- information we gather from your use of the Service;
- how we use the information gathered through the Service;
- how we protect that information; and
- your rights in relation to that information.
The information referred to above which we collect, use and protect includes information or an opinion that relates to you as an identified, or identifiable natural person (“Personal Information”).
Through using our websites or our app, or any other aspect of the Service, you accept that we will gather and use your Personal Information as set out in this Policy and agree to the practices set out in this Policy.
1) How do we collect your Personal Information, and what do we collect?
Vamp generally collects the following categories of Personal Information in the following manners:
- Information you volunteer– you may provide Vamp with your Personal Information voluntarily. If you sign up for a user or client account with Vamp through our Services (a “User”), you may provide Personal Information such as your name, gender, date of birth, email address, mailing address, phone number, password and payment information (such as your PayPal account). If you simply visit our websites or wish to make an enquiry (“Visitor”) you may also volunteer similar Personal Information through posting a message, using a feedback form or other feature;
- Platform integration – you may use our Services in conjunction with a related third-party service. For example, in signing up as a User, you may authorise us to connect with a third-party service such as Instagram or blog platform (for influencers) or other management service (for clients). In doing so, you authorise us to access Personal Information that may have been collected by those third-party services, and to use it in accordance with the Policy. Those third-party services will have their own policies around the collection of information and you should make yourself aware of their terms.
2) Information we don’t collect and sensitive information
As a general rule, we will not collect and store Personal Information that is not necessary for us to carry out our Services or operate our business.
We do not collect any sensitive information, such as your health data, political or religious views, sexual orientation or the like (Sensitive Information), unless we have your explicit and express consent. When and if we do collect Sensitive Information, we delete it when we have used it for the specific purpose of which it was provided by you. If we do collect any of this Sensitive Information, we will advise you of why we are collecting it when getting your consent to collect it.
3) Third-party websites
Our Services might include links or click-throughs to websites, apps or other services provided by third parties. If you provide information in those places, you are providing information to a third-party, and not us. In doing that, we are not responsible for the practices of those third parties – you should take time to familiarise yourself with the policies of any third parties when providing them with your Personal Information.
4) How do we use your Personal Information?
We use your Personal Information in a variety of ways which include:
- Use of the Vamp App – we use your Personal Information to sign you up for the Vamp App as a User. We cannot sign you up to the Vamp App unless we have your Personal Information which allows us to identify you, and authorisation to access relevant third-party services which are integral to the Vamp App. Mandatory Personal Information includes your name, gender, date of birth, location, Instagram account or blog (and associated information) and your PayPal information;
- Provision of services and improvement – having your Personal Information allows us to operate. For example, having your Personal Information is key for Vamp to be in touch with you regarding services you may provide through the Vamp App, to inform you about campaigns you may be interested in orfor us to provide you with specific products and services. We also use Personal Information so we can generally provide support to Users, improve our services and the features and functionality of our websites and the Vamp App and pay you (if applicable);
- Communications – we may use your Personal Information to get in touch with you. We need your Personal Information to respond to enquiries, provide you with information that you request and generally for administrative purposes. We may also contact you for marketing and promotional purposes, which you can always opt-out of by contacting us or modifying your Account settings. We can’t contact you if we don’t have your Personal Information that would allow us to know who you are and how we can get in touch with you; and
5) Privacy and Children
Vamp’s Services are not directed to children under the age of 18, and we do not knowingly collect any Personal Information from children, unless there is parental consent. If you are under the age of 18, we ask that you do not use our Services. We will delete any Personal Information relating to children should we become aware of it. Please contact us promptly if you become aware of anything that would breach our Policy in this regard.
6) How long do we retain your Personal Information?
We only retain Personal Information for so long as we actually need it in order to provide the Services. If you are a User, this usually means we will only retain your Personal Information for so long as you have an account, or for a limited period thereafter. This is all subject to our right to retain your Personal Information as necessary to comply with our legal obligations, resolve disputes and attend to trailing reporting requirements. We will endeavour to destroy or de-identify your Personal Information as early as reasonably possible if requested by you, or in the event that we no longer need it in order to provide the Services.
7) Who do we disclose your Personal Information to?
There are limited circumstances under which we may disclose your Personal Information. We may disclose your Personal Information with your express consent (and subject to any conditions of that consent), as well as in the following circumstances:
- Third party service providers – we will make disclosure to certain contractors or subcontractors or ours who provide administrative or promotional services (for example, mail processing businesses, printers, market research companies or other service providers) to help us provide the Services. Those third-party providers are only permitted under the terms of their contracts with us to use Personal Information of yours which we provide to them for the limited purposes for which we provide it and keep such Personal Information confidential;
- Brands and clients – if you are a User who is also an influencer, we may provide limited Personal Information of yours to clients who may be interested in your services for campaigns. Those clients are required by the terms of their contract with us to keep your Personal Information confidential;
- De-identified information – we may use information which is automatically collected, de-identified and/or aggregated for various purposes. We may use that information to comply with reporting obligations, for marketing purposes or to analyse usage of our Services.
8) How do we protect your Personal Information?
Vamp is committed to data security and follows the generally accepted industry standards to protect your Personal Information whenever and wherever we receive it and when we use or transmit it. Our safeguards may include a mixture of physical protection where appropriate, as well as firewalls, password protection, two-factor authentication and SSL technology when data is transmitted over the internet. We also regularly monitor and review our security and related procedures in order to best secure your Personal Information.
Ultimately, any internet-transmitted data is subject to a risk of data breach and we cannot and do not guarantee that any Personal Information you provide to us is 100% secure or free from access, alteration or destruction. If you do provide us with your Personal Information, you do so at your own risk. If you feel this risk is unacceptable, please do not provide us with your Personal Information and discontinue your use of the Services.
If our data security is breached, we will inform all relevant authorities in accordance with applicable laws.
9) Your choices regarding your Personal Information
You have the right to:
- Access and/or take your Personal Information – we keep your Personal Data in a portable, machine-readable format which readily allows us to provide you with access to your Personal Information. You can ask for a copy of your Personal Information. That notwithstanding, we may require you to comply with certain procedures before we allow access to or amendment of your Personal Information to ensure the integrity and security of information that we hold. Depending on the nature of your request, this may include verifying your identity to our satisfaction to ensure the integrity of your Personal Information;
- Delete, change and/or correct of your Personal Information – you may update, correct or ask us to erase or delete some, or all of your Personal Information at any time through your account settings in the Vamp App or through the Services generally. We will update that Personal Information quickly but may retain backups for the purposes of archiving, fraud prevention, abuse or satisfaction of obligations, or where we otherwise reasonably believe we have a reason to do so. If you believe that you are unable to update, correct or delete any Personal Information you have provided to us in the manner described above, then please contact us. If you delete your User account, your Personal Information will also be deleted by us. If your Personal Information is obtained through your authorisation of a third-party integration, you will need to either modify permissions, or deal with your Personal Information through that third-party platform, if you do not wish us to have access to it; and
- Object to, limit or restrict use of your Personal Information – at any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. You may also make complaints to the relevant data protection authority.
We may refuse to allow access or to amend your Personal Information if we are legally required or entitled to do so. Please be aware that if you ask us to delete or not process your Personal Information in a certain manner, we may not be able to provide the Services to you or allow you to use the Vamp App.
We will take reasonable steps to ensure that the Personal Information that we collect is accurate, up-to- date and complete and the Personal Information we use and disclose is accurate, up-to-date, complete and relevant. If we are satisfied that any Personal Information we hold about you is inaccurate, out-of- date, incomplete, irrelevant or misleading, we will amend our records accordingly.
Please note that you may opt-out of promotional and marketing communications without consequence by contacting us, using the “opt-out” function for emails or changing your account settings.
10) Data Transfers
We may transfer, store and process Personal Information through our centralised database in the United States and Belgium and use the assistance of third-party service providers based. Data security and privacy in Australia is in part governed by the Australian Privacy Act, which we adhere to.
We comply with all GDPR requirements relating to transfer of Personal Information out of the European Economic Area (“EEA”).
11) Laws which bind Vamp
- EU GDPR– Vamp’s UK and EU operations are currently headed by Visual Amplifiers Limited (UK) (Vamp UK). Vamp UK and other entities in our group, including Visual Amplifiers Limited (Australia) (Vamp Australia) are committed to upholding the terms of the European Union’s General Data Protection Regulation EU 2016/679 (“GDPR”).
Vamp UK is a data controller for the purposes of the GDPR, while Vamp Australia is both a data controller and data processor. Both Vamp UK and Vamp Australia are subject to the relevant requirements of those roles as set out in the GDPR.
- Australian Privacy Act–Vamp Australia is an “APP Entity” for the purposes of the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and is subject to the Australian Privacy Principles contained in the Privacy Act. Vamp Australia is committed to complying with the Privacy Act in all of its dealings with your Personal Information. Vamp Australia is not subject to any general exemptions under the Privacy Act in relation to its acts or practices.
12) Updates to the Policy
We may update the Policy from time-to-time. If we do so, we will inform all Users at the time of its update, indicating the date of revision. Any continued use of the Service after that time will be subject to the updated Policy notified to Users.
This Policy was last updated in May 2018.
13) Contacting us
If you wish to correct Personal Information, have your Personal Information deleted, or if you wish to make an enquiry or believe your privacy rights have been infringed upon, please contact our Privacy / Data Protection Officer at:
Attention: Privacy / Data Protection Officer
Room 17, 388 George Street
Sydney NSW 2000.
We will aim to respond to any query, complaint or request within a reasonable time (usually within 48 hours). If your query, complaint or request is extensive, we may require more time than usual to respond.