Privacy Policy

Jumbla Pty Ltd ( ABN 32 151 912 542) (collectively referred to as “Jumbla”, “we”, “us” or “our”) is committed to providing you with the best possible customer service experience. Jumbla is bound by the Privacy Act 1988 (Cth) and the General Data Protection Regulation (where applicable), which sets out a number of principles concerning the privacy of individuals

This Privacy Policy sets out Jumbla’s approach to handling personal information and includes information on how we collect, use, disclose and keep secure your personal information, whether provided to us via this website, any of our related websites, social media pages, intranet or mobile applications (each a “Website”), or any other means through which you provide personal information to us, including either physically or electronically. We are the data controller and we are responsible for your personal data.

We may, from time to time, review and update this Privacy Policy so please check this website periodically to stay informed of any updates. All personal information collected and held by us will be governed by the most recently updated Privacy Policy.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@jumbla.com.au

Anonymity and pseudonymity

Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, we only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified in this privacy policy. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.

Collection of personal information by Jumbla

There are many aspects of the site which can be viewed without providing personal information. Jumbla may collect and store personally identifiable information about you if you voluntarily submit such information to Jumbla.

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We will only collect personal information from you that we reasonably require for one or more of our business functions or activities, and will do so by lawful and fair means.  

The kinds of personal information we may collect from you will depend on what type of interaction you have with us.  However, it may include, among other things:

• Communication data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

• Marketing data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. 

• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business. 

• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
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  We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

• If you are applying for a position with Jumbla, we will collect information as outlined in the section below entitled “Employment Applications”.

In some circumstances, we may collect personal information from third parties such as recruitment agencies, social media platforms and other data providers or organisations that share the data in circumstance where it is lawful and/or you have given permission for them to do so. Where we do, we will ensure that we act in accordance with relevant Australian laws.

Sensitive data

We do not collect any sensitive data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@jumbla.com.au at any time. 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc. 

Where your personal information is stored

Where we store your personal information depends on what interaction you have had with us. However, some areas may include:

• Databases for processing customer enquiries or feedback; or
• Email or SMS databases for marketing communications about our products and services.

How your personal information is stored

Jumbla takes reasonable steps to protect your personal information from loss or unauthorised access and to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, including in Indonesia. Jumbla cannot ensure the security of any information transmitted to or from a Website or the security of information contained on a Website. Accordingly, although we strive to protect such information, we do not warrant the security of any information you transmit to us or from our online services and you use these services at your own risk.

If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable and may notify the Office of the Australian Information Commissioner, or the Information Commissioner’s Office (whichever is applicable), about that actual or possible breach.

We only keep your personal information for as long as it is required for the purpose for which it was collected, for example to administer a promotion or consider your employment application, or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it.  These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.

How your personal information will be used

We collect your personal information so that we can use it for our functions and activities and provide products and services to you, which include, among other things:

• administering and responding to your enquiry or feedback about our products and/or services;
• administering and conducting traineeships;
• facilitating our internal business operations, including fulfilment of any legal and regulatory requirements;
• improving the operation or navigation of our websites;
• maintaining and improving the functionality of a Website to provide better service to Website visitors and users, including the compilation and analysis of statistics and trends, the provision of information to you relating to the content available on that Website and any e-commerce transactions conducted via that Website;
• processing and considering your employment application and conducting reference checks (refer to Employment Application section below);
• providing direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel;
• providing you with relevant advertising when you use our Websites or those of a third party; and

We may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by law.

Disclosure of personal information to third parties

For the purposes described above, or to operate a Website or deliver a service, personal information may be shared with our group companies, selected service providers and other trusted third parties (and their directors, servants and agents) either in Australia or overseas including in Indonesia and New Zealand. Our group companies, selected service providers and/or other trust third parties may be engaged to provide a variety of functions, such as legal and accounting services, data storage, and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions.

We may also disclose personal information we collect from you:

• to our related companies, suppliers, consultants, contractors or agents for other purposes directly related to the purpose for which the personal information is collected;
• where the law requires or authorises us to do so;
• to others that you have been informed of at the time any personal information is collected from you; and
• with your consent (express or implied) to others.

Jumbla.co.uk (London)

Where we process the data of users based in the EU, we are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

• If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

Opting in or out procedures

At the point we collect information from you, you may be asked to “opt-in” to consent to us using or disclosing your personal information and to receiving direct marketing materials form us. You have the option to opt-out of receiving information from Jumbla and this opt-out messaging will appear at the bottom of every promotional email or SMS or other message we send to you. Jumbla also gives you the option to remove your information from our database of active users. If you no longer wish to take advantage of a Website or to receive any form of direct contact from Jumbla, whether it is email, newsletters, or other promotional offers or materials, or wish us to delete your personally identifiable information from our database of active users, send us a request marked "Privacy-Urgent" to the contact details contained in this Privacy Policy.

Passive Information Collection

As with many commercial websites, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally, you consent to the collection of such information where it is personal information.

As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Our Websites may use and combine such passively collected anonymous information or personal information from various third party sources to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.

Employment Applications

Generally, the type of personal information we collect about applicants is the information included in your application for employment, for example, your name, postal address, telephone number, email address, education details, employment history and other information relating to your work experience.

In considering your application, we may also obtain personal information about you from third parties, for example, from your previous employers or nominated referees.  Subject to your consent, we may also collect sensitive information about you such as information about your health (including any disability), visa or immigration status or any criminal record you may have.

We collect personal information for any one or more of the following purposes:

• assessing you for a position with us or one of our related entities;
• assessing whether you are suitable to progress to each stage of the recruitment process for a vacant position;
• storing your information for future employment opportunities.

If you do not provide us with the information we request, we will be unable to do one or more of the above.

We may disclose your information to:

• referees or previous employers;
• recruitment agencies or agencies or contractors acting on our behalf;
• our related entities;
• law enforcement agencies to verify whether you have a criminal record;
• educational organisations to the extent necessary to verify your qualifications; and
• immigration attorney to verify your visa status if you are on a working visa.

If we engage third party contractors to perform services for us which involves handling personal information, we will take reasonable steps to prevent the contractor from using the personal information except for the purpose for which it was supplied.

Third party websites

We may offer links to websites that are operated by third parties.  If you visit one of these linked websites, you should review their privacy and other policies.  We are not responsible for the policies and practices of third parties.

Access and Correction of your Personal Information

You may, at any time, request access and correction to any personal information we hold about you by contacting us (refer to Your Legal Rights section below).  If you make an access request, we may ask you to verify your identity and put your request in writing for security reasons.

Customer Confidentiality and Security

Jumbla has strict processes and procedures in place to maintain confidential customer information. 

We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

For more information on these processes and procedures please email info@Jumbla.com.au

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@jumbla.com.au

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or the Office of the Australian Information Commissioner (OAIC - www.oaic.gov.au) - whichever is applicable. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

If you have any questions or complaints about how we handle your personal information, please contact us at:

Jumbla

34 Park Street,

Melbourne, VIC, 3205

Telephone: (03) 9023 9310 (9.00am to 6.00pm, Monday to Friday)

Email: info@Jumbla.com.au