Privacy Policy
TWENTY TWENTY 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 have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs 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 https://www.oaic.gov.au/.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect includes names, addresses, email addresses, phone and facsimile numbers.
This Personal Information is obtained in many ways including [interviews, correspondence, by telephone and facsimile, by email, via our website 20twenty.com.au, from your website, from media and publications, from other publicly available sources, from cookies and from third parties. We don’t guarantee website links or policy of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
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.
Sensitive Information
Sensitive information is defined in the Privacy Act to include 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.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained
- For a secondary purpose that is directly related to the primary purpose
- With your consent; or where required or authorised by law.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
- Third parties where you consent to the use or disclosure; and
- Where required or authorised by law.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.
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. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
Access to your Personal Information
You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
TWENTY TWENTYwill not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
Maintaining the Quality of your Personal Information
It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Amazon Selling Partner data
Twenty Twenty Group (ABN 73658540651) provides advertising management and performance reporting to brands that sell on Amazon. When a client authorises our application through Amazon Seller Central or Vendor Central, we use Amazon’s Selling Partner API to retrieve data from that client’s own Amazon account.
What we collect.
We collect aggregated sales and traffic data only, for example ordered product sales, units ordered, page views, sessions and conversion rates, broken down by product (ASIN) and date. We do not request, collect or store any information about Amazon customers, such as names, addresses, phone numbers, email addresses or order-level buyer details.
Why we collect it.
We use it only to prepare performance reports for the client whose account it came from, and to manage that client’s Amazon advertising. We do not sell it, use it for any other client, combine it with other clients’ data, or use it to compete with the client or with Amazon.
Who can see it.
Access is limited to the TWENTY TWENTY staff who work on that client’s account, and to the people the client nominates to receive its reports. Reports are published on a private site that requires each viewer to sign in. We do not share the data with any other party unless the client asks us to or the law requires it.
How it is stored and protected.
API credentials are kept in an encrypted password manager and are never stored in source code. Data is transferred over encrypted connections (TLS) and stored in access-controlled systems, with multi-factor authentication on the accounts that can reach it. Access is
reviewed and removed when staff leave or no longer work on the account.
How long we keep it.
We keep a client’s Amazon data for as long as we provide services to that client. When the client revokes our access in Seller Central or Vendor Central, or our engagement ends, we stop collecting their data and delete it within 90 days, unless the client asks us to keep its reports or the law requires us to retain them. The seven-year retention of client files described above does not apply to data obtained through Amazon’s API.
Security incidents.
If we become aware of any unauthorised access to Amazon data we hold, we will notify the affected client and Amazon promptly and in line with Amazon’s requirements.
Revoking access.
A client can withdraw our access at any time from Seller Central (Apps and Services → Manage Your Apps) or Vendor Central, or by contacting us.
Contact.
Questions about how we handle Amazon data can be sent to [email protected] or 1300 752 152, or to the address under “Privacy Policy Complaints and Enquiries” below.
Policy Updates
This Policy may change from time to time and is available on our website.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our Privacy Policy please contact us at:
247 St Kilda Road, St Kilda, 3182 VIC
[email protected]