and law enforcement agencies or regulators;
  • gain an understanding of your information and communication needs or obtain your feedback or views about our services in order for us to improve them and add additional functionality; and/or
  • maintain and develop our business systems and infrastructure, including testing and upgrading of these systems,

and for any other purpose reasonably considered necessary or desirable by the Company in relation to the operation of our business.

From time to time we may email our customers with news, information and offers relating to our own products/services or those of selected partners. Your personal information may also be collected so that the Company can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease acquiring products and services from us. If you would prefer not to receive promotional or other material from us, please let us know and we will respect your request. You can unsubscribe from such communications at any time if you choose.

When we may disclose your personal information

In order to deliver the products/services you require or for any other purpose set out in this Policy, the Company may disclose your personal information to organisations outside the Company. Your personal information may be disclosed to these organisations only in relation to this platform, and the Company takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may carry out or provide:

  • customer enquiries;
  • mailing systems;
  • billing and debt-recovery functions;
  • information technology services;
  • marketing, telemarketing and sales services;
  • market research; and
  • platform usage analysis.

In addition, we may disclose your personal information to:

  • your authorised representatives or legal advisers (when requested by you to do so);
  • credit-reporting and fraud-checking agencies;
  • data validation providers;
  • credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
  • financial institutions where you hold accounts or have relationships and have been nominated by you;
  • our professional advisers, including our accountants, auditors and lawyers;
  • government and regulatory authorities and other organisations, as required or authorised by law;
  • our IT service providers, payment system operators, data storage, webhosting and server providers, security vendors and maintenance or problem-solving providers;
  • persons you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; 
  • organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
  • the police or other appropriate persons where your communication suggests possible illegal activity or harm to others

How we disclose personal information to overseas recipients

We may disclose your email address and other information needed to construct or tailor an electronic communication  to the following overseas recipients:

  • to our email and marketing service providers;
  • anyone else to whom you authorise us to disclose it.

We will take reasonable steps to ensure these service providers do not breach the Australian Privacy Principles.  

Storage and security of your personal information 

We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. 

We store information about you in computer systems and databases operated by either us or our external service providers with enterprise grade security. 

We take appropriate technical and organisational measures (including physical and electronic security) to safeguard personal information from loss, misuse, unauthorised access, modification or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measure that we use include:

  • restricting access to personal information where practicable;
  • implementing two-factor authentication on all accounts by default;
  • using industry-standard encryption to protect data in transit and at rest;
  • building and maintaining a secure (private) network with no direct access between the internet and systems processing your data;
  • using pseudonymisation techniques such as hashing email addresses or device IDs that we associate with you to reduce the risks when processing that data;
  • conducting regular scans and penetration tests of our applications and networks to identify (and address) any potential vulnerabilities;
  • demanding equivalent security and confidentiality measures from any third parties with which we do business;
  • requiring all employees to comply with internal information security policies and keep information secure;
  • requiring all employees to complete training about information security; and
  • monitoring and regularly reviewing our practise against our own policies and against industry best practice.


We cannot guarantee the security of any information that is transmitted to or by us over the internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Likewise, we take all reasonable measures to ensure the security of hard-copy information. 

Third party websites

You may click-through to third party websites from this platform, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this platform only and the Company assumes no responsibility for the content of any third party websites.

Re-marketing

We may use the Google AdWords and/or Facebook re-marketing services to advertise on third party websites to previous visitors to this platform based upon their activity on this platform. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.

You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.

Duration of retention of your data

We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements.  At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning).  In some circumstances, you can ask us to delete your data.

GDPR

The Company welcomes the General Data Protection Regulation (“GDPR”) of the European Union (“EU”) as an important step forward in streamlining data protection globally.  We intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.

GDPR rights

The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:

  • you are entitled to request details of the information that we hold about you and how we process it.  For EU residents, we will provide this information for no fee;
  • you may also have a right to:
  • have that information rectified or deleted;
  • restrict our processing of that information;
  • stop unauthorised transfers of your personal information to a third party;
  • in some circumstances, have that information transferred to another organisation; and
  • lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and
  • where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.  However, please be aware that:

  • such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other customers/clients subject to appropriate confidentiality protections; and
  • even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:
  • to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and
  • in exercising and defending our legal rights and meeting our legal and regulatory obligations.

Data that we collect about you may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools.  We consider that the collection and such processing of this information is necessary to pursue our legitimate interests in a way that might reasonably be expected (e.g., to analyse how our customers/clients use our services, develop our services and grow our business) and which does not materially impact your rights, freedom or interests.

The Company requires that all third parties that act as “data processors” for us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, only process personal data for specified purposes and have committed themselves to confidentiality.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy, please contact us by email to privacyofficer@thundercloud.co or by post.

Access to your personal information 

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access. 

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

  • be unlawful (e.g., where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
  • have an unreasonable impact on another person’s privacy; or 
  • prejudice an investigation of unlawful activity.

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.

If we refuse to give you access, we will provide you with reasons for our refusal.

Correcting your personal information 

We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Keeping your information up-to-date

To ensure that your personal information is accurate and up to date, please promptly advise us of any changes to your information by contacting our data protection officer by email at privacyofficer@thundercloud.co or by post.

Changes to this Privacy Policy 

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We may notify you about changes to this Privacy Policy by posting an updated version on this platform.

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If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Federal Privacy Commissioner’s website (see www.privacy.gov.au).


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