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Privacy Policy
Date: 18 July 2017

VIX Verify Pty Ltd ABN 67 111 307 361 (VIX Verify), is a private identity verification services provider and a gateway service provider for the Commonwealth Document Verification Service. VIX Verify Pty Ltd was previously named Edentiti Pty Ltd, with the same ABN (67 111 307 361) and continues with the same management, staff and facilities as held by Edentiti Pty Ltd.

VIX Verify is committed to complying with the Australian Privacy Principles. It understands the importance of protecting the privacy of individuals. This Privacy Policy, therefore, sets out:

  • VIX Verify’s procedures in relation to the collection, use, disclosure, storage and protection of information that VIX Verify collects from or about individuals (personal information); and
  • the rights of individuals to seek access to and correction of personal information which VIX Verify holds about them.

This Privacy Policy is divided into 5 principal sections:

If you would like VIX Verify to send you a MS Word or PDF copy of this Privacy Policy (at no charge), please use the contact details at the end of this Privacy Policy to request a copy. If you require a copy of this Privacy Policy in a different format, VIX Verify will use its reasonable efforts to comply with your request. If VIX Verify cannot supply a copy of the Privacy Policy in the format you have requested, VIX Verify will contact you to discuss your requirements and attempt to identify and agree an alternative format in which the copy of the Privacy Policy can be provided to you.

VIX Verify welcomes your comments on this Privacy Policy. If you would like to make a comment, you should contact VIX Verify using the contact details set out in the Contact Details section of this Privacy Policy

1. VISITORS

A visitor is a person who visits VIX Verify’s website or otherwise contacts VIX Verify but to whom VIX Verify does not provide any goods or services or who does not undertake a trial of any products or services provided by VIX Verify (Visitor).

VIX Verify does not attempt to identify a Visitor when the Visitor is accessing the website or otherwise contacting VIX Verify except where the Visitor wishes to undertake a trial of any of VIX Verify’s services (in which case, you should refer to section 2 of this Privacy Policy). VIX Verify will not collect personal information about any Visitor unless the Visitor expressly provides this to VIX Verify (for example, by sending an email or completing an online registration form or online inquiry form).

If a Visitor wishes to undertake a Trial, the Visitor cannot undertake the Trial unless the Visitor provides an email address.

Where possible, VIX Verify’s systems will allow a Visitor to communicate with VIX Verify on an anonymous basis or by using a pseudonym.

2. TRIAL USERS

A trial user is a person who visits VIX Verify’s website or otherwise contacts VIX Verify and undertakes a trial of any products or services provided by VIX Verify or visits the public demonstration pages of VIX Verify’s website (Trial User).

A Trial User will only be able to undertake a trial of products or services provided by VIX Verify if the Trial User provides an email address.

This section is divided into the following subsections:

2.1 Why VIX Verify collects personal information

VIX Verify collects personal information of Trial Users:

  • to confirm that the Trial User is a person who wishes to use the products and services of VIX Verify on a trial basis; and
  • for the purposes of communicating with the Trial User.

2.2 What personal information VIX Verify collects

VIX Verify collects only the Trial User’s email address. It is not possible to undertake a trial of any products or services provided by VIX Verify or visits the public demonstration pages of VIX Verify’s website unless a user provides the user’s email address. Therefore, it will not be possible for a Trial User to communicate with VIX Verify on an anonymous basis or using a pseudonym.

2.3 How VIX Verify collects personal information of Trial Users

VIX Verify will collect information directly from each Trial User.

2.4 How VIX Verify obtains consent from Trial Users

In most cases, either before or at the time of collecting the personal information, VIX Verify will obtain the consent of the Trial User to the collection of the personal information.

2.5 How VIX Verify uses personal information of Trial Users

VIX Verify will use the personal information to monitor usage patterns, to determine whether the Trial User is a genuine user of the trial products and services and to communicate with the Trial User including for the purposes of marketing.

VIX Verify will not disclose any personal information to any individual or entity without the express permission of the Trial User.

2.6 Disposal or destruction of personal information

VIX Verify will delete all personal information on conclusion of trial arrangement except in those cases where VIX Verify is required to maintain a record.

3. INDIVIDUAL USERS

An Individual User is a person who visits VIX Verify’s website or otherwise contacts VIX Verify and to whom VIX Verify provides products or services.

VIX Verify’s identity verification service is a service which verifies the identity of an Individual User thereby allowing the Individual User to prove that the Individual User is who the individual say he or she is including to allow the Individual User to electronically present himself or herself to a trusted independent entity with whom the Individual User may already have a relationship.

This section is divided into the following subsections:

3.1 Why VIX Verify collects personal information

VIX Verify collects personal information of Individual Users:

  • to provide identity verification services to the Individual Users;
  • for the purposes of communicating with the Individual User;
  • for the purpose of providing information to specific organisations with whom an the Individual User has authorised VIX Verify to communicate; and
  • to provide services related to the services and purposes described above.

To provide the VIX Verify’s identity verification service, the information collected by VIX Verify is compared against an information database.

VIX Verify also collects personal information of Individual Users which is reasonably necessary to undertake a function or activity (for example, to manage and administer VIX Verify and conduct its business).

3.2 What personal information VIX Verify collects

VIX Verify collects the following information about Individual Users:
(a) name;
(b) address;
(c) birthdate;
(d) time and date of use of VIX Verify; and
(e) email address.

Additional information may be required depending on the services which the individual user wishes to acquire from VIX Verify and VIX Verify will, notify the Individual User of the requirement to collect this additional information as specified in section 3.4 of this Privacy Policy.

Where possible, VIX Verify’s systems will allow an Individual User who wishes to communicate with VIX Verify on an anonymous basis or by using a pseudonym. However, it will not be possible for an Individual User to communicate with VIX Verify on an anonymous basis or using a pseudonym if the Individual User requires assistance in relation to its account or the information which it has provided to VIX Verify for the purposes of establishing or using its account.

3.3 How VIX Verify collects personal information of Individual Users

VIX Verify will collect information directly from each Individual User or from third parties whom the Individual User has authorised VIX Verify to contact.

3.4 How VIX Verify obtains consent from an Individual User

In most cases, either before or at the time of collecting the personal information, VIX Verify will obtain the consent of the Individual User to the collection of the personal information. If VIX Verify cannot obtain the consent of the Individual User before or at the time of collection, it will obtain consent as soon as practical after the collection.

3.5 How VIX Verify uses personal information of an Individual User

The VIX Verify service enables an Individual User to use the Individual User’s personal information for the Individual User’s own purposes. VIX Verify uses the personal information of an Individual User as required to provide products and services to the Individual User. This may include disclosure of personal information to persons whom the Individual User has authorised VIX Verify to contact or provide the personal information for the purposes of providing the verification service to the Individual User.

VIX Verify will not disclose any personal information to any individual or entity without the express permission of the Individual User.

3.6 Access to personal information

Individual Users may access all the personal information they have provided to VIX Verify or which VIX Verify has collected and may update or delete it except in those cases where VIX Verify or an organisation to which VIX Verify has provided the personal information as part of VIX Verify’s provision of the verification services is required to maintain a record. This includes retention of records for compliance with the Anti-Money laundering and Counter-Terrorism Financing Act 2006 or other laws or regulations.

3.7 Disposal or destruction of personal information

VIX Verify will delete all personal information on conclusion of the Individual User’s arrangements with VIX Verify except in those cases where VIX Verify is required to maintain a record.

4. ORGANISATION REPRESENTATIVES

An Organisation Representative is a person who is dealing with VIX Verify in his or her capacity as the representative of an organisation who has appointed VIX Verify as its agent for the purposes of the Commonwealth Attorney-General’s Department’s Document Verification Service and who is authorised to act on behalf of the organisation.

This section is divided into the following subsections:

4.1 Why VIX Verify collects personal information

VIX Verify collects personal information of an Organisation Representative to:

  • to provide services to the organisation which the Organisation Representative represents;
  • for the purposes of communicating with the Organisation Representative and the organisation which the Organisation Representative represents;
  • for the purpose of managing VIX Verify’s contract with the organisation which the Organisation Representative represent; and
  • to provide services related to the services and purposes described above.

VIX Verify also collects personal information of Organisation Representatives which is reasonably necessary to undertake a function or activity (for example, to manage and administer VIX Verify and conduct its business).

4.2 What personal information VIX Verify collects

VIX Verify collects the following information about Organisation Representatives:
(a) name;
(b) address;
(c) birth date;
(d) email;
(e) telephone number;
(f) fax number; and
(g) name of the organisation which the Organisation Representative is representing and other information which is required to identify the organisation including ABN, address, telephone number; fax number and website.

Where possible, VIX Verify’s systems will allow an Organisation Representative to communicate with VIX Verify on an anonymous basis or by using a pseudonym. However, it will not be possible for an Organisation Representative to communicate with VIX Verify on an anonymous basis or using a pseudonym if the Organisation Representative requires assistance in relation to VIX Verify’s arrangements with the organisation which the Organisation Representative represents or the Organisation Representative’s account.

4.3 How VIX Verify collects personal information of Individual Users

VIX Verify will collect information directly from each Organisation Representative.

4.4 How VIX Verify obtains consent from an Organisation Representative

In most cases, either before or at the time of collecting the personal information, VIX Verify will obtain the consent of the Organisation Representative to the collection of the personal information. If VIX Verify cannot obtain the consent of the Organisation Representative, it will obtain consent as soon as practical after the collection.

4.5 How VIX Verify uses personal information of an Organisation Representative

VIX Verify does not anticipate disclosing the personal information of an Organisation Representative to enable VIX Verify to provide products and services to the organisation which the Organisation Representative represents.

4.6 Access to personal information

Organisation Representative may access all the personal information they have provided to VIX Verify or which VIX Verify has collected and may update this information and update it or delete it except in those cases where VIX Verify is required to maintain a record.

4.7 Disposal or destruction of personal information

VIX Verify will delete all personal information on:

  • conclusion of the arrangements between VIX Verify or the organisation which the Organisation Representative represents except in those cases where VIX Verify is required to maintain a record; or
  • when the Organisation Representative notifies VIX Verify that it is no longer the representative of the organisation; or
  • when the organisation which the Organisation Representative represents notifies VIX Verify that it is no longer the representative of the organisation,

except in those cases where VIX Verify is required to maintain a record.

5. PROVISIONS APPLICABLE TO ALL PERSONS FROM WHOM VIX VERIFY COLLECTS PERSONAL INFORMATION

This section is divided into the following subsections:

5.1 Unsolicited personal information

There may be situations in which VIX Verify receives personal information about a person even though VIX Verify has not requested any personal information about an individual or has not requested the particular information which has been received about an individual (unsolicited personal information).

If VIX Verify receives any unsolicited personal information, it will, within a reasonable period of receipt of the unsolicited personal information, review the unsolicited personal information to determine if it is reasonably necessary for its functions. If it is, VIX Verify will handle the information in the same way as it handles the information we collect from a person. If VIX Verify does not need the information, VIX Verify will destroy the information or de-identify it.

5.2 Usage patterns

VIX Verify’s web server collects information on the usage patterns of people visiting VIX Verify’s website. The information is collected each time a user visits VIX Verify’s website. Except in relation to a Trial User, it is not used to identify browsing activities of any individual user but is collected for statistical purposes. The information collected consists of:

  • the date and time of visits;
  • number of users who visit the website;
  • traffic patterns and pages viewed.

This data will be used to research VIX Verify’s website and product and to evaluate, develop and improve its usability.

5.3 Cookies

VIX Verify’s website uses session based cookies to keep Individual Users and Organisation Representatives logged in during a session. No other cookies or trackers are used.

5.4 Disclosure of personal information by VIX Verify

VIX Verify will not disclose information that identifies an individual, or enables an individual to be identified except as:

  • specified in this Privacy Policy;
  • authorised by the individual;
  • as required under applicable laws; or
  • as directed by courts, tribunals or other bodies having authority over VIX Verify.

5.5 Transfer of personal information outside Australia

In providing verification services to an Individual User, VIX Verify will be required to transfer personal information of an Individual User outside Australia if the Individual User provides verification information from a country other than Australia. In this instance, personal information will be transferred by VIX Verify to the country from which the verification information provided by the Individual User originates. Therefore, given the possible scope of Individual Users, it is possible that VIX Verify may transfer personal information of an Individual User to a country which is a member country of the United Nations or a country having observer status at the United Nations.

By giving VIX Verify your personal information, you consent to such transfer and disclosure. In addition, we believe that the recipients of such information are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the applicable Australian privacy laws.

5.6 Data security and storage

All personal information held by VIX Verify is protected from unauthorised access through the use of secure passwords and user logons and other forms of biometric verification.
VIX Verify stores all personal information that it collects securely in a manner that is sufficient to prevent misuse and loss, unauthorised access, modification or disclosure of personal information. VIX Verify maintains a high level of data security by implementing:

  • physical security to prevent unauthorised entry to our premises, by installing systems to detect unauthorised access and secure containers for storing paper-based personal information;
  • computer and network security to protect computer systems and networks for storing, processing and transmitting personal information;
  • communications security to protect communications via data transmission and to prevent unauthorised intrusion into our computer network
  • personnel security, through VIX Verify’s personnel security measures and background checking procedures to limit access to personal information only by authorised staff and for only approved purposes.

5.7 Government related identifiers

VIX Verify does not use or disclose any government identifier or identifier issued by another person.

5.8 Concerns about personal information

Users can contact VIX Verify to address any concerns that they have about their personal information.

If you would like access to the personal information which VIX Verify holds about you or a person whom you are authorised to represent, please contact VIX Verify using the contact details set out in the Contact Details section of this Privacy Policy. Your request should specify the format in which you wish to be provided the personal information (for example, in person, by email, by telephone, hard copy or other electronic record). This application is free of charge. However, VIX Verify may make a reasonable charge for providing access to you. If VIX Verify wishes to charge you to access the personal information, VIX Verify will notify you of this charge prior to giving you access to the personal information.

5.9 Response to request for access to personal information

If you make a request to access personal information, VIX Verify will respond to your request within 30 days of the date of your request. If VIX Verify cannot respond within this period, VIX Verify will notify you of the delay, the reasons for the delay and the date by which VIX Verify will provide a response.

5.10 Process for accessing personal information

If VIX Verify agrees to give you access to your personal information, the following process will apply:

  • No charge for access – VIX Verify will notify you of its decision and (where you have requested that the information be provided to you by email, hard copy or other record that can be delivered to sent to you), VIX Verify will also provide the personal information to you at the same time (except as set out below)
  • Access charge – VIX Verify will notify you of its decision and the proposed charge for giving you access and the payment terms and method of payment. If you wish to discuss the proposed charge with VIX Verify, you should contact the VIX Verify representative nominated in the notice. Once you have paid the access charge ), VIX Verify will provide the personal information to you (except as set out below).
  • Form of access if different from format requested – If VIX Verify concludes acting reasonably, that it is not possible or practicable for VIX Verify to provide the personal information in the format you have requested (for example because of the volume or nature of the personal information or your needs), VIX Verify will contact you to agree a format in which VIX Verify can give you access to the personal information. If you have requested access by in person or by telephone, VIX Verify will contact you to arrange the time and place at which you may access the personal information.

5.11 Refusing access to personal information

VIX Verify is entitled to refuse a request for access in the circumstances specified in the Australian Privacy Principles. If VIX Verify decides to refuse your request, VIX Verify will notify you of its reasons (except where it is permitted to refuse to provide reasons). VIX Verify will consult with you to identify an alternative means of giving you access to the personal information which may include reducing the scope of request or giving you access through an agreed intermediary.

If you disagree with VIX Verify, you may make a complaint as described in the Complaints section of this Privacy Policy.

5.12 Quality of personal information and correction of personal information

VIX Verify makes reasonable efforts to ensure that the information that it collects is accurate, up-to-date, complete and relevant both at the time of initial collection and during the period that VIX Verify holds the personal information.

If you consider that any personal information that VIX Verify holds about you is inaccurate, out-of-date, incomplete, irrelevant or misleading and you wish to have the information corrected, you should contact VIX Verify using the contact details set out in the Contact Details section of this Privacy Policy. VIX Verify will respond to your request within 30 days. This application is free of charge.

If VIX Verify accepts the request, it will take such steps as are reasonable in the circumstances to correct the information to ensure that, having regard for the reasons for which the information is held, the information is inaccurate, out-of-date, incomplete, relevant and not misleading.

If VIX Verify refuses the request:

  • VIX Verify will send you a written notice explaining the reasons for the refusal (except where it is unreasonable to provide an explanation), the complaint mechanism which you may follow and other matters which VIX Verify is required to include; and
  • you may request that VIX Verify associate with the personal information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. VIX Verify will take reasonable steps (given the circumstances) to associate the statement in such a way to make it apparent to users of the information.

5.13 Complaints

If you wish to make a complaint about:

  • this Privacy Policy;
  • the manner in which VIX Verify has implemented this Privacy Policy; or
  • any other matter relating to the personal information VIX Verify holds about you or your dealings with VIX Verify in relation to your personal information,

please contact VIX Verify using the contact details set out in the Contact Details section of this Privacy Policy. All complaints will be considered by VIX Verify’s privacy officer who may contact you to obtain further details of your complaint and to better understand your complaint so that it resolved as quickly as possible.
VIX Verify aims to resolve all disputes in a manner which is satisfactory to both you and VIX Verify. There may be circumstances where you are not satisfied with the manner in which VIX Verify has resolved your complaint. If you are not satisfied with the manner in which VIX Verify deals with your complaint, you may complain to the Office of the Australian Information Commissioner (see http://www.oaic.gov.au/).

5.14 Changes to this Privacy Policy

VIX Verify reserves the right to change this Privacy Policy as required to maintain compliance with the Australian Privacy Principles and other applicable laws, to comply with changes in technology or to facilitate changes in its business. VIX Verify will, if possible, give prior notice of its intention to change this Privacy Policy. If VIX Verify considers it necessary, it will consult with the Office of the Australian Information Commissioner or other appropriate government representatives and other representative groups before implementing any change to this Privacy Policy. However, there may be circumstances where VIX Verify considers that prior notice or prior consultation is not required or where it is not possible for VIX Verify to give prior notice of a change to this Privacy Policy or undertake consultation before changing this Privacy Policy.

When this Privacy Policy is updated, those updates will appear on this page. VIX Verify will ensure that changes to this Privacy Policy are identified in each update. VIX Verify will also ensure that prior versions of the Privacy Policy can be accessed.

5.15 United Kingdom Data Protection Act 1998

VIX Verify is a registered data controller under the terms of the Data Protection Act in the United Kingdom. VIX Verify’s registration number is ZA215360. VIX Verify’s registration and notification of its uses of personal data can be viewed as part of the Public Register of Data Controllers maintained by the Information Commissioner’s Office at https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/

5.16 Contact Details

If you have any questions or comments about this Privacy Policy, would like to request a copy, request access to personal information held about you or make a complaint, please contact:
The Privacy Officer
VIX Verify Pty Ltd
PO Box 4863
Sydney NSW 2001
AUSTRALIA
e-mail: info@vixverify.com

© 2017 VIX Verify Pty. Ltd. All rights reserved. ABN 67 111 307 361.