1. Privacy generally

This privacy policy applies to the handling of personal information by GXE Pty Ltd trading as Startup Galaxy (ABN 23 643 428 693) of Level 15, 500 Bourke Street Melbourne VIC 3000 (Startup Galaxy, we us, our). 

Startup Galaxy understands the importance of protecting an individual’s personal information.  This privacy policy sets out how Startup Galaxy aims to protect your personal information, your rights in relation to your personal information held by Startup Galaxy and how Startup Galaxy  collects, holds, uses, discloses, and otherwise manages, your personal information.

In collecting, holding, using, disclosing and otherwise managing your personal information, Startup Galaxy will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act. 

Startup Galaxy will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time.  Any updated privacy policy will be made available on the Startup Galaxy website, startupgalaxy.com.au, or can otherwise be obtained by contacting us and requesting a copy.

2. Kinds of personal information collected 

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.  During the provision of services, or as a result of our other interactions or dealings with you, Startup Galaxy may collect your personal information.  

Startup Galaxy provides a range of resources to encourage connections within the Australian start-up ecosystem.  We provide users with access to information on start-up companies, investors, accelerator programs and relevant job postings, and we provide a digital tool to allow investors to manage their operations. 

The kinds of personal information that Startup Galaxy collects will vary depending on our particular interaction or dealing with you.  However, generally speaking, the kinds of personal information Startup Galaxy collects may include: 

• contact and general identification information you provide through inquiries or information you submit to us such as your name, address, telephone number, email address, date of birth or other types of verification details;
• specific identification information such citizenship details, tax status and social media profile links;
• information about your financial circumstances and objectives, including your assets, funding preferences and other types of financial data; 
• employment information, such as job application information including your employment and education history, salary preferences and information from referees;
• your credit card information (which may include transactional histories) or information relating to other payment methods; and 
• any other information you provide us from time to time in connection with our services. 

You should not submit personal information to us about other individuals.  If you do so (for example, the names of (and other details about) founders, investors or members in a startup), you must ensure that they are aware of this policy and that you are entitled to submit their personal information.  This includes having the consent of the relevant individuals to the provision of their information to us and their consent to our use and disclosure of their information in accordance with this policy.

Startup Galaxy also collects internet/technology related information from visitors to our site or users of our other online services, including the referring URL, your IP address, which browser you used to come to the site, the country, state or province, the pages of our site that you viewed during your visit and any search terms entered on our site.

Startup Galaxy may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information.  If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law. 

3. How we collect personal information 

Generally, Startup Galaxy collects your personal information directly from you.  For example, Startup Galaxy may collect your personal information:

• when you register or apply for an account with us, request information or services, or otherwise provide us with your details; 
• where you use our website or other online services or otherwise interact with us; 
• when you complete an application form or survey or provide us with any offerings or funding preferences; or
• if you post information to our website or any of our social media sites.

There may be occasions when Startup Galaxy collects your personal information from someone other than you, for example:

• from your bank or other relevant financial institutions in order to provide our services to you; 
• from third parties you authorise to disclose your information to us (including banks and other third party financial services);
• from a publicly maintained record or other publicly available sources of information including social media and similar websites;
• from our vendors or suppliers that help provide our services to you (for example, customer support information, payment information or identity validation); or
• from third parties if you connect to our services, submit an application or register an account with us using an external third-party application, such as Facebook or Google.

Generally, Startup Galaxy will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.  

4. Purposes for which personal information is used

Generally speaking, Startup Galaxy collects, holds, uses or discloses personal information so that we can provide you with information about the Australian start-up ecosystem and related technical services.  

Some examples of the purposes for which Startup Galaxy collects, holds, uses and discloses your personal information include to:

• determine your eligibility for our services; 
• enable us to supply you with information you request from us;
• facilitate the supply of services to you, including communicating with and providing information and offerings to you in relation to start-up companies, accelerator programs, investment opportunities and relevant job opportunities;
• personalise your experience with our services; 
• conduct promotions, competitions, giveaways and events; 
• contact you to obtain your feedback regarding our goods or services or to conduct other market research; 
• undertake direct marketing (as detailed in paragraph 5 below); 
• conduct investigations in cases of fraud, credit or data security risks;
• analyse information we collect so that we can administer, support, improve and develop our business and the services we offer (including by monitoring or recording our interactions with you for training purposes);
• comply with the obligations of Startup Galaxy under any applicable laws; and
• otherwise to appropriately manage and conduct our business, including performing administrative functions.

In addition to the purposes listed above, Startup Galaxy may use your personal information for purposes related to the above purposes, other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law. 

Where personal information is used or disclosed, Startup Galaxy takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.  You are under no obligation to provide your personal information to Startup Galaxy.  However, without certain information from you, Startup Galaxy may not be able to provide services or information to you or may be limited in how we can interact with you.

5. Direct marketing 

In addition to the purposes outlined in paragraph 4 above, Startup Galaxy may use and disclose your personal information  in order to inform you of promotions, competitions, giveaways, events, goods or services that may be of interest to you.  This may include Startup Galaxy disclosing the information to related companies of Startup Galaxy or other entities with which Startup Galaxy has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.  If you do not wish to receive such communications, you can opt-out by contacting Startup Galaxy via the contact details set out in paragraph 12 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.  

6. Disclosure of personal information 

Startup Galaxy discloses your personal information for the purpose for which Startup Galaxy collects it.  As a result, generally, Startup Galaxy will only disclose your personal information for a purpose set out in paragraphs 4 and 5 of this privacy policy.  This may include disclosing your personal information to:

• start-up companies, start-up accelerator programs, other potential investees and other interested parties;
• potential investors;
• related companies of Startup Galaxy;
• other parties who invest in or acquire an interest in Startup Galaxy;
• service providers and contractors and other third parties that provide goods or services to us (including our technology service providers, financial service providers, our business consultants, risk, compliance and identification verification companies, or other business or administration service providers);
• people or entities considering acquiring an interest in Startup Galaxy business or assets;
• Startup Galaxy professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
• government authorities where required by law.

Startup Galaxy may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law. 

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site. 

7. Overseas disclosures

Some of the parties that Startup Galaxy discloses your personal information to may be located outside Australia, including technology service providers located in the United States of America.

We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.  

8. Links to other websites 

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including websites operated by our partners, associates, or independent third parties.  These links are provided as a convenience to you.  Each website has its own privacy practices, as described in that website’s privacy policy.  Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that website.  Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot be and are not responsible for any information that you may submit to that website.

9. Cookies 

When you visit our websites or other online services, we will generally leave a ‘Cookie’ in the memory of your web browser.  The website or other online service may only function properly if Cookies are enabled.  Our websites and online services may use persistent Cookies to authenticate you as a user and display content that is relevant and specific to you.  

Cookies are very small files that store information about your visit to and use of a website.  Most major commercial Internet sites use them and they make your Internet-surfing more useful and less time-consuming because they store information that is reusable each time you visit our website, such as birthday and other preferences you have chosen to share with us.  

Cookies cannot access and read the files on your hard drive.  They do allow us to provide information and products that are more meaningful to you without asking you the same questions every time you visit us.  You may get Cookies from our advertisers.  We cannot pre-screen these Cookies since they come directly to you from other sites.  We hope you will want the better service that Cookies allow, but if you prefer, you can set your browser to refuse Cookies.  However by doing that, your access to our website, startupgalaxy.com.au, may be compromised or limited. This may also affect the provision of certain services through our website.

10. Security of personal information

Startup Galaxy takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.  

Startup Galaxy holds personal information in electronic forms in secure databases on secure premises, accessible only with the appropriate passwords by authorised staff.  

The processes and systems we use to secure your personal information include:

1. the use of identity and access management technologies to control access to systems on which information is processed and stored;
2. requiring all employees to comply with internal information security policies and keep information secure;
3. requiring all employees to complete training about information security; and
4. monitoring and regularly reviewing our practise against our own policies and against industry best practice.

Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access. 

We have in place procedures for training our employees about their obligations under this privacy policy. We also have in place internal procedures to confirm general company compliance with this privacy policy.

Startup Galaxy will destroy or de-identify personal information in circumstances where it is no longer required, unless Startup Galaxy is otherwise required or authorised by law to retain the information.  

All transmissions of your credit card information are encrypted.

11. Access and correction

Startup Galaxy takes steps reasonable in the circumstances to ensure any personal information it holds is accurate, up-to-date, complete, relevant and not misleading.  

In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Startup Galaxy.  If at any time you would like to access or correct the personal information that Startup Galaxy holds about you, or you would like more information on Startup Galaxy’s approach to privacy, please contact Startup Galaxy using the details set out in paragraph 12 below.  Startup Galaxy will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.  

To obtain access to your personal information:

• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
• Startup Galaxy requests that you be reasonably specific about the information you require; and
• Startup Galaxy may charge you a reasonable administration fee, which reflects and will not exceed the cost to Startup Galaxy for providing access in accordance with your request.

Startup Galaxy will endeavour to respond to your request to access or correct your personal information within 30 days from your request.  If Startup Galaxy refuses your request to access or correct your personal information, Startup Galaxy will provide you with written reasons for the refusal and details of complaint mechanisms. 

If you are dissatisfied with our refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner. 

12. Contacting Startup Galaxy

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Startup Galaxy using any of the following contact details:

Email: [email protected]

Website:  startupgalaxy.com.au

13. Privacy complaints

Please direct all privacy complaints to Startup Galaxy.  At all times, privacy complaints:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect the commercial arrangements between you and Startup Galaxy.

Startup Galaxy will acknowledge your complaint within 14 days of receipt and endeavour to resolve it within 30 days, unless Startup Galaxy informs you otherwise and seeks your agreement in writing. 

Startup Galaxy will commence an investigation into your complaint.  You will be informed of the outcome of your complaint following completion of the investigation.  In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Startup Galaxy will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.