Privacy Policy

VRTY Pty Ltd (VRTY.io) operates the VRTY.io Virtual Reality and 360 project creation tool and its associated functions (“the Platform).

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 in the USA, the EU and Asia.

“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.

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

VRTY.io 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

users’ personal information and how we do our best to maintain the quality and security of users’ 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 institutions’ whose users who have access to VTRY.io via that institution’s subscription, the subscriber-institution 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.io does not have access to, manage or control those passwords.

Adult users are responsible for everything they upload to the Platform. Users aged less than 18 must be under the supervision of a responsible adult or organisation (usually the subscriber to VRTY.io), to ensure all content with which they deal, is age-appropriate.

The personal information do we collect.

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

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

• the user’s name and mailing or street address;
• email address;
• phone number
• details of the organisation or institution (e.g. school) to which a user is connected via that organisation’s subscription to the Platform.

VRTY.io 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 users’ personal information directly from each user when they:

• interact with us over the phone;
• interact with us in person;
• interact with us online;
• use the platform;
• participate in surveys or questionnaires;
• subscribe to our mailing list;

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 users 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 user/s would reasonably expect us to disclose that information. For example, we may disclose a user’s personal information to:

• our third party service providers (for example cloud storage, data processing and customer relations);
• our professional services advisors;
• a students’ school or institution.

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 in the USA, the EU and Asia.

Where we disclose your 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:

• you have given us your 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.io 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.io 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 do not use cookies to identify users. We use them only to improve users’ experience on our website(s). If a user does not wish to use the cookies, users can adjust the settings on their internet browser 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 a user’s Personal Information.

Direct marketing

We may, with a user’s consent, wish to direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to that user. 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 user otherwise advises us, we will presume each user’s consent for us sending those direct marketing communications by any of those methods.

If a user indicates a preference for a method of communication, we will endeavour to use that method whenever practical to do so. Where a user is not yet 18 years old, consent must be from a responsible adult or guardian. Where a user is using the Platform via an organisation’s subscription, consent must be from that subscriber.

Users 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.

Retention of personal information

We will not keep a user’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 user’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 users’ Personal Information accurate, complete and up to date.

If a user wishes to make a request to access and / or correct the Personal Information we hold, the user should 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 user’s identification
• the user must identify the data they wish changed
• the user 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 users access 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 you about their own privacy practices and we encourage you to read their privacy policies.

Inquiries and complaints

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

Note we may require proof of your identity and full details of your request before we can process your complaint.

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

How to contact us

If you have a question or concern in relation to our handling of your personal information or this Policy, you can contact us for assistance as follows:

Email: support@vrty.io
Post: Suite 301, 46-56 Kippax Street, Surry Hills NSW, Australia 2010
Attention: VRTY.io Privacy Officer