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real-u Privacy Policy

Welcome to our website www.real-u.com.au (Website). This Website is owned and operated by Greatskin Pty. Ltd. (ACN 166 650 540), (We or Us)

We respect your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act) and is committed to protecting your privacy. By using the Website, you consent to the collection, use, holding and disclosure of your personal information by us as set out in this Privacy Policy.

 

Effective date: May 25, 2018. Last Updated: May 24, 2018

 

When transmitting personal information to our Website, you acknowledge that the transmission of information over the internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.

We regularly review our policies and procedures regarding personal information and may therefore update and amend this Privacy Policy from time to time. Any updated Privacy Policy will be made available on the Website or otherwise on request from us.

The personal information we collect

Personal information is information or an opinion about an identified or reasonably identifiable individual. 

What types of information we collect from you depends on how you use the Services, what Services you use, and what information you choose to provide or make available to us. We collect information from you when you:

  • Create or register an account, and when you administer your account
  • Input information or data into any of our Services, or post or upload Content to our Services
  • Submit questions, requests, other communications to us via forms, email, or other communication media
  • Contact us for customer support or technical support
  • Visit any of our websites or social channels
  • Participate in any promotions, demonstrations, contests, surveys, or other marketing events
  • Interact with other real-u users and guests on our community forums

From time to time we may collect health information about you. We will only collect and use health information about you with your consent and we will manage all health information we collect about you in accordance with the additional protections applicable to ‘Sensitive Information’ under the Privacy Act 

Also, information related to the creation of accounts or that otherwise identifies you as a customer or end user of real-u is what we call "Customer Information." Customer Information may include certain "personally identifiable information" or "PII", such as your name, email address, gender, postal address and phone number. It also may include payment information, such as payment method, credit card information, and any contact information (such as name and postal address) associated with payment billing information..

When you create an account with real-u, we may collect certain Customer Information directly from you or, if you create your account using a third-party service (such as Afterpay), we may collect Customer Information about you from the third-party service (such as your username or user ID associated with that third-party service). By choosing to create an account using a third-party service, you authorise us to collect Customer Information necessary to authenticate your account with the third-party service provider.

How your personal information is collected

Where it is reasonably practicable to do so, we will collect personal information directly from you, for example when you purchase products from us, submit your information to us or contact us directly. 

We collect information about how you use the Services and your actions on the Services, including IP addresses, what software and hardware you use (such as browser types, operating systems, ISPs, platform type, device type, mobile device identifiers such as make and model, mobile carrier), pages or real-u used and associated dates and time stamps, search terms, links you click, whether you open messages sent to your account, and other statistics related to your usage of the Services. We may also use tools, including third-party tools, to collect analytics data. Some of this information is collected through the use of "cookies" and other tracking technologies, such as web beacons, session replay scripts, and similar technologies ("tracking technologies"). We may also work with third party partners to employ tracking technologies.

We will collect personal information only by lawful and fair means and not in an unreasonably intrusive way. We will not collect personal information unless the information is reasonably necessary for our functions and activities. 

You are under no obligation to provide your personal information to us. If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, please see "Managing Your Information," below.

However, without certain information from you, we may not be able to supply our products to you and/or may not be able to process transactions involving you via our websites.

Location information

In some cases, we may collect limited location information. For example, we may use Google Analytics convert your IP address into a rough geolocation to understand in what areas our users are located and to improve and personalize real-u (for example, to display time data and currency data in the correct local time and currency).

Aggregated and anonymized information

We may collect information by aggregating and anonymizing other information. The aggregation and anonymization process prevents the information from being reassociated or identified with any one customer account, user, or individual. We may use aggregated and anonymized information for a wide variety of statistical and analytical purposes.

Purposes for which personal information is collected and used

In addition to any purpose notified to you at the time of collection, we collect and use your personal information for the purposes of:

1. facilitating the production, sale and distribution of our products; 
2. processing and fulfilling any orders placed by you for the purchase of our products; 
3. to administer or manage our relationship with you, including to communicate with you regarding the products purchased by you or your experiences dealing with us; 
4. providing our services to you;
5. to undertake customer surveys and analysis; 
6. our internal management needs;
7. our marketing activities;
8. responding to any enquiries or comments that you submit to us;
9. any other purpose you have consented to; and
10. any use which is required or authorised by law.

We may also collect, hold, use and disclose your personal information for direct marketing purposes, including to inform you of products, services or offers of us, our related companies or business partners that we work with.

Specifically, we may use personally identifiable information (including those contained within the Customer Information or otherwise collected by us) for the above purposes, but only as to the extent necessary for the purposes for which you have provided us with the information, to respond to inquiries or requests (including requests for customer support or technical assistance), to otherwise perform our obligations or act consistently with our Terms of Service, to respond to law enforcement or other governmental or legal authorities, and to otherwise use the information consistent with your instructions to us (both explicit, such as when you contact us directly with a request, and implied, such as when you engage us to provide you with the Services). If you wish to change these instructions, either by request, by correcting, amending, or deleting information we may have collected about you, or by opting out of certain data collection practices, please see "Managing Your Information", below.

Use of Content

Notwithstanding anything else in this Privacy Policy to the contrary, we will not use or access your Content except in the following cases: for providing the Services to you; where you (or, if you are an end user, the real-u customer through which you have an account) explicitly approve access (e.g., during a customer support inquiry); where compelled to do so in response to lawful requests by law enforcement or government regulators; where necessary to ensure the stability and security of the Services and our systems (e.g., where we have reason to believe specific Content is degrading server stability); and where necessary to protect the rights, privacy, safety, or property of you, us, or others. We may also analyse metadata related to Content (such as total number of records, file size, API volume, access logs, etc.).

 

Disclosure of personal information:

We may disclose your personal information to:

  • third-parties we ordinarily engage for any of the above purposes or to perform administrative or other business management functions including (without limitation) web hosting providers, IT systems administrators, mailing houses, payment processors, data entry service providers and electronic network administrators;
  • our professional advisors, contractors, consultants and related bodies corporate; 
  • any person or entity where you have consented to that disclosure; and
  • any person or entity to whom we are required or authorised to disclose your personal information to in accordance with the law, including government and regulatory authorities.

Security of personal information

We will take reasonable steps to protect the personal information we hold from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

We hold all personal information on secure servers and at access restricted premises. We will only permit authorised personnel to have access to such secure servers and premises. 

Personal information may also, in certain circumstances, be held on our behalf in electronic or hard copy forms by our service providers (such as electronic data storage providers or offsite document storage providers). We enter into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.

If we no longer require your personal information for any of the purposes set out in this policy, or as otherwise required by law, we will take such steps as are reasonable in the circumstances to destroy the information or to de-identify it.

Overseas Disclosures

We are not likely to disclose any personal information to overseas recipients, however where it is necessary to make any overseas disclosures we will take steps reasonable in the circumstances to ensure that the overseas recipient complies with the APPs or is bound by a similar privacy scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law. If we are likely to disclose your personal information to overseas recipients, we will update our Privacy Policy regarding the likely disclosures (including, if it is practical to do so, the countries in which the overseas recipients are located).

Access and correction 

We will take all reasonable steps to ensure that the personal information we hold is accurate, up-to-date, complete, relevant and not misleading.

Under the Privacy Act, you have a right to request access to and correction of your personal information that is collected and held by us. 

If at any time you would like to request access to or correction of the personal information that we hold about you, please contact us using any of the contact details set out below.

To obtain access to or correction of your personal information, you may have to provide us proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected.

We will take all reasonable steps to respond to a request for access to or correction of your personal information within 30 days from your request. In less complex cases, we will try to provide information within 14 days.

If we refuse a request for access to or correction of personal information, written reasons for the refusal and details of complaint mechanisms available to you will be provided.

If providing you with access requires a detailed retrieval of your personal information, a fee may be charged for the cost of retrieval and supply of information. This fee will not exceed the cost to us of retrieving and supplying the information and we will provide you with prior notice of the likely amount of the relevant fee. We will not charge you a fee for making a request for access. 

Managing Your Information

You have many choices to access information we collect about you and about how we use or disclose that information. This section details many of those choices, including how you can exercise rights you may with respect to your information (including personally identifiable information), how you can opt out of collection and use of certain types of information for certain purposes (such as marketing), and how you can use your browser or third-party tools to disable certain collection methods (such as cookies or tracking technologies).

You may access, correct, amend, or delete Customer Information we have about you by contacting us at contact@real-u.com and requesting that we change your information for you. If you wish to cancel your account, you may do so through emailing contact@real-u.com and requesting that your account be deleted. If you do, personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymised and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new real-u features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us contact@real-u.com to opt out.

Cookies and Tracking Technologies – How to Opt Out

If you would prefer not to accept cookies or otherwise wish to disable our use of tracking technologies, most browsers and mobile devices allow you to change your settings so as to notify you when you receive cookies or other tracking technologies are being used, and to choose whether or not to accept/allow it. Most browsers also allow you to disable or delete existing cookies or to automatically reject future cookies. Disabling cookies may limit your ability to use the Services.

Certain tracking technologies we use are related to advertising networks, and through those technologies we may share certain information such as IP addresses. No personally identifiable information is shared with these advertising networks, but please note that the information we share with those advertising networks might be combined with other information about you that those networks may have collected from other sources. To learn more about advertising networks and how to opt out of sharing information with them, please click here and here. If you’re in the EU, you can find additional information about your choices with respect to advertising networks and online behavioural advertising by clicking here.

Certain tracking technologies we use involve the use of session replay scripts or other scripts that run directly from your browser. If you wish to disable these tracking technologies, you can install a third-party browser analytics blocker plug-in such as Ghostery.

If you have any questions about how we or our third-party service providers use cookies or other tracking technologies that aren’t answered in this Privacy Policy, please contact us at contact@real-u.com

International Transfers (including Transfers Outside of the European Union)

We process and store information on servers located in Australia, and we may store information on servers and equipment in other countries depending on a variety of factors, including the locations of our users and service providers. By using the Services, you consent to the transfer of information (including Customer Information, Content, and personally identifiable information) to locations that may be outside of your country of residence, including Australia. You acknowledge and agree that, as a condition of providing any Content, you can legally transfer it to the United States, Australia or another country.

With respect to transfers of information out of the European Union (EU), we may process some personally identifiable information pursuant to data processing agreements that include the EU Standard Contractual Clauses.

Information from Children

Real-u is not directed to children under the age of 13 and we do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have collected personally identifiable information of a child under the age 13, we will take reasonable steps to delete such information from our files as soon as is practicable. Please contact us at contact@real-u.com if you believe we have any information from or about a child under the age of 13.

Changes to Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, revise the Privacy Policy from time to time. If a revision is material, as determined solely by us, we will notify you, for example via email. The current version will always be posted to our Privacy Policy page.

If you have any questions about this Privacy Policy, please contact us at contact@real-u.com

 

 

Privacy Complaints

If you believe that we have not dealt with your personal information in a manner that complies with the Privacy Act or the APPs, you can make a privacy complaint to us by submitting details of your complaint to us using the contact details set out below. 

You will generally be required to put your complaint in writing. 

Privacy complaints you make to us will:

  • be taken seriously;
  • be dealt with promptly;
  • be dealt with in a confidential manner; and 
  • not affect existing obligations or the commercial arrangements between you and us.

We will commence an investigation into your complaint and inform you of the outcome of the complaint following completion of the investigation. We will respond to privacy complaints and notify you of the outcome of the complaint within a reasonable time of you submitting the complaint (which is normally no longer than 30 days). 

In the event you are dissatisfied with the outcome of the complaint, you may refer your complaint to the Office of the Australian Information Commissioner.

Any privacy complaints can be submitted to us at:

Greatskin Pty. Ltd.
ACN 166 650 540
Suite 12, 358 Clarendon St.
South Melbourne 3205
Victoria, Australia

General queries or requests for information regarding privacy matters can also be submitted to us at contact@real-u.com