IYARN PTY LTD PRIVACY POLICY

1. Introduction

At iyarn Pty Ltd (“us”, “we”, “our” or “iyarn”), we are committed to respecting your privacy and complying with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). This privacy policy explains how we treat and use your personal information. By using the iyarn website, app or other services (referred to collectively in this privacy policy as “iyarn”) and agreeing to this privacy policy, you consent to everything stated in this privacy policy in relation to your personal information.

2. Your consent in relation to personal information

By providing personal information to us, you consent to our collection, retention, use and disclosure of your personal information in accordance with this policy. If you do not agree with the provisions of this policy then you should not provide us with your personal information and/or you should notify us which provision you do not agree to.

3. What is personal information?

The Privacy Act defines ‘Personal Information’ as information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or not.

4. Collecting personal information

We may collect your personal information including, but not limited to, the following:

(a) information that you provide to us when registering with us and completing your profile, such as your name, email address, date of birth, areas of focus / challenges you are looking to overcome in your use of iyarn, the types of work are you involved with that you may use iyarn for, your occupation / industry role and reasons why you want to use iyarn;

(b) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your first name, last name and email address); and

(c) information that you provide to us when using iyarn, or that is generated in the course of the use of iyarn (including the timing, frequency and pattern of service use); and

(d) information about your computer and about your visits to and use of iyarn. 

5.  Collection of sensitive information

We do not require you to submit sensitive information (as defined in the Privacy Act). 

Some of iyarn’s services allow you to provide sensitive information to us voluntarily. For example, in the context of our integrations with wearable devices and wearable data visualisation services, the health information that you may provide us can include (without limitation) heart rate data, exercise periods and ECG scans. 

You provide your express consent to us: 

1. collecting and storing any sensitive information which you provide to us voluntarily on our servers subject to our data security undertakings described in this policy; and
2. sharing your health information with designated health professionals. 

We do not accept any responsibility or liability in connection with disclosure of health information or other sensitive information that you provide us in accordance with your consent under this policy or its accessibility by business administrators of iyarn accounts.

The sole purpose of wearable data visualisation is to support the well-being of our users and is not used as a medical device or clinical decision support device. We are not health professionals and cannot be responsible for acting or failing to act in relation to any health information that you provide to us.  

6. Using personal information

Iyarn will not sell your personal information to any third party. 

We will only use your personal information for the purposes specified in this policy. We will not supply your personal information to any third party for the purpose of their or any other third party’s direct marketing

We may use your personal information to (as applicable):

(a) enable your use of iyarn and enable us to supply the iyarn services to you, including personalising iyarn for you;

(b) send you non-marketing commercial communications;

(c) send you email notifications that you have specifically requested;and

(d) send you support emails.

1. We may use personal information in an aggregated and anonymised form for the purpose of improving iyarn’s services to all users, including for testing, benchmarking and other statistical purposes.  Such use will never identify any individual data subject.

iyarn’s customer support services utilise Artificial Intelligence (AI) technology provided by third parties.  Whilst any support requests you make to iyarn may be shared with such AI technology providers for this purpose, your identity details will not be provided to them.  

7. Disclosing personal information

We may disclose your personal information:

1. to our security cleared authorised employees; and

(b) to the extent required by law or order of a court or other regulatory authority.

Except as provided in this policy, we will not provide your personal information to third parties.

All iyarn’s financial transactions with users are handled through our payment services providers Paypal, Stripe and Samcart. You can review the payment services provider’s terms of service and privacy policy through their respective websites. We will share information with our payment services provider only to the extent necessary for the purposes of processing payments you make via our website, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by us. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.

8. No international data transfers

The personal information that we collect is stored and processed in Australia.  We do not transfer personal data internationally.

9. Retaining personal information

Personal information that we process for any purpose or purposes will not be kept for longer than is necessary for that purpose or those purposes, subject to exceptions that require us to retain data for a longer period.

10. Security of personal information

iyarn will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. iyarn has obtained ISO27001 compliance certification in respect of its information security management and gained Right-Fit-For-Risk Cyber Security Accreditation. We use security precautions such as firewalls and passwords to protect your personal information.  All electronic financial transactions entered into through our website will be protected by encryption technology.

However, the internet is not a secure environment and we cannot guarantee the absolute security of personal information. Subject to our obligations under applicable privacy and data protection laws, if you send us personal information, then you do so at your own risk.

You are responsible for keeping the password you use for accessing iyarn confidential; we will not ask you for your password (except when you log in to iyarn).

11. Your rights

You may instruct us to;

1. delete any personal information we hold about you, subject to exceptions that require us to retain data for a longer period; and/or
2.  provide you with any personal information we hold about you on condition that you provide sufficient evidence of your identity. 

12. Third party platforms and websites

The iyarn API may be integrated into third party platforms that provide ‘white-labelled’ instances of the iyarn product. The operators of such third party platforms may have access to personal information within iyarn.  Whilst iyarn will secure adequate contractual protections in relation to personal information security in its engagement terms with such third parties, iyarn does not have control over the privacy policies and practices of third parties and you release and discharge iyarn from any claim or other liability that may arise from their acts or omissions.  

iyarn may include hyperlinks to, and details of, third party websites. As above, we have no control over, and are not responsible for, the privacy policies and practices of third parties.

13. Updating personal information

Please let us know if the personal information that we hold about you needs to be corrected or updated. As stated in clause 11 above, we may require you to provide sufficient evidence of your identity in order to update your personal information.

14. Cookies

Our website uses both persistent and session cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either persistent cookies or session cookies and are described below:

(a) a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; and

(b) a session cookie will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Most Internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer, giving you the choice whether to accept it or not. You may also delete cookies at the end of your browser session. Refusing or deleting cookies will have a negative impact on the usability of our website.

15.  Making A Complaint

We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice of iyarn has interfered with your privacy in relation to your personal information, you can contact us using the details below. Please include your name, email address, telephone number and clearly describe your complaint.

If we cannot resolve your complaint to a satisfactory standard, you are entitled to lodge your complaint with the Office of the Australian Information Commissioner at: http://www.oaic.gov.au.

16. Amendments to this Policy

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of material changes to this policy through our website.

17. Our details

This website is owned and operated by iYarn Pty Ltd ACN 622 358 212 operating under the business name iyarn.  iYarn Pty Ltd is registered in NSW Australia.  Our principal place of business is at level 29, 2 Chifley Tower, 2 Chifley Square, Sydney, 2000.

You can contact us by email, using hello@iyarn.com.au.

This Privacy Policy was last updated on [03/09/2024].