Last updated: 21 July 2020
Cubbei Studios is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We value your trust and take our privacy obligations seriously. We have developed this policy to explain how we met these obligations across the services we provide.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au.
Cubbei Studios, "we", "us" and "our" refers to staff or contractors of Cubbei Studios.
"Member", "Streamer(s)", "Account Holder", "Client", "User", "you", "your" refers to a person or entity that has engaged with the Jarvis platform on either the website, twitch.tv (via IRC) and the Discord platform (or Discord App) by creating an account. The client may also be someone authorised to act on your behalf (e.g. a moderator or community manager).
"Persona", "username" or "handle" refers to the name used to identify you on a plaform.
"Moderator" or "Community Manager" refers to a person or persons with authority to act on your behalf as defined by you in your community.
"Chatters", "Participants", "Community" and "Community Memebrs" refers to members of your twitch chat and discord server (guild).
"Community" refers the people or entities that follow, interact with and contribute to stream and discord server.
"Jarvis", "JarvisOnTwitch", Jarvis for Twitch and Discord, "Jarvis Platform" and "Jarvis Chatbot" means the services provided by us to you through the various Jarvis personas across the web, twitch.tv and discord.
Personal information is information or an opinion that identifies an individual. Examples of Personal Information include names, email addresses and phone numbers.
Raw data refers to data that has been collected but not processed or presented to convey information or meaning.
System administrator means Cubbei Studios staff or third party hosting providers that have access to administrative portals or underlying back-end systems and infrastructure.
2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
The information we collect about you depends on how you interact with us.
Information we collect generally
- If you chat or send messages where a Jarvis persona is present your persona and message content may be collected for logging and service delivery purposes.
- If you use our contact form or contact us directly the data you provide, such as contact information (names, email address and telephone numbers) and the nature of your enquiry.
- If you provide services to us we may collect contact and account information from suppliers, contractors and other third party service providers.
- If you attend our physical offices or events your name and contact information may be collected for visitor records and dietary preferences where catering is provided. In some cases, CCTV footage may be recorded for security purposes. We may also take photo, video and audio recordings at events for use in marketing materials.
Information you provide on social media sites
We use various social media platforms primarily for marketing and recruitment activities. While we are responsible for the content we publish on these social media platforms, we are not responsible for any customised notifications you make (these include "live" and "stream" announcements) or for managing the platforms and for the privacy and processing of your data on them. That includes any ‘likes’, ‘comments’, visits or other interactions with our content. You should familiarise yourself with the privacy policies and controls available directly from the social media platform providers.
Collection of sensitive information
Sensitive information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Generally, we do not intentionally collect sensitive information about either current or prospective clients. However, as the nature of our services is broad and varied, there may be times when this is required. In cases where sensitive information is provided to us, we will take all reasonable steps to ensure that the necessary consent has been obtained and that the data is securely protected.
3. HOW DO WE USE YOUR PERSONAL INFORMATION?
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
We collect Personal Information for the following primary purposes:
- To provide products and services to our clients;
- To maintain contact with past, present and prospective clients and provide thought leadership, information about our services and invitations to events that we believe may be of interest;
- To enable us to respond to enquiries from individuals;
- For seeking feedback in the development and improvement of our services;
- To comply with legal or regulatory obligations;
- For managing our business such as billing, account keeping, recruitment, employment and security matters; and
- For other purposes, which we outlined at the time we collected it.
We may, from time to time, collect Personal Information in order to market our services. You may unsubscribe from further marketing material at any time by using the ‘unsubscribe’ function where available in our communications or by contacting us (see section 9).
In some cases, we may use Personal Information that has been de-identified and/or aggregated, such that an individual can no longer be reasonably identified, for the purposes of data analytics, research and product improvement.
4. WHO DO WE DISCLOSE YOUR INFORMATION TO?
We do not disclose or sell your Personal Information to third parties for targeted advertising purposes without your consent. We may disclose Personal Information to the following people and companies for the purposes set out in section 3:
- Third parties including subcontractors, suppliers and partners we engage to support the delivery of our services or business operations, such as technology and accounting providers
- Law enforcement, regulatory or government agencies or other third parties where required or authorised by law; and
- Other third parties where you have consent to their use at the time we collected your Personal Information.
5. HOW DO WE STORE AND PROTECT YOUR INFORMATION?
Protection of Personal Information
We use a combination of administrative, technical and organisational measures when storing and processing Personal Information to in order to provide reasonable protection from misuse, loss or unauthorised access, modification or disclosure. Such measures include:
- Education and training of staff so they are aware of procedures to securely handle data;
- Technical and administrative controls to restrict unauthorised access to data;
- Technical controls implemented by us and our technology providers, such as encryption, anti-virus, firewalls, logging and monitoring; and
- Physical security controls such as security access passes, CCTV and locked cabinets.
Retention of Personal Information
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. Personal Information collected for the purpose of providing our services and managing our business is typically retained for a minimum period of seven (7) years unless a request is made to delete it per section 6.
Transfer of information outside of Australia
It is our policy that records containing Personal Information are stored within Australia wherever it is commercially feasible. However, some specialist software applications we use involve the storage and processing of data at overseas locations, including our accounting, customer relationship management and training systems. These locations include, but are not limited to, the United States, Singapore, and Europe.
6. HOW CAN YOU ACCESS OR CORRECT YOUR PERSONAL INFORMATION?
Making a request
You may request a copy of the Personal Information we hold about you or request that we update or correct it. In some rare cases we may refuse access to certain information, for example due to commercial sensitivity or legal reasons. In such a case we will write to you explaining our decision.
You may also request that we delete your Personal Information, in which case we will take reasonable steps to identify and permanently remove it from our systems unless it is required for legal or compliance needs.
To make any of these requests, please see section 9 for details on how to contact us.
Fees and timing
We will not charge any fee for your requests. Please allow up to 28 calendar days for us to process your request.
Proof of identification
In order to protect your Personal Information we may require identification from you before processing your request.
7. HOW IS THIS POLICY UPDATED?
This policy may change from time-to-time to reflect changes to our business, however, the latest version of this policy can be accessed on our website. We will amend the revision date at the top of this page to indicate when we have made changes.
8. HOW CAN YOU MAKE A PRIVACY COMPLAINT?
If you are concerned about how we have handled your Personal Information and wish to make a complaint, please contact us using the details provided in section 9. We will endeavour to investigate and respond to your complaint within 28 days. If this is not possible, we will contact you with a revised timeline for our full response.
If you are not satisfied with how we have handled your complaint, you can contact the Office of the Australian Information Commissioner (OAIC):
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
9. HOW DO YOU CONTACT US?