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When To Seperate ("WTS") Online Privacy Policy

(Last updated January 14, 2007)

WTS has established this Privacy Policy to explain how it protects and manages the personal information that it collects from you (the customer) online. 

1.  Consent for Collection, Use and Disclosure
Your use of the WTS site and/or your registration for WTS products and services constitute your consent to the terms of this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please do not use the WTS site.

WTS may occasionally update this Privacy Policy. When it does, WTS will also revise the “last update” date at the top of this Privacy Policy. In addition, WTS will seek a customer’s prior consent, by email, for any new uses or proposed disclosures of information collected from the customer prior to the change.  WTS will notify customers by email of changes to this policy that will affect information collected from them in the future.  In certain circumstances, however, WTS will not inform and obtain the consent of the customer, such as in connection with an investigation of a breach of an agreement, contravention of laws, an emergency where the life, health or security of an individual is threatened, the collection of a debt or in compliance with the request of a law enforcement agency or a court order.

A customer may withdraw his or her consent for collection, use and disclosure at any time by sending an email to unsubscribe@whentoseparate.com. Please note that, if you do, WTS may suspend its provision of products and services to you. When you unsubscribe, if you fall within the guarantee period for any WTS product and you request a refund, the guarantee will be honoured.

2. Accountability
WTS collects, at the time of your registration and your sign-on to its web site, certain “personal information” (information that personally identifies you) including but not limited to your name, email address, home or work address, telephone number, and information about your computer hardware and software (e.g., IP address, operating system, browser type, domain name, URL, access times, and referring web site addresses).

WTS has implemented this Privacy Policy to protect personal information received from its customers, and to respond to any inquiries.  The Privacy Policy also provides that WTS will use appropriate contractual means to establish a comparable level of protection for personal information which is sent for processing by third parties on WTS’s behalf.

WTS has designated responsibility for your personal information to its Privacy Officer, who ensures compliance with the principles in this Privacy Policy.  Other WTS individuals may be delegated to act on behalf of the Privacy Officer.

3.  Purposes for Collecting Personal Information
WTS collects and uses personal information for the following Identified Purposes:

  • to understand customer needs regarding WTS’s services;

  • to develop and provide our web site and our products and services for our customers;

  • to fulfill your requests for products, services or information;

  • to communicate with customers and site visitors, when necessary, and to inform customers of upgrades, as well as of other products and services available from WTS, its affiliates and third parties;

  • to allow customers to access limited-entry areas of WTS’s site;

  • to personalize some of our services and products for you and to deliver targeted advertisements and offers from WTS and third parties;

  • to bill accounts and maintain payment records;

  • to comply with any applicable law, regulation, legal process or government request;

  • to respond to a legitimate claim, or to address our reasonable belief, that you are violating the rights of any third party or any of the agreements or policies that govern your use of the WTS site or any WTS product or service;

  • to protect the services, products or rights of WTS, including but not limited to the security or integrity of the WTS site; and

  • to identify and resolve technical problems concerning WTS’s site, products and services.

WTS also uses personal information in an aggregate form (i.e., not individually attributable to you) for its business analysis, operational, marketing and other promotional purposes.

If we hire other companies to provide some products or services on our behalf, then we will only provide those companies the personal information they need for the Identified Purposes, and we will limit their rights to use and further disclose your personal information as appropriate in the course of their work for us.

4.  Limiting the Collection of Personal Information
WTS limits its collection of personal information to only that information which is necessary for the Identified Purposes.  WTS does not direct its site to, nor does it knowingly collect any personal information from children under the age of thirteen.

When you visit the WTS web site, a cookie may be placed on your computer or the cookie may be read if you have visited the WTS site previously.  WTS uses cookies to allow WTS to determine which products and services you have already purchased so that WTS does not provide redundant information to you, and, if you are a WTS affiliate, to track WTS sales made to customers referred by you so that you can receive compensation under our affiliate program.  If you choose to not have your browser accept cookies from the WTS web site, you may not be able to view all the text on the screens, or to experience a personalised visit, or to subscribe to certain service and product offerings on the WTS site.

5.  Disclosure, Processing and Retention
WTS does not sell, rent or disclose your personal information to anyone else, except:

  • to someone you have designated to act as your agent, for one or more of the Identified Purposes (listed in Section 2, above);

  • to WTS’s employees, independent contractors, subsidiaries, affiliates, consultants, business associates, service providers, suppliers and agents, acting on WTS’s behalf for any of the Identified Purposes;

  • as necessary if WTS has reason to believe that disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with WTS’s rights or property, other users of WTS’s web site, products or services, or anyone else that could be harmed by such activities;

  • and to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.

In addition, as we continue to develop our business, we or our affiliates may sell or buy other businesses or entities, or we may merge with another company. In such transactions, personal information may be one of the transferred business assets. Also, in the event that WTS or substantially all of its assets are acquired, your personal information may be one of the transferred assets.

Your information may be stored and processed in the United States, or in any other country in which WTS or its affiliates, subsidiaries or agents maintain facilities.  By using this web site, you consent to any such transfer of information outside of your country. 
After your account becomes inactive (that is, if you request to be removed from our database), WTS will keep your personal information in its archives.  Your information will then be used only as necessary for tax reasons or to prove WTS’s compliance with any applicable law.

6.  Accuracy of Personal Information
WTS will use reasonable efforts to keep customer personal information accurate for the Identified Purposes, and for minimizing the possibility of making inappropriate customer decisions based on such information. Customers are responsible for informing WTS about changes to their personal information. You can do this by calling emailing support@whentoseparate.com. WTS will use new or updated personal information it receives from customers to update its own records.

7. Security Safeguards
IMC will use reasonable efforts to protect customers’ personal information.

8.  Access to Personal Information
WTS will afford you a reasonable opportunity to review the personal information in your file, if you so request by writing to:

Customer Service
When To Separate
PO Box 5042
Middle Park
Melbourne, Victoria,
Australia 3206

If WTS is not able to provide access to some aspect of a customer’s personal information, it will provide reasons for denying access such as; that by doing so would likely reveal personal information about a third party, or that it is confidential commercial information or attorney–client privileged communications, or that the information relates to a breach of an agreement or a contravention of law, or that its disclosure could reasonably be expected to threaten the life or security of another individual.

Customers have the right to request that inaccurate or incomplete information be amended as appropriate, by contacting WTS or the Privacy Officer as described above.  WTS will promptly correct such personal information. 

 

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