In Australia, we are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). For individuals located within the European Economic Area (EEA), we also comply with the General Data Protection Regulation (EEA) 2016/679 (GDPR). Our representative within the EEA is Playground XYZ EMEA Ltd (UK Company No 10802474) of 2nd Floor Waverley House, 7-12 Noel Street, London, United Kingdom, W1F 8GQ. In the United States, we are subject to the California Consumer Privacy Act which comes into force on January 1, 2020 and applies only to California residents. See CA Civil Code 1798.1000, et seq.
Depending on the activity or services involved, we may collect the following types of personal information:
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
In addition, when you apply for a job or position with us, we may collect certain personal information from you (including your name, contact details, working history and relevant records checks) as part of the application process. We may also collect these types of information about you from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or to engage you under a contract.
We will collect, hold, use, process and disclose your personal information for the purposes set out in the table below. If you are located within the European Economic Area (EEA) and/or United States, the lawful basis for our collection, holding, use, processing and disclosure of your personal information is also set out in this table.
Purpose of collection, holding, use, processing and disclosure
Your consent (if given to us) and
for the performance of a contract with you
For our legitimate interests in operating our business efficiently and effectively
Your consent (if given to us) and performance of a contract with you
Your consent (if given to us) and to keep you informed and updated on topics we understand you have an interest in.
Your consent (if given to us) and for our legitimate interests in operating and promoting our business and rewarding the loyalty of our customers
Your consent (if given to us) and for performance of a contract with you
Your consent (if given to us) and performance of a contract with you
Compliance with our legal obligations and for our legitimate interests in enforcing our contractual and legal rights
Our legitimate interests, performance of a contract and in order to take steps requested by you prior to considering whether to enter into an employment agreement with you
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
We and/or our carefully selected business partners may send you direct marketing communications and information about our products and service if you have consented to receiving these communications. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act, in the UK the Privacy and Electronic Communications (EC Directive) Regulations 2003 and in the U.S., the CAN-SPAM Act. You may opt-out of receiving marketing materials from us by contacting us using the contact method set out here - email@example.com - or by using the opt-out facilities provided in the communication.
We may hold and disclose personal information outside of your country of residence to cloud providers and software providers located outside of Australia, including the United Kingdom, Ireland, Singapore and the United States of America. When you provide your personal information to us, you consent to the disclosure of your information inside or outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles, in case of the United Kingdom will deal with such personal information in accordance with the GDPR, and in the case of the United States will deal with such personal information in accordance with the CCPA.
We may hold and disclose personal information about individuals located outside of the EEA. In particular, our Australian companies may receive personal information that was originally collected by or disclosed to our UK company. Personal information transferred by our UK company to our Australian companies will be undertaken in accordance with an intra-group data transfer agreement that implements standard data protection clauses as permitted under Article 46.2 of the GDPR. Otherwise, our data transfers conform to industry best practices and local law, if any.
In addition, we may disclose personal information to cloud providers (including Google and Amazon Web Services), software providers (Xero and DocuSign), our accountants (Hall Chadwick), and our research partners (Kantar) that are located outside of, or may store personal information outside of, the EEA, including in Singapore, Australia and the United States. When we disclose personal information to these third parties, we do so:
We may collect personal information about you when you use and access our website or a publisher's website that we (or a third party acting on our behalf) is placing advertising on.
While we do not use browsing information to identify you personally, we may record certain information about your use of these websites, such as which pages you visit, the time and date of your visit and the internet protocol (IP) address assigned to your computer or other device. We record your IP address in order to assist us to protect our systems from malicious activities, including denial of service attacks, brute force attempts to access our systems and fraud detection and prevention. We store IP addresses for this purpose for 30 days in order to detect and analyse previous attacks on our systems.
We will store your personal data for up to 5 years after we have completed providing our services to you (or to the business that employs or engages you as a contractor, if applicable). After this time:
If you are located in the EEA or the United States, we do not store images or videos of your face for any period of time; this information is processed locally on your own device and is not retained by us.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and/or loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, if you become aware of a security breach, please notify us immediately at firstname.lastname@example.org.
You can access the personal information we hold about you by contacting us using the contact information provided through the website or using the contact details set out below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us using the details set out below and we will take reasonable steps to ensure that it is corrected.
If you are located within the European Economic Area (EEA), then you also have the following additional rights under the GDPR. We will comply with all of our obligations under the GDPR in respect of these rights.
Where we process any personal information about you on the basis of any consent given by you, you have the right to withdraw your consent at any time by giving notice to us (which you can do using our contact details set out below). We will give effect to your withdrawal of consent promptly and will cease any processing that you no longer consent to, unless we have another lawful basis for that processing. The withdrawal of your consent will not affect the lawfulness of any processing that occurred prior to the date that you notified us that you were withdrawing your consent.
You have a right to information portability, which is the right in certain circumstances to request a copy of your personal information in a structured, commonly used and machine-readable format and to transmit this information to another data controller. You may also request that we erase any personal information that we hold about you which is no longer necessary for any of the purposes that we collected it for, which you have withdrawn your consent in respect of processing, which you are allowed under the GDPR to object to. We will comply with such requests unless we are permitted or required by law to retain that information.
You also have the right to object to our processing of personal information in certain circumstances, including where we process personal information based on our legitimate interests. You can also request that we restrict our processing activities in some circumstances. If you make such a request then we will continue to store your personal information but will not otherwise process your personal information without your consent or as otherwise permitted by law.
If you think we have breached the Privacy Act (if you are located in Australia) or the GDPR (if you are located within the EEA) or the CCPA (if you are in the United States), or you wish to make a complaint about the way we have handled your personal information, you can contact us at email@example.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within the time required by law (if applicable) or otherwise within a reasonable period of time, typically within 30 days. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Playground XYZ is involved with the following organisations:
For the purposes of the GDPR, our representative within the European Economic Area is:
PLAYGROUND XYZ EMEA LTD (UK Company No 10802474)
2nd Floor Waverley House
7-12 Noel Street
London, W1F 8GQ
As our core activities do not consist of processing operations that require regular and
systematic monitoring of data subjects on a large scale, we are not required under GDPR to
appoint a data protection officer.
Scot Liddell - COO
Level 13, 50 Carrington St, Sydney, 2000, Australia.
Effective: 1 November 2022