VRTY PRIVACY POLICIES

Click below to jump ahead to our:

• VRTY Platform Privacy Policy (https://pro.vrty.io)
• VRTY Website Privacy Policy (https://vrty.io)

VRTY PLATFORM PRIVACY POLICY

VRTY Pty Ltd (“VRTY”) operates the VRTY Virtual Reality and 360 project creation tool (https://pro.vrty.io) and its associated functions (“the Platform”).

The Platform’s functionality is specifically intended to provide a safe space for students and others in the educational space to share original Virtual Reality and 360-degree content produced by users of the VRTY platform.

To access the Platform, a responsible adult or educational institution needs to first establish a subscription account with VRTY, under which that Subscriber’s students or other minors (“Users”) may access the Platform. Subscribers are solely responsible for the actions of their Users.

Use of the Platform is subject to each user’s compliance with the Terms and Conditions and these Privacy policies. Use of the Platform is the user’s consent to abide by these Terms and Conditions and this Privacy Policy.

We are committed to protecting our users’ privacy and to complying with the Privacy Act 1988 (Cth) and applicable privacy laws and regulations, Federal and State as these relate to Personal Information. These Privacy policies apply to all users of the Platform, regardless of where that user is located. The Platform’s servers are located in Australia, hosted with Microsoft Azure. Some of the third-party service providers to whom we disclose personal information may be based in, or have servers located outside, of Australia including Singapore.

Name: Microsoft Azure, Microsoft's public cloud computing platform
Website: https://azure.microsoft.com/en-au
Data Type: Azure provides technologies used to deliver specific Microsoft Online Services to VRTY. The sub-processors for this service may process, store, or otherwise access user data in the course of helping to provide that service.
Lawful basis: https://learn.microsoft.com/en-us/compliance/regulatory/gdpr
Country where data is processed or stored: Australia only

“Personal information” means any information or opinion, whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable. This includes information or an opinion that personally identifies a user directly (e.g. name) or indirectly.

Subscribers are directed to the Terms and Conditions that apply to all people who use this Platform (https://pro.vrty.io/legal/terms). Where a User is using the VRTY Platform via a subscription by, for example, a school or other organisation, the Subscriber party is primarily responsible for the actions of Users using the Platform via that subscription and to enforce their adherence to the Terms and Conditions relating to the Platform.

VRTY respects the privacy of all the people with whom we deal, particularly as there are children using this Platform as well as adults. We are cognizant of the importance of doing all we can to operate a safe platform for all users as much of the content on this Platform is user-generated.

This Privacy Policy sets out how we:

• collect
• hold
• use and
• disclose

Subscribers’ personal information and how we do our best to maintain the quality and security of Subscribers’ personal information.

As part of our data security protocols, we use personal login processes and passwords. Generally, passwords must not be shared with, used by or disclosed to users other than the person to whom the password has been connected. In the case of organisations’ whose users who have access to VRTY via that organisation’s subscription, the subscriber-organisation may choose to manage their users’ passwords or use a common password for all their users. Where a third-party password manager is used, VRTY does not have access to, manage or control those passwords.

The Personal Information Do We Collect.

The personal information we collect about each user depends on the nature of that Subscriber’s dealings with us or what that user chooses to share with us.

The personal information we may collect about each Subscriber may include:

• the Subscriber’s name and mailing or street address;
• email address;
• phone number;
• details of the organisation or institution (e.g. school).

The personal information we may collect about each User is limited to the User’s email address and name.

VRTY may, in order to prevent a serious and imminent threat to life or health, on occasion be required or need to collect sensitive information about a person using the platform or as may otherwise be required or authorised by law. If we collect sensitive information about a user, we will do so only with the user’s consent and we will take appropriate measures to protect the security of this information.

How We Collect Your Personal Information

We collect Subscribers’ personal information directly via:

• interaction with us over the phone;
• interaction with us in person;
• interaction with us online;
• use the platform;
• participate in surveys or questionnaires.

We may also collect personal information from third parties or through publicly available sources.

How We Use Personal Information

We use personal information for many purposes in connection with our functions and activities, including:

• to provide Subscribers with information or services that user requests from us;
• to deliver a more personalised experience and service offering;
• to improve the quality of the services we offer;
• for internal administrative purposes;
• for marketing and research purposes;
• managing subscriptions which have multiple users.

Disclosure of Personal Information to Third Parties

In accordance with this Policy, we may disclose personal information to third parties in circumstances where the relevant Subscriber would reasonably expect us to disclose that information. For example, we may disclose a Subscriber’s personal information to:

• our third-party service providers (for example cloud storage, data processing and customer relations);
• our professional services advisors.

We do not disclose personal information to third party advertisers.

Transfer of Personal Information Overseas

Some of the third-party service providers to whom we disclose personal information may be based in, or have servers located outside, of Australia including Singapore.

Where we disclose personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:

• we have consent to disclose personal information to that third party; or
• we reasonably believe that the overseas recipient is subject to a law or binding scheme that is, overall, substantially similar to the APPs and the law or binding scheme can be enforced; or
• the disclosure is required or authorised by an Australian law or court / tribunal order.

How We Protect Users’ Personal Information

VRTY will take reasonable steps to ensure that the personal information that we hold is kept confidential and secure, including by:

• having a robust physical security of our premises and databases / records;
• taking measures to restrict access to only personnel who need that personal information to effectively provide services to users;
• having technological measures in place (for example, anti-virus software, fire walls).

Online Activity

Cookies

The VRTY Platform uses cookies. A cookie is a small file of letters and numbers the website puts on each user’s device if the user allows it. These cookies recognise when that device has visited our website(s) before, so we can distinguish that user from other users of the website to improve each user’s experience and improve the functionality of the Platform.

We use them only to improve users’ experience on our website(s). If a user does not wish to use the cookies, the settings on the internet browser may be adjusted so it will not automatically download cookies. However, if cookies are removed or blocked, please be aware that the browsing experience and our Platform’s functionality may be affected.

Website Analytics

The Platform uses Google Analytics to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, it may contain Personal Information.

Name: Google Analytics, Google.
Website: https://analytics.google.com/analytics/web/
Data Type: Customer Personal Data only in accordance with Instructions from Customers through the settings of the services
Lawful basis: https://www.google.com/analytics/terms/dpa/dataprocessingamendment_20130906.html
Country where data processed or stored: Singapore

Direct Marketing

We may, with a Subscriber’s consent, wish to direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to that Subscriber. These communications may be sent in various ways such as mail, SMS and email. These activities would be conducted in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth). Unless a Subscriber otherwise advises us, we will presume each Subscriber’s consent for us sending those direct marketing communications by any of those methods.

If a Subscriber indicates a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

Subscribers may opt-out of receiving marketing communications from us at any time. This can be done by following the instructions to “unsubscribe" set out in the relevant communication or by contacting us using the details set out in the “How to contact us” section below.

We do not market directly to Users.

Retention of Personal Information

We will not keep a Subscriber’s Personal Information for longer than we need to. In most cases, this means that we will only retain that data for the duration of that Subscriber’s relationship with us, unless we are required to retain that Personal Information to comply with applicable laws, for example record-keeping obligations.

How to Access and Correct Your Personal Information

We will endeavour to keep Personal Information accurate, complete and up to date.

If a Subscriber wishes to make a request to access and / or correct the Personal Information we hold, they contact us and we will endeavour to respond within ten working days. We will deal with such a request by following the procedure outlined below:

• we may require additional proof as to the Subscriber’s identification
• the Subscriber must identify the data they wish changed
• the Subscriber is responsible for providing the correct information as we cannot check it
• the requested changes will be actioned as soon as reasonably practicable.

Links to Third Party Sites

The Platform may contain links to websites operated by third parties. If any party using the Platform accesses a third-party website through the Platform, Personal Information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third-party provider or website and we are not responsible for the privacy policies or the content of any third-party provider or website. Third-party providers / websites are responsible for informing visitors to their site, about their own privacy practices and we encourage all to read their privacy policies.

Notification of Changes

VRTY reserves the right to change this Platform Privacy Policy from time to time at its sole discretion. If at some point in the future, there is a change to our VRTY Platform Privacy Policy, Subscribers and Users will be notified of the changes at least 1 day prior. Notifications will be visible to users once they login to the VRTY Platform. Continued use of the Platform indicates assent to the Platform Privacy Policy once posted.

Inquiries and Complaints

For complaints about how VRTY handles, processes or manages your Personal Information, please contact our VRTY Privacy Officer by emailing to support@vrty.io

Please allow up to ten days for VRTY to respond to a complaint. It will not always be possible to resolve a complaint to everyone’s satisfaction. If a Subscriber is not satisfied with our response to a complaint, they have the right to contact the Office of Australian Information Commissioner (at www.oaic.qov.au/) to lodge a complaint.

How to Contact Us

For any questions or concerns in relation to our handling of Personal Information or this Policy, contact us for assistance as follows:
Email: support@vrty.io
Post: C106, 11 Chandos Street, St Leonards, NSW, Australia 2065
Attention: VRTY Privacy Officer

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VRTY WEBSITE PRIVACY POLICY

The VRTY website (https://vrty.io) (the “Site”) is owned and operated by VRTY Pty Ltd (“VRTY”).

We are committed to protecting the privacy of Visitors while they interact with the content on the Site. This Privacy Policy applies to the Site only. For additional policies that may apply when you become a VRTY Platform Subscriber or User, please check the VRTY Platform Terms and Conditions and the VRTY Platform Privacy Policy.

Because we gather certain types of information about Visitors, we want Visitors to understand what information we collect, how we collect it, how that information is used, and how Visitors can control our disclosure of it. Each Visitor agrees that their use of the Site signifies their assent to this Privacy Policy.

Information Collected

We collect two types of information from Visitors:

• information that Visitors voluntarily provide to us (e.g. through a voluntary registration process, sign-ups or emails); and
• information that is derived through automated tracking mechanisms.

Voluntary Information for Services and Features

We collect personally identifiable information when a Visitor chooses to use certain other features of the Site, including:

• making purchases;
• consenting to receive email or text messages about upcoming promotions or events;
• consenting to receive email or subscribe to our mailing list.

When Visitors choose to use these additional features, we require them to provide their “Contact Information” in addition to other personal information that may be required to complete a transaction such as a phone number, billing and shipping addresses and credit card information.

Cookies

Our site uses “cookies” and other tracking technologies. Most browsers allow a Visitor to control cookies, including whether or not to accept them and how to remove them.

Visitors may set most browsers to notify them if they receive a cookie, or may choose to block cookies with the browser.

How We Use Your Information

VRTY only uses Visitors’ personal information for the original purposes it was given. Personal information will not be sold or otherwise transferred to unaffiliated third parties without that Visitor’s approval at the time of collection.

VRTY will not disclose, use, give or sell any personal information to third parties for any purposes other than to our suppliers and other third parties who need to know in order to deliver services on behalf of VRTY unless required to do so by law. Further, VRTY reserves the right to contact Visitors regarding matters relevant to the underlying service provided and/or the information collected.

Please note that personally identifiable information is used only to provide Visitors with a more enjoyable, convenient online experience and to help us identify and/or provide information, products or services that may be of interest to you. We use personally identifiable information to support and enhance use of the Site and its features, including without limitation: fulfilling orders; providing customer service; and otherwise supporting the functionality of the Site.

We may permit certain trusted third parties to track usage, analyse data such as the source address that a page request is coming from, Visitors’ IP address or domain name, the date and time of the page request, the referring website (if any) and other parameters in the URL. This is collected in order to better understand our website usage and enhance the performance of services to maintain and operate the Site and certain features on the Site. We currently use third parties to host the Site; operate various features available on the Site; send emails; analyse data; provide search results and links and assist in fulfilling Visitors’ orders.

We may share personally identifiable or other information but only with our parent, subsidiaries, divisions, and affiliates.

We may transfer personally identifiable information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganisation, stock sale or other change in control.

VRTY may disclose Contact Information in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our terms and conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities.

Visitors will receive notice should their personally identifiable information be provided to any third party for any reason other than as set forth in this Privacy Policy, and you will have an opportunity to request that we not share such information.

We use non-identifying and aggregate information to better design our website and for business and administrative purposes. We may also use or share with third parties for any purpose aggregated data that contains no personally identifiable information.

How We Protect Your Information

We are committed to protecting the information we receive from Visitors. We take appropriate security measures to protect Visitors’ information against unauthorised access to or unauthorised alteration, disclosure or destruction of data. To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

Accessing and Updating Your Personal Information and Preferences

We provide mechanisms for updating and correcting personal information for many of our services. Visitors may access and update registration information and preferences to receive email or other communications from us by sending an email to support@vrty.io.

Email Choice/Opt-Outn

If any Visitor who receives an email from the Site and would prefer not to receive such communications in the future, Visitors can do so by following the instructions in the emails. In addition, Visitors may send an email to support@vrty.io. We will make commercially reasonable efforts to implement opt-out requests promptly, but the Visitor may still receive communications from us for up to ten business days as we process the request.

Disclaimer to Securityn

By consenting to the Website Privacy Policy, Visitors acknowledge that no data transmission over the Internet is completely secure. We cannot guarantee or warrant the security of any information Visitors provide to us; such information is transmitted to us at Visitor’s own risk.

Notification of Changes

VRTY reserves the right to change this Website Privacy Policy from time to time at its sole discretion. If, at some point in the future, there is a change to our VRTY Website Privacy Policy, unless we obtain a Visitor’s express consent, such change will only apply to information collected after the revised Privacy Policy took effect. Continued use of the Site indicates a Visitor’s assent to the Website Privacy Policy as posted.

Contact Informationn

If a Visitor has any questions or concerns regarding this VRTY Website Privacy Policy please contact us.