Hearoes Privacy Policy

 

Last updated: 2019/08/27

 

1. Privacy Statement

Thank you for choosing to be a part of our community at Games 4 Hearoes Pty Ltd, doing business as Hearoes ("us", "we", "G4H", "the app", "Games 4 Hearoes" or "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, please contact us on hello@g4h.net.au or by the information provided below.

This privacy policy applies to all information collected through our website (such as www.games4hearoes.com) and mobile application (Apps) and/or related services, sales, marketing or events (we refer to them collectively in this policy as "Services"). 

This page informs you of our policies regarding the collection, use, and disclosure of Personal Information when you use our Service as well. If there are any privacy policy that you do not agree with, please discontinue the use of Our Services.

We take your privacy very seriously and we will not use or share your information with anyone except as described in this Privacy Policy. 

In short, we use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at www.gamesforhearoes.com/tandc.

 

2. Your Consent

In short, by creating an account with us, signing up to a newsletter, filling out a contact form, or otherwise engaging with us, you consent to us collecting, processing, and using your personal information in accordance with this Policy. 

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include but is not limited to, your name, your email address and other information ("Personal Information").

By providing your email address upon using Our Services, you agree (with the exception of clause 7 (seven)sss, that we may send you periodic emails, in which you can opt-out and unsubscribe to at any time.  You may withdraw your consent regarding our services at any time by contacting us via the details provided below.

 

3. Personal Information Collected by Us

In short, Personal Information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. As part of our business, we may collect personal information from you.

We collect a variety of personal information that is reasonably necessary for the purposes of conducting and improving our business and our products and services.

This information may be collected in a number of ways, including:

1) through our website Games4Hearoes.com including subdomains, as well as our Apps (Hearoes/ Games 4 Hearoes), groups and forums, and other services (collectively, our Services);

2) through marketing research, including surveys and polls;

3) from competitions and other user participation events;

4) through any of our other business activities or events;

5) through a person seeking employment with us, having been employed by us or being employed by us; and/or

6) by otherwise having some form of contact with a person, such as by personal contact, mail, telephone, email, video teleconferencing, Internet or other forms of telecommunication.

Personal information collected by us may include:

1) your name;​

2) your contact details (such as email address);

3) geo-location information;

4) the information that you use to access our Services or any of our products and services, including your reasons, preferences, and opinions for using our Services or any of our products and services;

5) your publicly available information from social media platforms, including but not limited to, Facebook, Twitter, Instagram, Reddit and LinkedIn;

6) any other information that you choose to send to us including your phone number, and fax number; role and/or organisation;

7) usage data and logs, which may include information such as your Internet Protocol (IP) address, browser type, browser version, device type and version of operating system that is used to access Our Services, clickstream data, the pages of our Services that you visit, the features and functions of our Services you use, activities or actions you do while using our Services (including activities played and their progress history), the time and date of your visit to our Services, the time spent on any pages of our Services, and other log related information relating to your use of our Services.

We endeavour to only collect personal information about you from you, where it is reasonable and practical to do so.

4. How Do We Use Your Information?

In short, we process your information for purposes based on legitimate business interest, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our services for a variety of business purpose as described below. We process your personal information for these purposes in reliance on our legitimate business interest, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:

We may use the information we collect or receive:

1) To facilitate account creation and logon process;

2) To send you marketing, promotional, surveys or to information communications. You can opt-out from our marketing emails at any time,

3) To fulfill and manage your orders or payments if applicable,

4) To post testimonials. We sometimes post testimonials on our service, however, won't knowingly post any personal information relating to this testimonial without your consent. If you wish to update to remove your testimonial, please contact us at hello@g4h.net.au,

5)  Request feedback. We may use your information to request feedback and to contact you about your use and experience of our services,

6) To protect our Services. We may use your information as part of our effort to keep our service safe and secure,

7) To enforce our terms, conditions, and policies for Busines Purposes, Legal Reasons and Contractual,

8) To respond to legal request and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond,

9) To manage user accounts. We may use your information for the purpose of managing our accounts and keeping it in working order,

10) To deliver service to the user. We may use your information to provide you a requested service,

11)  To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you may have with the use of our service,

12) For other Business Purposes. We may use your information for our business purposes, such as data analytics, usage trends, determining the effectiveness of campaigns and to evaluate and improve our services or app, products, marketing, and your experience. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end-users and does not include personal information. We will not use personally identifiable information without your consent,

 

5. Will Your Information Be Shared With Anyone?

In short, we only share information with your consent, to comply with laws, to provide you with services, to protect your rights or to fulfill business obligations. We do not, however, unless described in this policy, share, sell, rent or trade any of your information with third parties for their promotional purposes.

We may process or share data based on the following legal basis;

- Consent: We may process your data if you have given us specific consent to use your personal information in a specific manner or purpose. 

- Legitimate Interest: We may process your data when it is reasonably necessary to achieve our legitimate business interest. 

- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of the contract. 

- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with the applicable law, government request, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirement).

- Vital Interest: We may disclose your information where we believe it's necessary to investigate, prevent, or take action regarding a potential threat to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your information in the following situations:

- Vendors, Consultants, and Other Third- Parties Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include; Payment processing, data analysis, hosting services, and customer services and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Service or Apps over time (such as Google Analytics, Google Crash Reporting, and TestFlight).

 

This information may be used to, amongst other things, determine the popularity of certain content and better understand the online activity, analyse and track data statistically. Unless described in this Privacy Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. this means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.  By providing us with your personal information, you consent to us disclosing this information overseas for the reasons outlined in this policy and we take reasonable steps to ensure that overseas third parties deal with your personal information in a way that complies with Privacy Act and this policy.

- Business Transfers. We may share or transfer your information in the connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

-Affilates; we may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture or other companies we control or that are under common control with us.

- Business Partners; We may share your information with our business partners to offer you certain products, services or promotions. 

- Other Users; When you share personal information or otherwise interact with public areas of the Service or Apps, including sharing your progress report and progress data with others through the share function feature in Our Services or otherwise. Such personal information may be viewed by all users on the channel you share with and may be made publicly distributed outside the Service or Apps in perpetuity. Any information which you disclose or share on any third party social media services, websites or communication channels such as text messaging or within the App (including sharing progress reports with other users) is at your own risk and expense. We accept no liability or responsibility whatsoever in relation to the use, non-use or misuse by you or any other person.

6. Children's Privacy

In short, Our Services offers a range of interactivity and digital methods for auditory training, education, and information which, although, not specifically targeted for children, are intended for users of different ages.

 

We're committed to protecting privacy and compliance with COPPA (Children's Online Protection Privacy Act), and therefore have adopted the following policies to keep children safe:

a) We do not knowingly distribute personally identifiable information from children under 13.

 

b) We try to not knowingly ask a child under the age of 13 to divulge more information than is needed to participate in any activity, game or service.

c) Allowing the basic of Our Services to be used without providing personally identifiable information.

d) If you believe that your child is participating in an activity which collects personal information without your consent, please feel free to contact us on hello@g4h.net.au.

During the registration process of the service, we may ask for certain information for notification and security purposes, such as a parent or guardian's email address, child's first name, their hearing loss and year of birth. That said, we do not require users to provide more information than is reasonably necessary to play activities, facilitate an account and maintain and enforce security. Please note, Our Services can be used without providing any personal information, however, certain features which require information cannot function as a result.

In the event that we have knowledge that a child under the age of 13 has submitted their email to us via our services, we will not use the email address provided for marketing or any other purposes, other than saving that user's gaming activities (progress) or facilitate their account. Other information which isn't personally identifiable may also be used so we can improve the experience in order to better meet their needs, or as otherwise described in the policy.

7. How Long Do We Keep Your Information?

In short, we keep your information for as long as necessary to fulfill purposes outlined in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years past the termination of the user's account unless required by legal requirements or associated laws.

When we have no ongoing legitimate business needs to process your personal information, we will either delete it, or anonymise it, or, if this is not possible (for example, because your personal information has been stored in back-up archives). then we will securely store your personal information and isolate it from any further processing until deletion is possible. 

8. How Do We Keep Your Information Safe?

In short, we take personally identifiable information very seriously and we aim to protect your information through a system of organisational and technical security measures. We take reasonable steps to protect all information which we hold (including your personal information) from misuse, interference, loss, unauthorised access, modification or disclosure.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. The precautionary steps we take to protect personal information may include:

 

1) adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;

 

2) adoption of procedural and personnel measures for limiting access to personal information by our staff;

3) regularly reviewing our information collection, storage and processing practices;

4) secured encrypted servers, password protection for electronic files, multi-factor authentication procedures, securing of paper files and physical access restrictions.

However, please also remember that the security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. Although we do our best to maintain the high standards we enforce to protect your personal information, the transmission of personal information to and from Our Services and Apps is at your own risk and we cannot completely guarantee the security of your personal information. You should only access the Services within a secure and trusted environment. 

9. What Are Your Privacy Rights?

In short, some regions, (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, and (iv) if applicable, to data portability. 

 

We will provide you with access to your personal information held by us, unless:

1) giving access would be unlawful; or

2) denying access is required under any applicable law.

 

To make such a request, please use the contact information provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal. 

Account Information and Right to be Forgotten

If you would at any time like to review or change the information in your account or terminate your account, you can do so by contacting us by emailing us at hello@g4h.net.au or by the contact details provided below. Upon request to terminate your account, we will deactivate or delete your account and the information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and /or comply with legal requirements.

Cookies and similar technology

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of Our Service.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe button in the emails which we send, or by contacting us using the details provided below. You will then be removed from the marketing email list - however, we may still need to send you service-related emails that are necessary for the administration and use of your account.

10. Data Breach

In short, a privacy breach occurs when there is unauthorised access to or collection, use, disclosure or disposal of personal information.

 

Staff are required to sign a confidentiality clause as a part of their contracts of employment. They are also required to adhere to and comply with our Privacy Policy. Following this, there is a range of physical and electronic procedures to ensure that privacy is safeguarded. However, the internet is not 100% secure and we cannot guarantee the security of any information sent to us via the internet.

 

When a data breach is considered serious it is likely to cause harm to the individual that the personal information is about. This is called an eligible data breach. If a circumstance arises that is considered an eligible data breach, we will notify the individual and the appropriate authorities. In this notification, we will make recommendations to the individual on the steps they should take in order to protect themselves in relation to the breach of information.

11. Complaints

We strive to ensure our compliance with this Policy and to regularly review our practices under it.

If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to contact details below. All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution of the issue raised.

Please note that you may also make a complaint to the Office of the Australian Information Commissioner (OAIC) about the handling of your personal information. Information on making a privacy complaint can be found on the OAIC website at http://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint.

If you are located in the European Union, the General Data Protection Regulation 2016/679 applies to our relationship with you. The Regulation in its entirety may be accessed in your language at the European Union Law Website.

 

12. Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

13. Changes To This Privacy Policy

We may update our Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

14. Contact Us

If you have any questions about this Privacy Policy, please contact our Data Protection Officer (DPO), Elliot Miller at hello@g4h.net.au (with the title "Privacy Policy" and your query in the subject of the email), or by post to:

Games 4 Hearoes Pty Ltd

Elliot Miller

3/155 Queen St Mall,

Brisbane, Queensland, 4000

Australia