Ralli | Privacy Policy

Privacy Policy

Last updated February 12, 2020

In the course of operating this Online Platform and providing the facility to have conversations about buying or renting products, goods and services, Pricemaker Limited ("Pricemaker"), the owner and operator of Ralli, may collect, use, disclose and hold information about identifiable individuals ("Personal Information").

This Privacy Policy describes the Personal Information collected by Pricemaker or the Online Platform and describes the purposes for which Pricemaker may use, disclose or hold such Personal Information.

  1. Definitions

    1. In this Privacy Policy, the following terms will have the following meanings:

      "Direct Marketing Information" means marketing or promotional information about products, goods or services of Pricemaker or third parties;

      "Member" means a registered business;

      "Offer" means an offer made by a Registered Business to negotiate the purchase or rental of a Product, Good, or Service contained in a Product, Good, or Service Description on the price and other terms specified in that offer;

      "Online Platform" means the online platform known as "Ralli" comprised of the internet and mobile websites located at https://ralli.app, the downloadable software applications called "Ralli" and designed for use on smart-phones and tablets ("Apps") and any other electronic internet-based or online means through which the Services are offered by Pricemaker from time to time;

      "Product, Good, or Service" means the products and/or goods and/or services and/or property in a Product, Good, or Service Description that a Registered Businesses Customer is interested in buying or renting from a Registered Business;

      "Product, Good, or Service Description" means the product, good or service description that a Registered Businesses Customer has posted on the Facebook Messenger platform for a Product, Good, or Service that the Registered Businesses Customer wants to buy or rent, and for which Registered Businesses may make Offers;

      "Registered Business" means a business that Ralli and Pricemaker has accepted as a registered business of the Ralli platform;

      "Registered Business Customer" means a person who has used Facebook Messenger to engage with the Registered Business; and

      "Visitor" means a person that uses or browses any part of the Online Platform, but who is not a Member.

  2. Visitors to Ralli's Online Platform

    1. If you are a Visitor, during your visit to any part of Ralli's Online Platform, Ralli may collect statistical data about your visit, such as the date, time and length of your visit, your location, the URLs or addresses of the internet or mobile website pages you visit, the operating system, browser, search engine and IP address used by the computer, smart-phone, tablet or other device you are using to connect to the internet or Online Platform, and any domain name from which you are accessing the internet. This information is collected by third party software operating on Ralli's Online Platform.
    2. Pricemaker uses and discloses such statistical data for the following purposes:
      1. to obtain information about the traffic on, and the demographics of users of, all parts of Ralli's Online Platform;
      2. to sell and measure the effectiveness of advertising on Ralli's Online Platform;
      3. to identify user behaviour and trends on Ralli's Online Platform;
      4. to identify sales trends for products on Ralli's Online Platform;
      5. to maintain and optimise the technical performance, operation and security of Ralli's Online Platform; and
      6. targeting advertising and promotional messages displayed on the Online Platform.
    3. Pricemaker may disclose such statistical data to others, including businesses, but only on an aggregated basis and in a way that ensures that no individual is identifiable from such data.
    4. If you are a Visitor, Pricemaker will not use Personal Information about you collected by Ralli or Ralli's Online Platform to send Direct Marketing Information to you, unless you have expressly agreed to Pricemaker sending Direct Marketing Information to you. If you want Pricemaker to stop sending Direct Marketing Information to you, you can contact Pricemaker at any time to ask Pricemaker to stop sending you such information. You can either contact our Privacy Officer privacyofficer@ralli.app or use the "Unsubscribe" facility at the bottom of any Direct Marketing Information email or electronic communication that Pricemaker sends you.
  3. Members

    1. If you are a Member, or an employee or other personnel of a Member, during the process of registering as a Registered Business, you will provide Ralli and Pricemaker with Personal Information, for example, email addresses, phone numbers, and names. Pricemaker may also collect other Personal Information during the course of your relationship with Ralli, either directly from you, from third parties, from other Members or from your use of the Online Platform.
    2. If you do not provide the information requested by Pricemaker or Ralli, Pricemaker may not be able to register you as a Member of Ralli.
    3. Pricemaker will use, disclose and hold such Personal Information for the purposes of:
      1. establishing, operating and maintaining the memberships, accounts, Product, Good, or Service Descriptions, Offers and conversations (as applicable) of Members;
      2. providing Ralli services to Members, including operating conversations on Ralli's Online Platform;
      3. contacting Members about their memberships, accounts, Product, Good, or Service Descriptions, Offers and conversations (as applicable);
      4. arranging billing, payment, credit checks, reference checks and verifying identities, locations and business operations (as applicable);
      5. gauging customer satisfaction and providing customer services;
      6. providing technical support and administration;
      7. maintaining Ralli's records;
      8. legal compliance and to comply with requests from law enforcement or governmental agencies;
      9. enforcing Ralli's various terms and conditions and policies;
      10. enforcing or protecting the rights or property of Pricemaker, its Members or others;
      11. addressing feedback or complaints and resolving disputes;
      12. reporting to you about Product, Good, or Service Descriptions, Offers or conversations that you are involved in; and
      13. sending you Direct Marketing Information, if you have expressly agreed to Pricemaker sending it to you.
    4. If you want Pricemaker to stop sending Direct Marketing Information to you, you can contact Pricemaker at any time on the Ralli Online Platform to ask Pricemaker to stop sending such information. You can either contact our Privacy Officer privacyofficer@ralli.app or use the "Unsubscribe" facility at the bottom of any Direct Marketing Information email or communication that Pricemaker and Ralli sends you.
    5. In addition to Personal Information, if you are a Member, during any visit to any part of Ralli's Online Platform or after you have downloaded the App, Ralli may collect statistical data about you or your visit, such as the date, time and length of your visit, your location, the URLs or addresses of the internet or mobile website pages you visit, the operating system, browser, search engine and IP address used by the computer, smart-phone, tablet or other device you are using to connect to the internet or Online Platform, and any domain name from which you are accessing the internet. This information is collected by third party software operating on Ralli's Online Platform.
    6. Pricemaker uses and discloses such statistical data for the following purposes:
      1. to obtain information about the traffic on, and the demographics of users of, all parts of Ralli's Online Platform;
      2. to sell and measure the effectiveness of advertising on Ralli's Online Platform;
      3. to identify user behaviour and trends on Ralli's Online Platform;
      4. to identify sales trends for Products on the Ralli Online Platform;
      5. to maintain and optimise the technical performance, operation and security of Ralli's Online Platform; and
      6. targeting advertising and promotional messages displayed on the Online Platform.
  4. Cookies

    1. Parts of the Online Platform use cookies. "Cookies" are pieces of software that are stored on the computer, smart-phone, tablet or device that you are using to access the Online Platform. Cookies are designed to remember information about your personal preferences, your visit and your use of Ralli's Online Platform. Pricemaker will only use and disclose such information to improve your experience of the Ralli Online Platform, to remember your visit to the Ralli Online Platform, and to measure the number of times some advertisements are viewed. You can change the settings on your browser or device to reject some cookies, but this may affect the functionality of Ralli's Online Platform.
  5. Disclosing Personal Information to third parties

    1. Pricemaker will not sell your Personal Information to direct marketers or anyone else.
    2. Pricemaker will not use your Personal Information, or disclose your Personal Information to third parties, except:
      1. to the extent reasonably necessary to achieve any of the purposes described in clauses 2 or 3; or
      2. where Pricemaker reasonably believes that such use or disclosure is required or expressly permitted under any applicable law.
    3. Pricemaker will not hold your Personal Information for longer than is reasonably required for the purposes for which Pricemaker may lawfully use that Personal Information.
  6. Your rights to access and correct Personal Information

    1. Where Pricemaker holds Personal Information about you, you have a right to access and correct that Personal Information in accordance with the Privacy Act 1993. If you want to access or correct your Personal Information, please contact our Privacy Officer and they will tell you how to make a request and if any charges will apply. If you are a Member, you may also access and correct some of your Personal Information by editing your profile or account settings on Ralli's Online Platform.
  7. Security

    1. Pricemaker will use all reasonable endeavours to effect and maintain adequate security measures to safeguard the Personal Information that Pricemaker holds from loss or unauthorised access, use, modification or disclosure. However, as the internet is an open network, Pricemaker does not warrant or guarantee that your Personal Information is safe from loss or unauthorised access, use, modification or disclosure, either during transmission to or from the Ralli Online Platform, or when held by Pricemaker.
  8. Other websites

    1. Other websites that are linked to parts of the Ralli Online Platform may have privacy policies that govern the use of information collected by those other websites. Pricemaker is not responsible for any information collected by those other websites, or the privacy or data protection practices of the operators of those other websites.
  9. Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)

    1. If you are from the European Economic Area (EEA), Pricemaker's legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information Pricemaker collects and the specific context in which Pricemaker collects it.

      Pricemaker may process your Personal Information because:

      1. Pricemaker needs to perform a contract with you;
      2. you have given us permission to do so;
      3. the processing is in our legitimate interests and it's not overridden by your rights;
      4. for payment processing purposes; or,
      5. to comply with the law.
  10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

    1. If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Pricemaker aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

      If you wish to be informed what Personal Information Pricemaker holds about you, or if you want it to be removed from our systems, please contact us.

      In certain circumstances, you have the following data protection rights:

      1. the right to access, update or to delete the information Pricemaker holds on you;
      2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
      3. the right to object. You have the right to object to our processing of your Personal Information;
      4. the right of restriction. You have the right to request that Pricemaker restricts the processing of your Personal Information;
      5. the right to data portability. You have the right to be provided with a copy of your Personal Information in a structured, machine-readable and commonly used format; and
      6. the right to withdraw consent. You also have the right to withdraw your consent at any time where Pricemaker relied on your consent to process your Personal Information.

      Please note that Pricemaker may ask you to verify your identity before responding to such requests.

      You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).

  11. Transfers of your information out of the EEA

    1. Your data will be processed in the US and in Australia (where Ralli's Online Platform is hosted) and in New Zealand (where our development team is located). All of these locations are outside the European Economic Area (EEA). Pricemaker may also have to transfer your data to other suppliers who are based outside of the EEA. In order to do this, Pricemaker has ensured appropriate safeguards are place in accordance with data protection legislation.
  12. California Consumer Privacy Rights

    1. Pricemaker does not sell your Personal Information so no opt-out choice is necessary. What this means is that Pricemaker does not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your Personal Information to another company for monetary or other valuable consideration.
    2. You have the right to request, twice in a 12-month period, the following information about the Personal Information Pricemaker may have collected about you during the past 12 months:

      1. the categories and specific pieces of Personal Information Pricemaker has collected about you;
      2. the categories of sources from which Pricemaker collected the Personal Information;
      3. the business or commercial purpose for which Pricemaker collected or sold the Personal Information;
      4. the categories of third parties with whom Pricemaker shared the Personal Information; and/or
      5. the categories of Personal Information about you that Pricemaker sold or disclosed for a business purpose, and the categories of third parties to whom Pricemaker sold or disclosed that information for a business purpose.
    3. You have the right to request that Pricemaker delete the Personal Information Pricemaker has collected from you. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment.
    4. To submit an access or deletion request, please contact Pricemaker's Privacy Officer privacyofficer@ralli.app. To help protect your privacy and maintain security, Pricemaker may take steps to verify your identity before granting you access to your Personal Information or complying with your request. To the extent permitted by applicable law, Pricemaker may charge a reasonable fee to comply with your request.
  13. Service Providers

    1. Pricemaker may employ third party companies and individuals to facilitate our Online Platform ("Service Providers"), to provide the Online Platform on our behalf, to perform platform-related services or to assist us in analysing how our Online Platform is used.
      1. Google Analytics

        Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Online Platform. This data is shared with other Google services. Google may use the collected data to contextualise and personalize the ads of its own advertising network.

        You can opt-out of having made your activity on the Online Platform available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

      2. Firebase

        Firebase is a service offered by Google that provides our authentication, error-reporting (mobile apps only), and notification services. Google uses the data collected to track and monitor the use of our Online Platform. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

        As our platform depends on Firebase, there is no way to opt-out and continue using the service Pricemaker provides.

      3. Google Cloud Platform

        Google Cloud is a cloud infrastructure provider offered by Google. Our platform is hosted on Google Cloud and data from our applications will be transmitted to these servers and stored there permanently. This data is held by us, and is not used by Google in any other way.

        As our platform depends on Google Cloud, there is no way to opt-out and continue using the service Pricemaker provides.

      4. Facebook

        Facebook is a social media and technology company based in the U.S. Our platform uses Facebook to connect users of its Messenger platform with users within our platform. The platform may expose your name to users on the Messenger platform, and this is stored on Facebook servers permanently.

        It is possible to opt-out of this process by not responding to messages coming through the Platform that originated in Messenger. Look out for the tags that make mention of this.

      5. SendGrid

        SendGrid is an email marketing company that Pricemaker uses to send emails from our platform. Data, such as names and email addresses, will be stored by SendGrid in order to provide the email service, but will not be used for remarketing by SendGrid (although Pricemaker reserves the right to send emails to you beyond the scope of platform services as defined in 2.4 and 3.3(m)).

        It is possible to opt-out of this process by not contacting us directly and asking for an account to be setup on your behalf that disables these email integrations. Pricemaker reserves the right to unconditionally refuse this service for any reason.

      6. Sentry

        Sentry is a web based error monitoring system used by our Platform's websites to debug our platform. Sentry provides a logging service that may expose data (such as name and email addresses) to our developers in plain text. Sentry stores these logs permanently, but does not use them in any other way.

        It is not presently possible to opt-out of providing log data to us and continue to use the service Pricemaker provides.

  14. Payments

    1. Pricemaker may provide paid products and/or services within the Online Platform. In that case, Pricemaker uses third-party services for payment processing (e.g. payment processors).

      Pricemaker will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

      The payment processors Pricemaker works with are:

      1. Stripe Inc

        https://stripe.com/
  15. Amendments

    1. Pricemaker may amend this Privacy Policy from time to time. Notice of any such amendments will be announced on Ralli's Online Platform and will be effective immediately, unless Pricemaker states otherwise. You are responsible for reviewing Ralli's Online Platform regularly to obtain notice of any such amendments.
    2. Your continued use of Ralli's Online Platform will constitute your acceptance of any amendments to this Privacy Policy.
  16. Contacting Pricemaker or our Privacy Officer

    If you:

    1. have any questions about this Privacy Policy or Pricemaker's privacy and data protection practices;
    2. want to access or correct any Personal Information Pricemaker holds about you; or
    3. want Pricemaker to stop sending you Direct Marketing Information.

    Please contact our Privacy Officer at privacyofficer@ralli.app