Vanua Investments Pty Ltd  ABN 94 136 408 216 trading as track.approvals.com

Privacy Policy

1. About this Policy

1.1. Vanua Investments Pty Ltd (ABN 94 136 408 216) trading as trackapprovals.com (We, Us or Our) respects and recognises the importance of your privacy.

1.2. This Privacy Policy describes how We comply with the requirements of the Privacy Act 1988 (Cth) (Privacy Act) including the Australian Privacy Principles (APPs), and any other applicable laws in Australia in relation to the collection, use, disclosure and management of your personal information.

1.3. By engaging with us and using or downloading our products and services, you are agreeing to the terms of this Privacy Policy.  This Privacy Policy is in addition to any other terms and conditions applicable to the products or services that We provide you.  Specific privacy terms contained in any documents made available by Us should be read together with this Privacy Policy.

1.4. We will update this Privacy Policy from time to time, at our discretion, so you should review this Privacy Policy periodically so that you are updated on any changes.

1.5. This Privacy Policy uses the term "personal information" which is defined in the Privacy Act.

2. Contact

2.1. If you have any queries relating to this Privacy Policy, please contact Our privacy officer at:

Email:    privacy@trackapprovals.com
Telephone:    +61 2 9238 2062

We will endeavour to respond to your query within seven (7) days.

2.2. For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner's website at

www.oaic.gov.au.

3. What kinds of personal information do we collect and why?

3.1. We do not collect personal information unless it is reasonably necessary for, or directly related to, one or more of the services or products We provide or functions we carry out.  

3.2. We may collect and process the following personal information about you:

a. your name, job title and place of business, contact details (address, phone number, email address), financial information and other information that you provide at the time of your registration to use the document approval tracking service available through this website;
b. records of our correspondence with you;
c. your responses to any surveys that we conduct;
d. details of your visits to our website, such as traffic data, location data, logs and other communication data and the resources that you access;
e. publicly available information about you; and
f. information provided to us from other organisations, with your prior permission.    

3.3. Your credit card details are not stored by Us and cannot be accessed by Our staff.  Your credit card details are encrypted and securely stored by Commonwealth Bank of Australia BPOINT facility to enable Us to automatically bill your credit card on a recurring basis.  The BPOINT facility is compliant with Payment Card Industry (PCI) standards. You should review Commonwealth Bank of Australia’s Privacy Policy to ensure you are happy with it.  See:

https://www.commbank.com.au/security-privacy/general-security/privacy-policy-html-version.html

3.4. We may also collect other personal information that is relevant to Our functions and activities.

3.5. If We do not collect this personal information from you, We may not be able to provide you with the products, services or assistance that you request.

3.6. As a rule We do not collect or hold Sensitive Information.  Sensitive Information is personal information that includes information relating to your racial or ethnic origin, criminal history, sexual orientation, and membership of any trade or profession associations.  We will only collect Sensitive Information from you with your consent, or as otherwise permitted by the Act.

4. How do We hold and use your personal information?

4.1. Your personal information, and any documents containing your personal information, is held in a secure environment.  We maintain electronic and procedural safeguards and security measures that are reasonably designed to protect your personal information.   

4.2. We collect, use, hold and disclose your personal information for the primary purposes for which it is collected.  Those purposes include to:

2.a. provide information to you about Our products and/or services;
2.b. for the purposes related to the reason you gave Us the information, namely to provide Our software as a service offering;
2.c. manage Our relationship with you;
2.d. fulfil Our regulatory or legal obligations;
2.e. fulfil your specific requests;
2.f. analyse Our service and customer needs with a view to improving Our services; and
2.g. contact you to provide a testimonial or complete a survey, to conduct market research or for direct marketing purposes.

4.3. We may also use such information for a purpose related to the primary purpose of collection and where you would reasonably expect Us to use or disclose the personal information in such a way.

4.4. In addition, We may use or disclose personal information held about you:

4.a. where you have consented to the use or disclosure; or
4.b. otherwise as specifically provided for by the APPs or as otherwise permitted by law.

4.5. If We use your personal information for the purposes of direct marketing, We will always give you the opportunity to request that your information not be used for future direct marketing.

5. Who do we disclose your information to?

5.1. We may disclose personal information collected to third parties such as:

1.a. Lavo Investments Pty Ltd, Our Licensor;
1.b. Our suppliers, third party service providers or subcontractors engaged by Us to perform functions on Our behalf, such as our technology providers or developers;
1.c. representatives who sell products and services on Our behalf;
1.d. people authorised by you to receive information held by Us;
1.e. payment system operators such as merchants receiving credit card payments;
1.f. professional service firms providing services to Us, such as legal or accountancy firms;
1.g. where permitted, debt collection agencies;
1.h. regulatory or government agencies; and
1.i. as required or authorised by the law.

5.2. Our website may contain links to external websites and those third party websites may collect personal information about you.  We take no responsibility for the privacy practices or the content of those other sites.

5.3. Our website uses social media including blogs, bulletin boards, Twitter feeds and links to other social media (such as Facebook, LinkedIn, Twitter etc.).  Any information, including personal information, that you choose to submit in such a forum may be read, collected, or used by others who visit those forums or social media sites, and may be used to send you unsolicited messages.  We are not responsible for the personal information you choose to submit in those forums.

5.4. We will not sell your personal information to other companies or organisations without your prior consent.

6. Will we disclose your personal information outside of Australia?

6.1.  We may disclose your personal information to the categories of persons set out in paragraph 5 wherever they are located.  This includes to overseas recipients located in the United States of America, the United Kingdom, New Zealand, Canada, Fiji, Vanuatu and the Cook Islands.

6.2. We use a cloud host provider to store the personal information we hold about you.  The cloud host provider, and the IT servers on which your personal information is stored, are located in the United States of America.

6.3. By engaging with Us, and using Our products and services, you consent to the disclosure of your personal information to such overseas recipients, and acknowledge that We will not be accountable under the Privacy Act for such disclosure and that you will not be able to seek redress under the Privacy Act.

7. Accessing and correcting your personal information

7.1. We will take reasonable steps to keep accurate, up-to-date and complete any personal information that We collect and hold about you.  If, at any time, you discover that personal information held about you is incorrect, you may contact us in writing (including via email) to have the personal information corrected.  We usually respond to you within seven (7) days of receiving your request.

7.2. You can also gain access to the personal information We hold about you, subject to certain exceptions provided for by law.  To request access to your personal information, please contact Our privacy officer using the contact details at paragraph 2 above.

7.3. If We do not agree to provide access to your personal information, or to allow you to amend or annotate the personal information We hold about you, you may seek a review of Our decision.  In some circumstances, We may need to charge a fee to cover our administrative costs in respect of retrieving your personal information and providing it to you or in respect of correcting or annotating that personal information.  We will inform you if there are going to be any such costs involved.

8. Keeping your personal information secure

8.1.  We will take reasonable steps to protect all personal information We hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.  

8.2. We have ensured that appropriate technical and organisational security measures, consistent with standard industry practice, are in place to attempt to safeguard the security and confidentiality of the personal information We collect and hold. This includes:

2.a. the information is held on secure servers in controlled facilities;
2.b. information stored within Our computer systems can only be accessed by those entrusted with authority and computer network passwords; and
2.c. Our staff have been trained to maintain the security of your information.

8.3. No data transmitted over the Internet can be guaranteed to be 100 per cent secure.  As a result, while we strive to protect users’ personal information, We cannot ensure or warrant the security of any information transmitted to or from our online products or services, and users do so at their own risk.  Once we receive your information, we make every effort to ensure its security in Our systems.

8.4. Whilst we, and the contractors who provide services related to Our information systems, are obliged to respect the confidentiality of any personal information held, We do not accept responsibility for events arising from unauthorised access to your personal information.

8.5. We will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the personal information may be used or disclosed under this Privacy Policy or law.

9. Contacting us anonymously or using a pseudonym

9.1. You may deal with Us on an anonymous basis or by using a pseudonym when making inquiries through Our website, or when you make general inquiries by telephone and do not require a further response from Us.  However, We may need certain contact details from you to respond to inquiries.

9.2. Generally, We will require your personal information in order to correspond with you.

9.3. In order to provide some of Our services to you, We may need to identify you.

10.  Complaints

10.1. You may make a complaint about an alleged breach by us of the APPs in relation to Our handling of your personal information.  The complaint should be in writing and provided to Our Privacy Officer, whose details are set out in paragraph 2 above.

10.2. Where possible, the complaint should include the following information about the alleged breach:

2.a. what happened;
2.b. when it happened;
2.c. what personal information was affected;
2.d. when you found out about it;
2.e. the names of individuals involved (if known);
2.f. details of any action already taken by Us to address the complaint.  

10.3. We will acknowledge your complaint within seven (7) days and try to respond to your complaint within thirty (30) days of receipt of the complaint.

10.4. If you are not satisfied with Our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). The OAIC's contact details are:
The Commissioner:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au

11. Cookies

11.1. When you visit Our website and applications and tools on it, a cookie records the authentication to allow your user id to login.  We use the information gathered by cookies to identify your web browser so that when you log in on the next occasion your use of the website and other applications and tools on it is easier and faster because the website has remembered your details including Country or origin and time zone.  

Last updated:  JULY 2016