Privacy Policy

Updated 1 October 2019

In this Privacy Policy we, us or our means Vybrance Pty Ltd (ABN 85 635 467 908).

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.

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website (collectively our Site), and connected applications, and application programming interfaces (collectively our Services). By accessing and/or using our Site and/or Services, you agree to these terms of use and our Privacy Policy.

Personal Information: Personal Information is information or an opinion that identifies an individual. The types of personal information we may collect about you include:

  • your name;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your credit card details;
  • your demographic information, such as postcode;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • information you create, upload, store or transmit while using our Site, and information of end users of applications connected to our Services;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • any other personal information requested by us and/or provided by you or a third party.

This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our Site and applications you connect to our Services, from your website, from media and publications, from other publicly available sources, from cookies and from 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.

We may collect, hold, use and disclose personal information for the following purposes:

  • to enable you to access and use our Site,
  • to enable you to access and use our Services,
  • to contact and communicate with you;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, * including to operate and improve our Site, associated applications and associated social media platforms;
  • for advertising and marketing, including to send you promotional information about our products and services; to comply with our legal obligations and resolve any disputes that we may have; and
  • to consider your employment application.

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.

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.

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, religious or philosophical beliefs, or health information.

To provide our Services, we collect and store the Sensitive Information you submit, upload or transmit through our Site, including health information of end users of your applications.

Sensitive information will only be used:

  • for the primary purpose for which it was obtained;
  • for a secondary purpose that is directly related to the primary purpose; and
  • with your consent; or where required or authorised by law.

Disclosure of Sensitive Information: Sensitive Information is a subset of Personal Information, that we disclose only in order to provide Services to you, unless you specifically consent otherwise, and are entitled to do so.

Your Sensitive 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.

We may disclose Sensitive Information to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers;
  • our employees, contractors and/or related entities;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

Disclosure of Personal Information: In addition to Disclosure of Sensitive Information, your Personal Information (but not Sensitive 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.

We may disclose Personal Information (but not Sensitive Information) to:

  • our existing or potential agents or business partners;
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. Where unavoidable, this may include parties located, or that store data, outside of Australia; and
  • 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.

For the avoidance of doubt, Sensitive Information is never transmitted, stored or disclosed outside of its country of origin, unless we are explicitly requested to do so, and such transmission and storage complies with relevant regulations.

Security of Personal Information: Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Sensitive 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 Sensitive Information. However, most of the non-Sensitive 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.

We will will 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 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 Services to you.

Policy Updates: This Policy may change from time to time and is available on our website. We will also notify customers of any updates.

Questions: info@vybrance.co

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