Your privacy is important to us, and so is our responsibility to be transparent about how we collect, use and share information about you. We are bound by the Australian Privacy Principles contained in the Privacy Act, and observe applicable principles of the GDPR.
When using the products and services provided by Drawboard we may record and use your personal data. Personal data means any information relating to an identified or identifiable natural person. The data, including personal data, that we collect includes:
For personal data subject to the GDPR, we rely on several legal bases to process the data. These are:
You may at any time refuse to provide the personal data that we request; however, this may limit or prohibit our ability to provide our products and services to you. You may withdraw your consent for us to process your personal data at any time by contacting us in accordance with our ‘Contact us’ section below.
Due to the work-related nature of our services we do not knowingly advertise or collect personal data from any individual under the age of 16. If we later find out that we have collected personal data from an individual under the age of 16, we suspend and remove this personal data immediately.
We use the personal data we collect from you to:
The above provides a high level view of how and why we collect your personal data. So let’s take a deep dive into those areas where we gather and use this data.
Like many websites, www.drawboard.com and app.bullclip.com collect certain information through the use of “cookies”, web beacons, device identifiers, pixels and other technologies to provide functionality and to recognize you across different services and devices. This includes both users of our products and services and non-users.
Cookies are small text files that are saved by your browser when you access our site. We may use both session cookies (stored for individual visits to the website) and persistent cookies (stored over time) to identify that you’ve visited or logged in to a site and to tell us how and when you interact with our site.
Unlike persistent cookies, session cookies are deleted when you log off from the site and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of our products and services.
If you live in the European Economic Area or Switzerland (the ‘Designated Countries’), you must opt in to cookies collected on www.drawboard.com for us to use them for non-critical tracking. You can do this by accepting the notice that appears on your screen when you first visit the website, or by visiting www.drawboard.com/terms
Our servers may automatically record certain information about how a person uses our products and services.. This information is collected from the Drawboard PDF Windows 10 (W10) application, and the Bullclip web application, Bullclip W10 application and Bullclip iOS application. This information may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features to which a user browsed and the time spent on those pages or features, the frequency with which the site is used by a user, search terms, the links on our site that a user clicked on or used, and other statistics. If you have cookies enabled on your web browser, we are usually able to connect your product behaviour to your anonymous behaviour on www.drawboard.com.
We use this information to administer our products and services and we analyze (and may engage third parties to analyze) this information to improve and enhance the products and services by expanding their features and functionality and tailoring it to our users’ needs and preferences.
If you opt to have your Bullclip account deleted, audit logs of your activity in the service will be retained. These logs are a core part of the service provided by Bullclip. In the same vein, we recommend that all our clients have employment contracts with their employees that provide a basis for data retention in this manner.
Drawboard does not respond to “Do Not Track” browser signals or other similar mechanisms.
Third parties may also collect personal information about your online activities over time and across sites when you visit the sites or use our services.
You may choose to submit your email address or other contact information via our website, products, services, support sites or via our partners. We may use this information to send you news about Drawboard services, products or promotions.
We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.
We will give you the ability to opt out of marketing-related emails by clicking on a link at the bottom of each marketing-related e-mail we send you.
In some of our communications, we use tracking means, such as a “click-through URL” linked to content on our websites. We track this data to help us measure the effectiveness of our customer communications.
Drawboard may collect and analyze data (but not personal data) about the performance of its products and services. From time to time, Drawboard may release data (but not personal data) in the aggregate, e.g., by publishing a report on trends in the usage of its products and services.
If you purchase subscriptions to Bullclip from our site, we request that you provide your name, email address, billing address, credit card information, telephone number and other information necessary to open your account and complete the transaction. We do not collect or store any of your credit card information. Our credit card processing service provider (who is a PCI DSS Level 1 certified service provider) will collect and store full payment card information from you to pay for the service.
When transacting on the Microsoft Store or Apple Store, your card data is handled by Microsoft Corporation or Apple Inc or as otherwise set out in their privacy policies, separate to Drawboard, and we do not see nor store your card data.
When transacting via PayPal your card data is not seen nor stored by Drawboard. A record of the sale is recorded in our systems along with some additional personal data but this is not related to your credit card details.
When you apply for a role at Drawboard we may collect personal data to enable us to effectively communicate and progress you through our hiring process. This data will be limited to information that we absolutely need to ensure Drawboard is the best match for you.
Outside of authorised personnel employed by Drawboard, we only disclose personal data to third-parties that meet our data privacy conditions (as guided by the Australian Privacy Act and the GDPR). When this occurs, it occurs in a secure and contractually-regulated manner. These third parties include:
We may also share or publish aggregate information that does not specifically identify you, such as statistical information about how our users use our products or their demographic characteristics.
The European Commission has the power to determine, on the basis of the GDPR, whether a country outside the European Union offers an adequate level of data protection by making an ‘adequacy decision’. To date, the European Commission has not adopted an adequacy decision in respect of Australia. Instead, we rely on other legal bases to lawfully transfer personal data around the world (including transfers to countries like Australia where an adequacy decision has not been adopted). These bases include your consent and the European Commission-approved model contractual clauses, which require certain privacy and security protections. You may obtain a copy of the model contractual clauses by contacting us in accordance with the ‘Contact us’ section.
Our services may contain links to other websites and services. The fact that we link to a website or service is not an endorsement, authorization or representation that we are affiliated with that third party.
We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit and services you use.
We may make available on our site, or link to, certain opportunities for our customers and other users to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.).
Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information.
By posting personal information online in public forums, you may receive unsolicited messages from other parties.
All Bullclip account holders may access, review, update, rectify or delete their personal data in their profile by logging into their account. Removing your information may limit our ability to provide the service to you. If you opt to completely delete all such information, your account will be deactivated and you will lose access to the service.
All Drawboard PDF users may access, review, update, rectify or delete their personal data by contacting us.
You may contact us directly to request data modification outside of our services or if you have additional questions. We’ll take reasonable steps to provide, modify or delete your information as soon as is practicable, but some information may remain in archived/backup copies for legal reasons or to prevent harm, including as described in our ‘Who do we disclose information to?’ section.
You may also contact us directly to receive (in a commonly used file format) the personal data you have provided to us.
We may limit or reject your request in certain cases, including without limitation where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, where the rights of other persons would be violated, or as required by law.
We will respond to all requests within 30 days.
If you need further assistance regarding your access and control of your personal data, please contact our Data Protection Officer and we will consider your request in accordance with applicable laws.
If you reside in a Designated Country and are unhappy with our data practices, you also have a right to lodge a complaint with your local data protection authority.
The security of your personal data is important to us. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it (including encrypted storage and password protection).
Each of our employees is aware of our security policies, and your information is only available to those employees who need it to perform their jobs.
No method of transmission over the Internet using industry standard technology is 100% secure. Therefore, we cannot guarantee the absolute security of your information.
For more information, please see the Drawboard Approach to Security document at www.drawboard.com/terms.
We keep your account information, like your name and email address, for as long as your account is in existence because we need it to operate the accounts you have with us. We keep other data, including information about how you use our products and services, until you request that we delete this data because we use this data to provide our products and services to you and for the other purposes set out in the ‘How we use Personal Data’ section above.
Our head office is located here: Level 4, 99 Queen Street, Melbourne, 3000, Australia