GVDP PTY LTD – PRIVACY POLICY
GVDP Pty Ltd ABN 34 657 216 941 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website, hardware and platform, which intends to assist first responders in responding to incidents involving people with vulnerabilities, to minimise the risk of harm to the person with vulnerabilities (Services) or when otherwise interacting with you.
The information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
If you are a governmental or regulatory authority:
- first responders’ names, badge numbers and office telephone numbers
- your credit card or other payment details (through our third party payment processor Stripe);
- details of services we have provided to you and/or that you have enquired about, and our response to you;
- support requests submitted to us and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Services and/or accounts from which you permit us to collect information; and
- any other personal information requested by us and/or provided by you or a third party.
In respect of people with vulnerabilities, your (or their):
- name, date of birth and age, weight, address and email address;
- emergency contact name and details;
- sensitive information as set out below;
- geo-location data;
- details of services we have provided to you and/or that you have enquired about, and our response;
- browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- any other personal information requested by us and/or provided by you or a third party.
If you are the legal guardian of a person with vulnerabilities:
- your name;
- your contact details, including your email address, address and/or telephone number;
- details of services we have provided to you and/or that you have enquired about, and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- any other personal information requested by us and/or provided by you or a third party.
If you are an emergency contact of a person with vulnerabilities:
- your name; and
- your contact details, including your email address, address and/or telephone number.
If you are a first responder:
- your name and date of birth; and
- your contact details, including your work email address and/or telephone number;
- your identification, credentials and qualifications including your badge number;
- the organisation your work for and the State, city or precinct that you work in;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour; and
- any other personal information requested by us and/or provided by you or a third party.
If you otherwise visit our website:
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- Information you provide to us, including through feedback, customer surveys or otherwise; and
- details of services we have provided to you and/or that you have enquired about, and our response to you.
Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.
Sensitive information: The types of sensitive information we may collect about you include:
In respect of people with vulnerabilities:
- information relating to your (or their) health and medical condition; and
- any triggers that may agitate you (or them) and any de-escalation techniques that may help you (or them).
Unless otherwise permitted by law, we will not collect sensitive information about you (or them) without first obtaining your consent.
How we collect personal information
We collect personal information in a variety of ways, including:
- Directly: We collect personal information which you directly provide to us, including e.g. when you register for an account via the platform, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
- Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as e.g. when you use our website, in emails, over the telephone and in your online enquiries.
- From third parties: If you are an emergency contact of a person with vulnerabilities, we collect personal information from the person with vulnerabilities or their legal guardian. We may otherwise collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
Why we collect, hold, use and disclose personal information
Personal information: We may collect, hold, use and disclose personal information for the following purposes:
If you are a government or regulatory authority or as a first responder:
- to enable you to access and use our platform, including to provide you with a login;
- to contact and communicate with you about our Services, including in response to any support requests you lodge with us or other enquiries you make with us;
- for internal record keeping, administrative, invoicing and billing purposes;
- for analytics, including to operate and improve our Services;
- to comply with our legal obligations and resolve any disputes that we may have; and/or
- if otherwise required or authorised by law.
In respect of people with vulnerabilities:
- to enable you (or them) to access and use our platform, including to provide you (or them) with a login;
- to assist first responders in responding to any incidents which may involve you (or them), for your safety;
- to comply with our legal obligations and resolve any disputes that we may have; and/or
- if otherwise required or authorised by law.
If you are the legal guardian of a person with vulnerabilities:
- to enable you to access and use our platform, including to provide you with a login;
- to allow first responders to contact you in case of emergency;
- to comply with our legal obligations and resolve any disputes that we may have; and/or
- if otherwise required or authorised by law.
If you are an emergency contact of a person with vulnerabilities:
- to allow first responders to contact you in case of emergency; and/or
- if otherwise required or authorised by law.
As If you are a first responder:
- to enable you to access and use our platform, including to provide you with a login;
- to comply with our legal obligations and resolve any disputes that we may have; and/or
- if otherwise required or authorised by law.
If you otherwise visit our website:
- to provide our website to you;
- for analytics, market research and business development, including to operate and improve our Services and associated applications; and
- if otherwise required or authorised by law.
Sensitive information: In respect of people with vulnerabilities (or their legal guardian), we only collect, hold, use and disclose sensitive information for the following purposes:
- any purposes you (or they) consent to;
- the primary purpose for which it is collected to assist us in providing our Services, so as to allow first responders in emergencies or incidents involving you (or them) to identify that you (or them) are a person with vulnerabilities and to assist them in managing the emergency or incident;
- secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you (or them);
- to contact emergency services, or to speak with your (or their) legal guardian or emergency contact person where we reasonably believe there is a serious risk to the life, health or safety of you (or them) or another person and it is impracticable for us to obtain your (or their) consent; and
- if otherwise required or authorised by law.
Our disclosures of personal information to third parties
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) emergency services, IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- our existing or potential agents or business partners;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for the Services;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Azure or other relevant analytics businesses; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Google Analytics: We have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Google Display Network Impression reporting etc. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
Overseas disclosure
We may store personal information overseas, including in the United States of America. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information outside of Australia, including but not limited to, the United States of America.
Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our assessment of your needs and preferences and the services you may expect from us and our ability to provide our Services to you.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Use of Google API Services (this section applies to personal information accessed through Google API Services)
We use Google’s Application Programming Interface (API) Service to [e.g. access your email account to read your emails in order to enable you to log into our application.
Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).
We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.
We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.
We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.
We don’t allow humans to read the personal information unless
- we have first received your consent to view specific messages, files or other data;
- it is necessary for security purposes (such as investigating a bug or abuse);
- our use is limited to internal operations and the personal information (including derivations) have been aggregated and anonymised.
These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.
We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.
Use of geo-localisation data
We collect your precise or approximate location via our mobile application for the following purposes:
- if you are a person with vulnerabilities, to connect you to the appropriate users of the platform and enable those users to locate you in cases of emergencies or incidents, and to allow your legal guardian to locate you to check on your website;
- for security and safety;
- to prevent and detect fraud; and
- as permitted by law.
We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
info@gvdp.com
GVDP Pty Ltd ABN 34 657 216 941
Email: info@gvdp.com
Last update: 6 July 2022