PRIVACY POLICY

Elucidare Pty Ltd (ACN 622 263 852) trading as NoGrey (NoGrey or us or our or we) is in the business of providing a mobile device software application, website and any other technological products operated by us, now or in the future, which provides a tool to facilitate initial mutual interest discussions (NoGrey Online Platform).

This Policy governs how NoGrey will deal with your Personal Information collected in connection with the NoGrey Online Platform.

This Policy also applies to Personal Information collected by NoGrey in connection with its NoGrey Online Platform as well as in connection with any direct communication between you and NoGrey.

1. SCOPE OF THIS PRIVACY POLICY

1.1 We understand that when accessing and/or using our NoGrey Online Platform, the privacy and confidentiality of Personal Information (as defined under the Privacy Act) is important to you. That’s why we fully respect your rights to privacy and are committed to protecting the personal details you provide us in line with this Privacy Policy. This Privacy Policy applies to our NoGrey Online Platform and all individuals who access and/or use our NoGrey Online Platform or whose Personal Information is processed by NoGrey.

1.2 We are committed to protecting the privacy of everyone who uses our NoGrey Online Platform, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) and the General Data Protection Regulation (EU) 2016.679 (GDPR).

2. THE INFORMATION WE COLLECT

We may collect Personal Information that allows us to identify who an individual is and share Personal Information.

The type of Personal Information we may collect includes an individual’s:

  • email address;

  • preferred username;

  • telephone number;

  • date of birth;

  • password or pin; and

  • gender and location (including IP address and GPS location).

The type of Sensitive Information we may collect includes an individual’s:

  • sexual orientation;

  • interests.

3. WHY WE COLLECT INFORMATION

3.1 We collect your Personal Information so that we can carry out the following actions:

  • to enable you to access and/or use our NoGrey Online Platform;

  • to communicate with you, including about our NoGrey Online Platform and offers which might interest you;

  • to provide you with information or advice;

  • to provide your Personal Information to third parties in order for them to supply the NoGrey Online Platform to you;

  • to consider and respond to complaints made by you.

3.2 We may disclose additional purposes for collection of your Personal Information in collection statements at the point of collection.

4. HOW INFORMATION IS COLLECTED

Information is collected in association with your access and/or use of the NoGrey Online Platform, an enquiry about NoGrey or generally dealing with us directly or via our NoGrey Online Platform.

5. WHEN PERSONAL INFORMATION IS USED & DISCLOSED

5.1 We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission.

5.2 We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

5.3 We will not sell an individual’s Personal Information to unrelated third parties.

 5.4 There are some circumstances in which we must disclose an individual’s information:

  • where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;

  • as required by any law (including the Privacy Act and GDPR); and/or

  • in order to sell our business (in that we may need to transfer Personal Information to a new owner).

6. SENSITIVE INFORMATION

Sensitive Information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.

It is our policy to only collect your Sensitive Information where it is reasonably necessary for our functions or activities and either you have consented, or we are required or authorised under law to do so.

7. OPTING “IN” OR “OUT”

7.1 By clicking “I Agree” or any other button or check box indicating your acceptance of this privacy policy, you expressly consent to the collection and use of your Personal Information and Sensitive Information in accordance with this privacy policy.

7.2 An individual may opt to not have us collect their Personal Information and Sensitive Information. This may prevent us from offering them access and/or use to some or all of our NoGrey Online Platform and may terminate their use and/or access to some or all of the NoGrey Online Platform they access and/or use with or through us. They will be aware of this when the following privacy principles apply to us:

  • Opt In. Where the individual will have the right to choose to have information collected and/or receive information from us; or

  • Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.

7.3 If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the contact details set out in clause 13.

8. COOKIES

We may use temporary (session) cookies or permanent cookies when you access and/or use our NoGrey Online Platform.  This allows us to recognise your browser and track the web pages you have visited. You can switch off cookies by adjusting the settings on your web browser.

9. THE SAFETY & SECURITY OF PERSONAL INFORMATION

9.1 We may hold your Personal Information in either electronic or hard copy form.

9.2 If you provide information to us electronically we retain this information in our computer systems and databases. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.

9.3 We use industry standard security measures to safeguard and protect your information. 

9.4 We may disclose your personal information to third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of your Personal Information do not breach the privacy obligations relating to your Personal Information. We use the following technical and storage third parties overseas:

  • Twilio

  • Sendgrid

  • Mailchimp

  • Firebase

  • Google Analytics

  • Zapier

  • MLab

  • Amazon

9.5 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.

9.6 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.

9.7 Where we become aware of any breach to our security systems that breaches or is likely to result in a breach of your rights or freedoms with respect to your Personal Information, we will notify you and any supervisory authority as required.

9.8 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information

10. HOW TO ACCESS AND/OR UPDATE INFORMATION

10.1 If you would like us to update or amend your Personal Information, please contact us on the contact details set out in clause 13 and we will make the requested amendments.

10.2 We may ask you to verify your identity to ensure that Personal Information we hold is not improperly accessed.

11. RIGHT TO BE FORGOTTEN

In the event that you decide that you no longer want us to hold your Personal Information, you may notify us in writing on the contact details set out in clause 13 of your desire for us to delete your Personal Information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your Personal Information, unless we are required by law to retain such information.

12. LINKS

Links from our NoGrey Online Platform to third party services that we do not operate or control are provided for your convenience. We are not responsible for the privacy or security practices of services that are not covered by this Privacy Policy. Third party services should have their own privacy and security policies which we encourage you to read before supplying any Personal Information to them.

13. COMPLAINTS AND DISPUTES

13.1 If an individual needs to contact us or has a complaint about our handling of their Personal Information, they should address their communication in writing to the details below:

Privacy Officer - Contact Form

13.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.

13.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them and any supervisory authority as required, at the earliest practical opportunity once we have established what was accessed and how it was accessed.

14. GDPR

14.1 If you are:

  • A resident of the European Union accessing and/or using our NoGrey Online Platform in Australia; or

  • accessing our NoGrey Online Platform from within the European Union,

then in addition to our obligations under the Privacy Act, NoGrey is required to comply with the GDPR with respect to your Personal Information.

14.2 Any reference to Personal Information in this Privacy Policy is also a reference to Personal Data (as defined under the GDPR).

14.3 NoGrey takes the security and privacy of your Personal Information seriously and has prepared this privacy policy and taken measures to collect, process and hold all Personal Information in compliance with both the Privacy Act and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.

15. ADDITIONS TO THIS POLICY

If we decide to change this Privacy Policy, we will post the changes on our website. Please refer back to this Privacy Policy to review any amendments.


Version Date: November  2018








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