Our Privacy Policy
Updated 01 January 2022.
1 - Purpose Of Our Policy
1.1 Who is Henri ABN 41 571 367 853 (we, us or our) has adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:
(a) Providing the services and systems that we offer; and
(b) The normal day-to-day operations of our business.
1.2 This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act).
1.3 By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.
2 - Who And What This Policy Applies To
2.1 Our Privacy Policy deals with how we handle “personal information” as it is defined in the Privacy Act (Personal Information).
2.2 We handle Personal Information in our own right and also for and on behalf of our customers and users.
2.3 Our Privacy Policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies which we store.
2.4 The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.
2.5 If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.
3 - The Information We Collect
3.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:
(a) Personal Information. We may collect personal details such as an individual’s name, location, date of birth, nationality, family details and other information defined as “Personal Information” in the Privacy Act that allows us to identify who the individual is;
(b) Contact Information. We may collect information such as an individual’s email address, telephone number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
(c) Financial Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
(d) Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
(e) Information an individual sends us. We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities.
3.2 We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.
3.3 We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.
4 - How Information Is Collected
4.1 Most information will be collected in association with an individual’s use of Who is Henri, an enquiry about Who is Henri or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
(a) Registrations/Subscriptions. When an individual registers or subscribes for a service, list, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;
(b) Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
(c) Supply. When an individual supplies us with goods or services;
(d) Contact. When an individual contacts us in any way;
(e) Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or
(f) Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.
4.2 As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
4.3 Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.
5 - When Personal Information Is Used & Disclosed
5.1 In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected without the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
5.2 We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
5.3 If it is necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, we will inform you that we intend to do so, or have done so, as soon as practical.
5.4 We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.
5.5 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
(a) The provision of goods and services between an individual and us;
(b) Verifying an individual’s identity;
(c) Communicating with an individual about:
(d) Their relationship with us;
(e) Our goods and services;
(f) Our own marketing and promotions to customers and prospects;
(g) Competitions, surveys and questionnaires;
(h) Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or
(i) As required or permitted by any law (including the Privacy Act).
5.6 There are some circumstances in which we must disclose an individual’s information:
(a) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
(b) As required by any law (including the Privacy Act); and/or
(c) In order to sell our business (in that we may need to transfer Personal Information to a new owner).
5.7 We will not disclose an individual’s Personal Information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of Australia will not be made until that entity has agreed in writing with us to safeguard Personal Information as we do.
5.8 We may utilise third-pay service providers (such as Gmail from Google, Inc., and MailChimp from The Rocket Science Group LLC) to communicate with an individual and to store contact details about an individual. These service providers are located in the United States of America.
6 - Opting “In'“ Or “Out”
6.1 An individual may opt to not have us collect their Personal Information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:
(a) Opt In. Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or
(b) Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.
6.2 If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.
7 - The Safety & Security Of Personal Information
7.1 We may appoint a Privacy Officer to oversee the management of this Privacy Policy and compliance with the Australian Privacy Principles and the Privacy Act. This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.
7.2 We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.
7.3 Who is Henri uses SSL encryption to store and transfer Personal Information. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
7.4 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
7.5 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
7.6 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
8 - How To Access And/Or Update Information
8.1 Users of Who is Henri can update their Personal Information from within their Who is Henri account or profile.
8.2 Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.
8.3 If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.
8.4 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
8.5 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.
9 - Complaints And Disputes
9.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.
9.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
9.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
10 - Contacting Individuals
10.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
11 - Contacting Us
11.1 All correspondence with regards to privacy should be addressed to:
The Privacy Officer
Who is Henri
privacy@whoishenri.com
You may contact the Privacy Officer by email in the first instance.
12 - Additions To This Policy
12.1 If we decide to change this Privacy Policy, we will post the changes on our webpage at http://www.whoishenri.com. Please refer back to this Privacy Policy to review any amendments.
12.2 We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.
13 - GDPR Compliance
13.1 Collection of Data
We process Data you provide directly to Us, in particular when you complete a data collection form.
For example, we collect Data when you create an account, use the Services, participate in a contest or promotion, register for an event or an online course, apply for a job, request customer support or otherwise communicate with Us.
The Data may include the following data as well as any other type of information that we specifically request you to provide to Us through Our collection forms, such as:
name
email address,
postal address,
phone number.
We use other third parties, such as a credit card processing company to bill you for services. When you sign up for our services, we will share your personal information only as necessary for the third party to provide that service.
14 - Information We Collect Automatically Through Cookies And Other Tracking Technology
We may use cookies, web beacon and other similar technologies on our online Services to collect information and provide you with the services or products that you have requested.
A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and which is used to record information related to the navigation or the use of a device or a website.
A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags (also known as “tracking pixels”). It may be used in Our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.
We use cookies and other similar technologies to collect information for the purposes described in this Privacy Policy. We may also combine the information collected by these technologies with information we have collected about you by other means that are described in this Privacy Policy.
Some of the cookies are used for the exclusive purpose of enabling or facilitating communication or are strictly necessary for the provision of Our Services.
These are essentially of session cookies for authenticating and connecting to the Services, as well as memorizing navigation items during a session.
You have the ability to decline cookies by changing the settings on your browser but this might prevent you from benefiting from some elements of the Services. You can also consult or destroy cookies if you wish, since they are stored on your hard disk.
We may also use these technologies for other purposes than the Services operation such as:
To improve Our Services;
To remember you, for your convenience, when you visit Our Services;
To provide you with advertising tailored to your interests;
We inform you, in particular, that We use Google Analytics to collect information about use of Our Services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. We inform you that Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit Our site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. For more information on Google Analytics, please visit Google Analytics.
Who is Henri also uses social media including but limited to LinkedIn and Instagram which may utilize your core profiling information to target an online advertisement of our products and services to you.
15 - Minors
We do not collect data from Persons under 18 year of age. All Users must warrant that they are above 18 years of age through agreement to our Terms of Service.
16 - How We Use The Data
We may use information about you for the following purposes:
Provide, maintain and improve Our Services;
Provide and deliver the Services you request, process transactions and send you related information, including confirmations and invoices;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Communicate with you about products, services, offers, promotions, rewards, and events offered by Who is Henri and others, with your prior consent, and provide news and information we think will be of interest to you;
Monitor and analyse trends, usage and activities in connection with Our Services;
Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
Process and deliver contest entries and rewards;
Link or combine with information we get from others to help understand your needs and provide you with better service; and
Carry out any other purpose for which the information was collected, and which is necessarily contemplated by the collection of such information or is otherwise explicitly mentioned in the process of collection.
According to the Regulation, each Data processing is performed on one of the following legal basis:
Your consent;
The performance of the Service subscribed by you.
The legitimate interests pursued by Us or by a third party, except where such interests are overridden by your interests or your fundamental right and freedoms.
17 - The Period Of Data Retention
Data are retained in a form that allows your identification for a period no longer than is necessary for the purposes for which they are obtained and processed.
Who is Henri will retain your data on file until you actively elect to have your data removed from our records by means of unsubscribing.
18 - Online Complaint
In compliance with the Privacy Shield Principles, We commit to resolve complaints about our collection or use of your Data. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Us at:
19 - Security
We are committed to taking appropriate measures designed to keep your Data secure. Our technical, administrative and physical procedures are designed to protect Data from loss, theft, misuse and accidental, unlawful or unauthorized access, disclosure, alteration, use and destruction. We follow generally accepted standards to protect the personal information submitted to Us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact Us at sayhello@whoishenri.com
20 - Your Rights
According to the Data Protection Act of January 6th, 1978, and the regulation 2016/679 of the European parliament and of the council of 27 April 2016 (the “Regulation”), you have – at any time – a right of access, rectification, opposition on legitimate grounds and limitation where appropriate, as well as the right to define guidelines related to the fate of your Data after your death.
You also have the right to receive Data which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under conditions and in accordance with the Regulation.
You may exercise your rights by contacting Us in writing, with a proof of your identity, at the address provided in the “Contact Us” section below or at the address provided in our Data collection form. We inform you that you also may update, correct or delete by yourself your account information by logging into your online account.
Especially regarding promotional or sales communications, you may opt out of receiving promotional or sales communications from Who is Henri by following the instructions provided in those communications or by sending an email to sayhello@whoishenri.com. If you email Us to unsubscribe from Our commercial email messages, please include the word “UNSUBSCRIBE” in the email subject line. Please note that if you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or Our ongoing business relations.
You can also contact Us by sending an email to sayhello@whoishenri.com to request to be removed from mailing lists.
Finally, you have the right to lodge a complaint with a supervisory authority.
Contact Us
If you have any questions about this Privacy Policy, please contact us.