Privacy Policy
1 Purpose
Fleet Space Technologies Pty Ltd (Fleet Space) takes privacy seriously and is committed to responsible privacy practices.
This Policy describes how Fleet Space manages personal information including details of what types of personal information Fleet Space collects, how Fleet Space collects personal information, the purposes for which Fleet Space uses personal information and to whom personal information is disclosed.
FleetSpace seeks to comply with relevant laws in its areas of operation, including the Privacy Act 1988 (Cth) (Privacy Act) and the EU General Data Protection Regulation (GDPR), where applicable.
2 What is personal information
In this Policy "personal information" has the meaning set out in the Privacy Act. Essentially, personal information is information about an individual who is identified or reasonably identifiable. This definition generally corresponds with 'personal data' as defined in the GDPR.
Some types of personal information are designated as 'sensitive information', which would be subject to additional protection under the Privacy Act. This generally corresponds with 'special category data' as defined in the GDPR.
When we refer to "collection", "use", "disclosure", "storage" or "handling" of personal information in this Privacy Policy, we mean any operation or set of operations that are performed on personal information, whether or not by automated means. This corresponds with 'processing' as defined in the GDPR.
3 What types of personal information do we collect?
The types of personal information that Fleet Space collects will depend on the purpose for which the information is collected. It may include:
- in the case of customers acquiring our products and/or services:
- name;
- contact details, including email address, mailing address, street address and/or telephone number;
- your preferences and/or opinions;
- information that may be provided to us through customer surveys;
- details of relevant products and services that we have provided and/or that you have enquired about, and our response to you;
- how you interact with our content and information that may be publicly available about you; and
- in the case of our physical sites where we may have CCTV, video, audio or similar monitoring technology installed - footage and recordings from that monitoring technology;
- in the case of prospective employees or contractors – information that is contained in an application or résumé, that may be recorded during any interview, or that may be obtained through any pre-employment checks, as well as government-issued identifiers such as tax file numbers;
- in the case of our suppliers and distributors – name, mailing or street address, email address, and telephone number(s), the types of products and services provided, as well as details of products and services that we acquire from you, and if applicable, your banking details;
- if you have contacted us to make a complaint, provide feedback, submit an enquiry, or request a call-back – your name, mailing or street address, email address, and telephone number(s); and
- any other personal information requested by us and/or provided by you or a third party.
Generally, Fleet Space will not collect sensitive information. However, in certain limited circumstances, we may need to collect limited sensitive information. For example, if you apply to become an employee of Fleet Space, we may collect personal information about your citizenship, residency status, membership with any political, professional or trade associations or unions, procure police checks to confirm your criminal record, and obtain other sensitive information you choose to disclose to us for your wellbeing, such as details of disabilities, medical conditions or other dietary or health requirements. Where this nature of information is required, it is a result of the company's compliance with legal requirements and/or risk management protocols relating to export controls, national security or working with children. In all other circumstances disclosure of such information is voluntary.
Fleet Space also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser type, version and language, operating system, geolocation data, browsing preferences, pages viewed while browsing the websites, page access times and referring website address and usage of Fleet Space's websites https://www.fleet.space/ and https://exoSphere.fleet.space (Websites) or products) arising from your use of the Websites. This information is used solely internally for the purpose of understanding visitor traffic, trends and delivering personalised content to you while you are on our Websites.
In addition to the types of personal information identified above, Fleet Space may collect personal information as otherwise permitted or required by law.
4 How do we collect personal information?
Fleet Space will usually collect your personal information directly from you, including when you:
- access, use or subscribe to the Websites or use Fleet Space's products or services;
- apply to work with Fleet Space or are engaged by Fleet Space as an employee or contractor;
- make enquiries about us or our services or otherwise communicate with Fleet Space by email, by telephone, in person, via a website or otherwise;
- sign up to sign up to receive news about our products or services; and
- enter surveys, competitions or promotions organised by us.
Where it is reasonable to do so, we will only collect personal information about you directly from you, and not from third parties. In limited circumstances, Fleet Space may also collect personal information from third parties such as:
- publicly available sources;
- entities with which Fleet Space conducts business; and
- other third parties (for example, from referees if you apply for a position as an employee or contractor with us).
You may deal with us anonymously or using a pseudonym when you access many aspects of the Websites or making inquiries through the Websites or by telephone, if you do not require a response from us. However, to access Fleet Space's customer support features or for us to respond to inquiries, we require certain contact details from you. We generally need your personal information in order to transact with you.
5 Cookies
We use "cookies" and similar tracking technology, such as web beacons and authentication tokens on our Websites. A "cookie" is a small amount of information which is transferred to the hard drive of your computer and which can identify your web browser, but not you.
Cookies can be "persistent" (cookies that stay on your browser until you delete them or else your browser deletes them based on the duration period set in the cookie) or "session" (cookies which are deleted when you close your browser). Fleet Space uses session cookies and persistent cookies on the Websites.
By using the Websites, you are consenting to the use of cookies and other tracking technologies in accordance with this Privacy Policy.
Cookies, by themselves, do not tell us your name or contact details. We use this data in aggregate to improve our Websites and our offerings. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without the individual's consent.
Any third party links or advertising on our Websites might also use cookies; you may receive these cookies by clicking on the link to the third party site or advertising. We do not control the collection or use of information by these third parties, and these third party cookies are not subject to this Privacy Policy. Those cookies (or other cookies on our website) may also allow third parties, such as social media operators and search engine operators and providers of advertising services, to cause our (or third parties') advertisements to appear on your social media and online media feeds. If you do choose to provide our Websites with personal information, this information may be linked to the data stored in the cookie and used for those purposes.
Fleet Space uses third party providers to provide us with web analytics services, such as Google, WebFlow and Autopilot. These providers collect information on how individuals use our Websites. These providers may use cookies, features like Enhanced Conversations, and other technologies such as clear gifs or web beacons to obtain such information. This allows us to improve our Websites and our offerings. Please refer to the privacy policies of these entities on their websites, for more information on their privacy processes.
You can disable your web browser from accepting cookies and other tracking technologies used to collect technical information and general analytics when browsing our Websites. If you do so, you can still access our Websites, but it could impact your user experience.
6 Why do we collect, use and disclose your personal information?
In general Fleet Space collects, uses and discloses your personal information for purposes connected with our business, and the purposes for which we collected it.
To the extent the GDPR applies, Fleet Space will only use personal information about you if we have a lawful basis to do so, for example:
- where you have given Fleet Space your consent;
- where processing of your personal information is necessary for the performance of a contract with you;
- to meet Fleet Space's legal obligations; and
- to pursue Fleet Space's legitimate business interests.
Some of the specific purposes for which Fleet Space collects, uses and discloses personal information are as follows:
- to provide its products and services to its customers or to receive goods or services from third parties;
- to enable the proper operation and functionality of its products and services, including the Websites;
- to improve and develop its products and services and offerings;
- to verify your identity (for example, if you request access to the personal information Fleet Space holds about you);
- to consider you for a job at Fleet Space (whether as an employee or contractor) or other relationships with Fleet Space;
- to address any issues or complaints that Fleet Space has or you have regarding our relationship;
- to comply with its legal obligations;
- to develop and improve the quality of its Websites, products and offerings, and to customise its Websites and offerings according to your preferences, to tailor search results, and to show relevant advertising;
- for direct marketing purposes (see the "Direct marketing" section below); and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
If Fleet Space is unable to collect your personal information then Fleet Space may not be able to provide you with the products, services, offerings and opportunities that depend on the collection of that information.
Automated decision making
To the extent the GDPR applies, we do not envisage that any decisions will be taken about you using fully automated means., We will notify you in writing if this position changes.
7 To whom do we disclose personal information?
Fleet Space may disclose your personal information to third parties in connection with the purposes described above.
This may include disclosing your personal information to the following types of third parties:
- its related companies;
- any potential third party acquirer of Fleet Space or its business or assets, and advisors to that third party;
- its professional advisers (such as lawyers, accountants or auditors) and insurers;
- its employees, contractors and third party service providers who provide services to Fleet Space or assist Fleet Space in performing its functions and activities including payment systems operators and financial institutions, debt collectors, cloud service providers, data storage providers, web-hosting and server providers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors shipping companies, telecommunications providers, IT service providers, and IT support services providers;
- organisations authorised by Fleet Space to conduct promotional, research or marketing activities;
- third parties to whom you have authorised Fleet Space to disclose your information (e.g. referees);
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia;
- third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia; and
- any other person as required or permitted by law.
If Fleet Space discloses your personal information to third parties it will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in Fleet Space's agreement with a third party service provider to which Fleet Space discloses your personal information.
To the extent the GDPR applies, we will use reasonable commercial efforts to ensure that the third party will only process your personal information in accordance with written instructions from us, and that the third party either complies with the GDPR or another mechanism set out by applicable EU or Swiss data protection laws for the transfer and processing of personal information.
8 Direct marketing
Fleet Space may use and disclose your personal information for the purpose of direct marketing to you if:
- you have consented to Fleet Space doing so; or
- it is otherwise permitted by law.
Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.
You can unsubscribe from Fleet Space's direct marketing, or change your contact preferences, by contacting Fleet Space (see the "How to contact us" section below) or by clicking on the relevant link at the bottom of any direct marketing emails.
9 Does personal information leave Australia or the EU?
Fleet Space stores personal information in servers located in Australia and in the Netherlands as well as through third party service providers located overseas, such as in the United States of America.
Fleet Space may disclose your personal information to overseas recipients, such as to its subsidiaries, subscribers, resellers and service providers located overseas, in order to provide its products and services and to obtain services. Such overseas recipients may be located in different countries which are likely to include the Netherlands, the United States.
Except where an exception applies under the Privacy Act or other relevant legislation, Fleet Space will take reasonable steps to ensure that overseas recipients to whom Fleet Space discloses personal information do not breach the Australian Privacy Principles stated in the Privacy Act, and any other relevant legislation relating to privacy and data security, in relation to such information.
To the extent the GDPR applies we only disclose your personal information outside of the EU where the EU Commission has made an adequacy decision to ensure that there is an adequate level of protection in that country, or where there are appropriate safeguards in place to protect your personal information.
10 How do we protect your personal information?
Fleet Space engages service providers to store your personal information, including Amazon Web Services, WebFlow, Hubspot, Retently, Autopilot and Google. We may amend this section from time to time where we engage other third parties to process your personal information for the purposes set out in this privacy policy. Fleet Space recommends that you review these companies' privacy policies to understand how they use and store your personal information.
Fleet Space will take reasonable steps to keep any personal information it holds about you secure and to protect it from unauthorised access, modification or disclosure and from misuse, interference and loss. Among other techniques, Fleet Space usually:
- stores information behind its "firewall" in a secure location; and
- restricts the number of employees who can have access to such information.
However, you acknowledge that the security of personal information transmitted over the internet cannot be guaranteed. Fleet Space cannot guarantee that any personal information you disclose to Fleet Space will not become publicly available. Except to the extent liability cannot be excluded due to the operation of statute, Fleet Space excludes all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this policy restricts, excludes or modifies or purports to restrict, exclude or modify Fleet Space's obligations under the Privacy Act and any other applicable legislation or any statutory consumer rights you may have under any applicable law including the Competition and Consumer Act 2010 (Cth).
Please notify Fleet Space immediately if you become aware of any breach of security.
Where a breach of security gives rise to a 'data breach', being an incident when personal information, in any format, held by an agency or organisation is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference, Fleet Space will comply with its obligations under the Notifiable Data Breaches Scheme under the Privacy Act or under the GDPR where applicable.
11 How long do we keep your personal information?
Generally, Fleet Space will only retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this policy) unless a longer retention period is required by law.
This means that Fleet Space will store your personal information for the following periods:
- if you unsuccessfully apply for a job at Fleet Space (whether as an employee or contractor): up to 2 years;
- if you work at Fleet Space (whether as an employee or contractor): up to 7 years after you cease working with Fleet Space;
- if Fleet Space processes your personal information in connection with you being a supplier to Fleet Space (or an employee or contractor of a supplier) or in connection with you being a subscriber or reseller (or an employee or contractor of a subscriber or reseller): up to 7 years from your last interaction with Fleet Space; and
- if Fleet Space processes your personal information for direct marketing purposes or processes your personal information based on your consent, Fleet Space may process the information until you ask Fleet Space to stop and for a short period after that (to allow Fleet Space to implement your request). Fleet Space will indefinitely keep a record of the fact that you have asked Fleet Space not to send you direct marketing or to process your information so that Fleet Space can respect your request in future.
Fleet Space may retain your personal information for a longer period of time if it is reasonably necessary to comply with Fleet Space's legal obligations, resolve a dispute or maintain security.
When personal information is no longer required, Fleet Space will take reasonable steps to delete the personal information from Fleet Space's systems or de-identify the personal information.
12 AI Model Data
Fleet Space is committed to building space-enabled technology to solve global challenges and empower humanity's exploration of worlds. Our work increasingly involves the use of artificial intelligence (AI)-powered insights to deliver leading products and services.
Where you are a Fleet Space customer (and depending on our relationship with you), we may collect information from you to expand the capabilities of the AI-powered products and services we provide to you. We are committed to taking all commercially reasonable steps to ensure the confidentiality of this information. Where this information includes personal information, we will take reasonable steps to ensure that information is de-identified prior to use.
13 Individuals located in Australia
Choice and consent
Please read this Privacy Policy carefully. You do not have to provide personal information to us. However, as above, if you do not it may affect your use of the Websites, our products and/or services, or our ability to otherwise engage or interact with you.
How can you seek to access and correct personal information we hold about you?
You may seek access to personal information Fleet Space holds about you by contacting Fleet Space as described in the "How to contact us" section below.
Fleet Space will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply. Fleet Space may require that the person requesting access provide suitable identification and where permitted by law Fleet Space may charge a fee for giving access to your personal information.
If the personal information was provided to Fleet Space by any of Fleet Space's subscribers or resellers, Fleet Space may advise the relevant subscribers or resellers of your request and liaise with them about it.
If you become aware that any personal information Fleet Space holds about you is incorrect or if you wish to update your information, please contact Fleet Space as described in the "How to contact us" section below.
How can you complain about a privacy issue?
You may make a privacy complaint in relation to personal information Fleet Space holds about you by contacting Fleet Space as described in the "How to contact us" section below.
If you make a privacy complaint, Fleet Space's Ethics and Privacy Officer or another suitable staff member of Fleet Space will investigate the matter and attempt to resolve it as soon as reasonably possible (usually within 30 days of receipt of the complaint).
If you consider your concerns have not been resolved satisfactorily by Fleet Space, or you wish to obtain more information on privacy requirements you can contact:
Office of the Australian Information Commissioner
GPO Box 5218Sydney NSW 2001
Phone: 1300 363 992
Online: www.oaic.gov.au
Email: enquiries@oaic.gov.au
14 Individuals located in the EU/EU Citizens
Our responsibilities as a 'controller' under the GDPR
The term "Controller" is defined by the GDPR as a natural or legal person, or a public authority, agency or other body, to whom personal information or personal information has been disclosed, whether or not via a third party, and who determines the purposes and means of processing personal information. We are a "controller" under the GDPR, as we collect, use and store your personal information to enable us to provide you with our goods and/or services.
As a controller, we have certain obligations under the GDPR when collecting, storing and using the personal data of EU citizens. If you are an EU citizen, your personal information will:
- be processed lawfully, fairly and in a transparent manner by us;
- only be collected for the specific purposes we have identified in the 'collection and use of personal data' clause above, and will not be further processed in a manner that is incompatible with the purposes we have identified;
- be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal data is processed;
- be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal information);
- be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal information was collected;
- be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Where appropriate, we also apply these principles to the way we collect, store and use the personal information of our Australian customers or clients as well.
Your rights to control your personal information
You may also have the following rights:
- Choice and consent: Please read this Privacy Policy carefully. You do not have to provide personal information to us. However, as above, if you do not it may affect your use of the Websites, our products and/or services, or our ability to otherwise engage or interact with you.
- The right to access, rectify or update your personal information: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
- The right to request erasure: You may request Fleet Space erase personal information we hold about you.
- The right to ask us to restrict data processing: You may ask us to limit the processing of all or some of your personal information where you believe that the personal information we hold about you is inaccurate or incomplete (to give us enough time to verify if the information needs to be changed), or where processing that personal information would be unlawful. If you ask us to restrict how we process your personal information, we will let you know how the restriction affects your use of the Websites, our products or services, or our other engagements or interactions with you.
- The right to access and data portability: In some circumstances you have the right to be provided with a copy of the personal information that Fleet Space has about you in a structured, machine-readable and commonly used format. You may also request that we transfer this personal information to another third party (data portability).
- The right to withdraw consent: You may withdraw your consent at any time where Fleet Space relied on your consent to process your personal information.
Fleet Space may ask you to provide suitable identification when you seek to exercise any of these rights.
Complaints
If you believe that we have breached an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.
You also have the right to contact your relevant supervisory authority if you wish to make a complaint – via https://edpb.europa.eu/about-edpb/board/members_en.
15 Local exemptions and inconsistency with law
Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption in Australia), Fleet Space may rely on such an exemption.
This policy will not apply to the extent that it is inconsistent with any applicable law.
16 Changes to this policy
Fleet Space may change this policy from time to time at its discretion. Amendments to this policy will be posted on the Websites, and we recommend you check them regularly to ensure you are aware of our current Privacy Policy.
17 How to contact us
If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by Fleet Space or would like to request access to or correction of the personal information Fleet Space holds about you, please contact Fleet Space's Privacy and Ethics Officer:
Attn: Privacy and Ethics Officer
Fleet Space Technologies
E: ethics.officer@fleet.space
Quality Policy
Fleet Space Technologies is dedicated to fulfilling customer needs through innovative solutions to revolutionise critical mineral discovery, space exploration, and defence using satellite-enabled solutions and seismic array technology.
We are committed to:
- Maintaining compliance to the ISO 9001 standard
- Embedding quality into our products and services
- Driving high standards in all areas of the business
- Understanding customer needs to ensure we design and develop the right products
- Continually improving our processes and the quality management system
Quality Certifications & Process
Fleet Space complies with International standards, including ISO:9001:2015. Fleet has a quality management system (QMS), quality policy, and processes to address new product introduction, change management, corrective actions, and more.
Company Certifications
Fleet complies with the following standards and international requirements:
- ISO 9001:2015—QUALITY MANAGEMENT SYSTEM (QMS) CERTIFICATION — ISO 9001:2015 sets out the criteria for a quality management system and is based on a number of quality management principles, including; a strong customer focus, the motivation and implication of involvement or ownership by top management, the process approach and continual improvement.
DOWNLOAD ISO 9001:2015 CERTIFICATE
- ISO/IEC 27001 —INFORMATION SECURITY MANAGEMENT SYSTEM (ISMS) CERTIFICATION — ISO/IEC 27001 is the world’s best-known standard for information security management systems (ISMS) and their requirements and covers information security, cybersecurity and privacy protection.
DOWNLOAD ISO/IEC 27001 CERTIFICATE
Responsible Disclosure
We consider the security of our systems a top priority. But no matter how much effort we put into system security, there can still be vulnerabilities present.
If you discover a vulnerability, we would like to know about it so we can take steps to address it as quickly as possible. We would like to ask you to help us better protect our clients and our systems.
Please do the following:
- E-mail your findings to is@fleet.space. Encrypt your findings using our PGP key to prevent this critical information from falling into the wrong hands;
- Do not take advantage of the vulnerability or problem you have discovered, for example by downloading more data than necessary to demonstrate the vulnerability or deleting or modifying other people's data;
- Do not reveal the problem to others until it has been resolved;
- Do not use attacks on physical security, social engineering, distributed denial of service, spam or applications of third parties; and
- Do provide sufficient information to reproduce the problem, so we will be able to resolve it as quickly as possible. Usually, the IP address or the URL of the affected system and a description of the vulnerability will be sufficient, but complex vulnerabilities may require further explanation.
What we promise:
- If you have followed the instructions above, we will not take any legal action against you in regard to the report;
- We will handle your report with strict confidentiality, and not pass on your personal details to third parties without your permission;
- We will keep you informed of the progress towards resolving the problem;
- In the public information concerning the problem reported, we will give your name as the discoverer of the problem (unless you desire otherwise); and
- As a token of our gratitude for your assistance, we offer a reward for every report of a security problem that was not yet known to us. The amount of the reward will be determined based on the severity of the leak and the quality of the report. The minimum reward will be a $50 gift certificate.
We strive to resolve all problems as quickly as possible, and we would like to play an active role in the ultimate publication on the problem after it is resolved.