We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. 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 in response to your complaint. You also have the right to contact the relevant authority in the country in which you are based.
1. How We Collect and Receive Personal Information
We collect and receive personal information about users of the Digital Applications and related services. This information is either collected or received by us or submitted or shared by users of the Digital Applications and related services.
The information includes data on the pages you access, your device’s IP address, device identifiers, the type of operating system you’re using, your location, mobile network information, and standard web log data. Standard web log data includes the browser type you’re using and traffic to and from our Digital Applications.
When you download or use our mobile applications, or access one of our mobile optimised sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalised content. Most mobile devices allow you to control or disable location services in the device’s settings menu. If you have questions about how to disable your device’s location services, contact your mobile service carrier or the manufacture of your particular device.
In addition, we may collect and store any information you provide us when you use the Digital Applications or related services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, or resolution of dispute, or when you otherwise correspond with us.
We may also obtain information about you from third parties such as credit reporting agencies and identity verification services.
2. Types of Personal Information We Collect, Receive and Hold
We may collect the following types of personal information from you:
(a) contact information, such as your name, business name, address, email address, phone numbers, tax ID or registration numbers, social media handles, and similar information;
(b) personal information, such as date of birth, gender, and educational qualifications; and
(c) financial information, such as bank account details and credit card information.
3. How We Use Personal Information
The lawful basis and primary purpose for collecting and processing your personal information and data is to provide you with a secure, smooth, efficient, and customised experience. We comply with the European General Data Protection Regulation which governs the protection of personal data of EU residents. In addition to law in Australia, we will afford UK-based users with all rights available to EU users, regardless of the UK’s EU member status. We may use your personal information to:
(a) provide you as a contractual obligation under our contract with you as our customer – customer support and information on our products, services, events, programs, newsletters, email updates, and other services;
(b) verify your identity, including during account creation and password reset processes and to pursue other activities within our legitimate interests as part of running our business and doing so in ways which do not hurt your interests and rights, for example obtaining identity, device and location information to prevent fraud and abuse and to keep the Digital Applications secure and obtaining and retaining data which tax laws require us to retain for payments made or received by us;
(c) customise, measure, and improve the content, layout, and operation of the Digital Applications and related services;
(d) contact you at any telephone number, or by placing a voice call or through text (SMS) or email messaging;
(e) manage and protect our information technology infrastructure, which is necessary to provide the services and features you request and serve the legitimate interests of ourselves and third party processors;
(f) share minimal personal information and data with third party processors in order for us to provide services under our contract with you, including service providers of hosting, storage and infrastructure, security, insurance, analytics, communications and support, and payment processing;
(g) perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties;
(h) design products and services;
(i) provide to you targeted marketing about our services and promotional offers and the services of our contractors unless and until you opt-out;
(j) include you in our databases, directories, listings and Digital Applications to communicate with you and indicate your affiliation with us;
(k) process any transactions by you and send notices about your transactions;
(l) confirm your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and assess applications or creditworthiness for premier or business accounts or products and services offered to premier or business accounts with third parties;
(m) resolve disputes, collect fees, and troubleshoot problems;
(n) detect, prevent or resolve violations of policies or applicable user agreements; and
(o) manage our risks and help detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities.
We provide services in conjunction with payment processors which may include processors such as financial or merchant facility providers such as Paypal. When you delete your account with us, we delete your personal data retained by us, except to the extent we are prevented by law from deleting your personal information or data. However, to delete any payment or billing information, you will need to do so with your payment provider, as we only have minimal secure access to those records as needed to provide the services.
4. Personal Profile
When you use the Digital Applications, subject to the services or functionality we introduce or change, you may upload or download content, set up your personal profile, form relationships, send communication, perform searches and queries, form groups, set up events, add applications, and transmit information through various channels. We collect this information so that we can provide to you the Digital Applications with personalised features. To provide you with more useful and personalised information the Digital Applications may also collect your personal information from other sources referred to in paragraph 1 above.
5. Privacy Settings
When you register with the Digital Applications, you may be asked to create your own profile and privacy settings. Your profile information is displayed to people in the networks specified in your privacy settings to enable you to connect with the Digital Applications and other users of them. We may occasionally use your personal information to send you notifications regarding new services offered by us, the Digital Applications or related services that we think you may find valuable.
When you use the Digital Applications, certain information you post or share with third parties (eg a friend or someone in your network), such as personal information, comments, messages, photos, videos, or other information, may be shared with other users in accordance with the privacy settings you select. All such sharing of information is done at your own risk. Please keep in mind that if you disclose personal information in your profile or when posting comments, messages, photos, videos, or other items, this information may become publicly available.
6. Protection of Personal Information
We use technological, legal and training means to provide high levels of security and privacy for personal information.
Despite our security and privacy measures, personal information we collect is at your risk. We may have facilities for you to set privacy options that limit access to your personal information. Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your pages and information. Even after removal, copies of user-generated content may remain viewable in cached and archived pages elsewhere or files stored by others. Any improper collection or misuse of information should be reported to us.
7. How You Can Protect Your Personal Information
We will never send you an email requesting confidential information such as account numbers, usernames, passwords or social security numbers, and you should never respond to any email requesting such information. If you receive such an email purportedly from Visionflex, do not respond to the email and do not click on any links and/or open any attachments in the email.
You are responsible for taking reasonable precautions to protect your user ID, password and other account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify Visionflex at email@example.com if you know of or suspect any unauthorised use or disclosure of your user ID, password, and/or other user account Information, or any other security concern.
8. Information Submission by Minors
We do not knowingly collect personal information from individuals under the age of 18 and the Digital Applications are not directed to individuals under the age of 13. We request that these individuals do not provide personal information through the Digital Application. If you are aware of a user under the age of 13 using the Digital Application, please contact us at firstname.lastname@example.org
9. Privacy of Email Addresses
The Digital Applications provide users the opportunity to opt-out of receiving communications, usually at the point where we request information about the user. The Digital Applications require users to affirmatively ask to join mailing and subscriber lists. These lists are only available to our authorised personnel.
10. To Communicate with You
We may send you emails, text messages, and push notifications to your device if you have them enabled, to verify your account and for informational and operational purposes, such as account management, providing instructions, alerts, reminders, customer service, system maintenance, and other purposes related to the Digital Applications.
11. Aggregated Browser Information
We analyse Digital Applications logs to constantly improve service. We use the log information to record various information regarding different sections of the Digital Applications. This helps make the Digital Applications more useful.
12. Cookies and Analytics Technologies
We may also occasionally use “web beacons” (also known as “clear gifs,” “web bugs,” “1-pixel gifs,” etc.) that allow us to collect non-personal information about your response to our email communications and for other purposes. Web beacons are tiny images, placed on a web page or email, that can tell us if you have visited a particular area of the Digital Application. For example, if you have given us permission to send you emails, we may send you an email urging you to use a certain feature of the Digital Applications. If you do respond to that email and use that feature, the web beacon will tell us that our email communication with you has been successful. Because web beacons are used in conjunction with persistent cookies, if you set your browser to decline or deactivate cookies, web beacons cannot function.
13. Permitted Disclosure
If you become a registered user of any of the Digital Applications, you will be taken to consent to:
(a) your personal data being transferred to and processed in countries where our hosting servers are located;
(b) us using your personal information to check your identity, including to check your status (eg as a member of a defined user group) and for any merchant facility arrangement we have with bankers, their respective related bodies corporate, and their respective officers, employees and agents;
(c) use of your personal information by us and our authorised personnel and service provider contractors; for example, to improve service we may provide your personal information as statistical data to others for research and analysis purposes; and as another example we may use Google Analytics and give you notice of its operation on the webpage titled “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).
(d) us disclosing your personal information in situations where we reasonably believe it is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering with our rights, either intentionally or unintentionally; and
(e) us disclosing your personal information to law enforcement agencies and others if we in good faith believe we are legally obligated to do so.
The Digital Applications may contain links to sites and applications published by others. We have no control over their privacy practices.
15. Right of Access and Correction
Generally speaking, you may access the personal information the Digital Applications hold about you by sending an email giving full details to our Privacy and Data Protection Officer set out in paragraph 20. Generally, if any of that information is incorrect, you can have that information corrected by sending an email giving full details to that Privacy and Data Protection Officer. If you provide us with your personal information and you later decided that you would no longer like to receive information from us, follow the “unsubscribe” directions at the end of any email or other communication you receive from us. You may withdraw consent by deleting your account at any time.
16. Disclosure of Personal Information Abroad
We are likely to disclose your personal information to the following countries:
(b) New Zealand;
(c) United States;
(d) United Kingdom;
(e) member states of the European Union;
(f) Republic of Korea;
(g) People’s Republic of China;
(k) Singapore; and
(l) other states in which we or you have business activities.
17. Consent for Platform Applications
If you, your friends, or members of your network use any third-party applications developed using third party applications on the Digital Applications (“Platform Applications“), you consent to those Platform Applications accessing and sharing certain personal information about you with others in accordance with your privacy settings. We do not screen or approve developers of Platform Applications and cannot control how those developers use any personal information that they may obtain in connection with Platform Applications.
18. Third Party Use of Personal Information
We may use third parties to manage the Digital Applications and activities from time to time, including, but not limited to, promotions and statistical analysis. These parties may have access to and store the personal information of users of the Digital Applications. Similarly, we may contract with third parties to handle requests for information submitted to us.
19. Disclosure or Sale
20. Data Retention and Deletion
We store your personal information for as long as you maintain an account and up to five (5) years after the account is closed. At the end of this five-year period, we may remove your personal information from our databases and will request that our business partners remove your personal information from their databases. When we delete any information, it will be deleted from the active database, but may remain in our archives. However, once we disclose your personal information to third parties, we may not be able to access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Written requests for deletion of public information other than as described should be directed to email@example.com. We retain anonymised data indefinitely.
21. Business Transfer
23. Objections and Complaints about Our Privacy Practices
You have a right to object to our use of your personal data. For any complaint about our privacy practices, please provide details to the Privacy and Data Protection Officer, whose contact details are in paragraph 20. We will then respond.
24. Contact Details
Privacy and Data Protection Officer
Visionflex Pty Ltd
Phone: +61 2 8914 4000
Last updated: 30 June 2021