Privacy Policy - Geora Limited

Last updated 24th Feb 2021.

1 What is this Privacy Policy?

       (a) Geora Limited (ABN 86 630 167 618) of Suite 3.02, Level 3, 201 Elizabeth Street, Sydney NSW 2000 (we, us and our) is committed to keeping all information collected through the provision of our products and services (including through (our Website)) confidential, secure and private.

       (b) This Privacy Policy explains how we collect, use, manage and disclose your personal information.

       (c) We may modify or amend this Privacy Policy from time to time. We will display a notice on our Website indicating when any such revisions have been made. This Privacy Policy was last updated on 16 December 2019.

       (d) You agree to be bound by this Privacy Policy by using our products, engaging our services and by accessing, browsing, or using the Website. If you do not agree with any aspect of this Privacy Policy, please notify us.

       (e) Unless you notify us otherwise, we will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Privacy Policy.

       (f) We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and will adhere to the Australian Privacy Principles (APPs) in the collection, protection, use and disclosure of your personal information. The APPs are designed to protect the confidentiality of this information and the privacy of individuals by regulating the way personal information is collected, used and managed.

2 What is personal information?

 Personal information is information or an opinion about an individual (or an individual who is reasonably identifiable) whether true or not and whether recorded in material form or not.

3 What personal information do we collect?

       (a) We may collect personal information from you when you engage our services, use our Website, or contact us by any method, such as telephone, email, post, facsimile or in person.

       (b) The type of personal information that we may collect from you will depend on our relationship with you, the services we provide and the circumstances of the collection. Information we collect may include (but is not limited to), the following:

           (i) name;
           (ii) address;
           (iii) email address;
           (iv) contact phone numbers;
           (v) financial information;
           (vi) your nationality and country of birth;
           (vii) corporate details;
           (viii) information that is required or authorised by law (including for anti-money laundering and counter-terrorism financing law purposes); or
           (ix) government identifiers.

       (c) We may collect sensitive information about you with your consent. Sensitive information is a subset of personal information that is given a higher level of protection under the APPs. 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. Provided you consent, your sensitive information may only be used and disclosed for purposes to which you have consented or are directly related to the primary purpose for which the sensitive information was collective, including:

           (i) for the purpose of us maintaining a comprehensive company file;
           (ii) for the purpose of data compilation or analysis for internal purposes; and
           (iii) in an anonymised format for the purpose of data compilation or analysis to share with third parties.

       Sensitive information may also be used or disclose if required or authorised by law.

       (d) As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. In such instances, we will determine whether we would have been entitled to collect such information from you under this section 3, and to the extent we would not have been entitled to do so, we will destroy or de-identify such information as soon as reasonably practical.

4 Cookies

       (a) If you use our Website, some of the personal information referred to in section 3 may be collected through the use of cookies. Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a particular site, or by default reject cookies.  

       (b) Please note that rejecting cookies may mean that some or all of the functions on our Website will not be available to you. In particular, cookies must be enabled to access and use any part of our Website for placing orders.

5 How is your personal information used?

       (a) The personal information that we collect is generally used to provide products or services to you, including:

           (i) assessing your application to receive our products or services;
           (ii) fulfilling our legal and regulatory obligations;
           (iii) connecting people within our community;
           (iv) performing our related administrative and organisational functions and tasks; and
           (v) if you use our Website, to track your usage, to evaluate performance of our Website, and to keep track of your account settings.  

       (b) Information collected by us may also be used for the following purposes:
           (i) to provide you with information in relation to the products and services we provide;
           (ii) to conduct marketing activities and to conduct market research;
           (iii) to respond to your questions or suggestions;
           (iv) to improve the quality of our products or services; or
           (v) to improve the quality of your visit to our Website.

       (c) You may opt out of receiving such information by notifying us accordingly, or using any unsubscribe facility we provide for that purpose.

6 Disclosure of your personal information

       (a) We do not sell, rent or trade personal information to or with any other third parties.

       (b) We will not otherwise disclose your personal information to any third party unless:

           (i) that third party is a group company of ours, in which case that group company will only use and disclose your personal information in accordance with this Privacy Policy as if a reference in this Privacy Policy to us included a reference to that group company;
           (ii) that third party is a contractor engaged to provide goods or services to us.  This may include disclosure to contractors outside of Australia. Our agreements with such contractors require that they keep your personal information confidential, and that they only use or disclose your personal information for the purposes of providing those goods or services to us;
           (iii) such disclosure is in connection with the sale of some or all of our business or assets; or
           (iv) you have consented for us to share the information for this purpose, or the disclosure is authorised by the Privacy Act including:

               (A) to lessen or prevent a serious threat to life or health;
               (B) to protect the personal safety of users of our Website or the public;
               (C) if authorised or required by law;
               (D) if we have reason to suspect that unlawful activity has been, is being or may be engaged in;
               (E) to enforce the law or where necessary to investigate a suspected unlawful activity; or
               (F) you would reasonably expect or we have told you that your personal information is usually used or disclosed to third parties in this way,

       (c) At this time, the third parties referred to in paragraph (b) are located within Australia, however this may change in the future and if it does we will update this Privacy Policy accordingly. We may disclose your personal information to a third party referred to in paragraph (b) that is located outside Australia, including in any of the following countries:

           (i) Singapore; and
           (ii) the United States of America.

7 Access and correction of your personal information

       (a) You have a right to access most personal information that we hold about you and seek its correction.

       (b) We will, on request, provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception to such disclosure which applies under the APPs.

       (c) You may request access to the information that we hold about you through the contact details on our Website. Before we provide you with access to your personal information we will require some proof of identity. We will process your request within a reasonable time, which will depend on the nature and size of the request. There is usually no fee for making a request for information. However, we may charge a reasonable fee for the processing of your request (for example, an hourly rate of the person assigned to collate your information, and any out of pocket expenses).

       (d) In some circumstances, where empowered to or required to by law, we may refuse access to certain personal information. If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the APPs (unless it would be unreasonable to do so).

       (e) We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.  If the personal information we hold about you is inaccurate, incomplete, irrelevant or out-of-date, please contact us and we will take reasonable steps to either correct this information, or if necessary, discuss alternative action with you.

8 How we hold and secure your personal information

       (a) The security of your personal information is important to us. We take reasonable steps to prevent the personal information we hold about you from misuse, interference or loss, and from unauthorised access, modification or disclosure. This includes the use of technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect the privacy of your personal information. We will exercise care in providing secure transmission of information between your computer and our servers, but we cannot ensure or warrant the security of any information submitted via the internet.

       (b) We may hold or process the information collected from you on servers located overseas, including for storage, hosting, analytical, reporting, testing, and filtering purposes. If we do this, we ensure that the organisations providing the servers have appropriate data handling and security standards to comply with this Privacy Policy.

9 Links to other websites

Sometimes our Website contains links to other websites. When you access a website other than our Website, we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each website you visit.  

10 How to contact us

       (a) If you have any queries or complaints with regard our collection, use or management of your personal information, please contact:

           A: Bridie Ohlsson
               Suite 3.02, Level 3, 201 Elizabeth Street Sydney NSW 2000

       (b) If you wish to make a complaint about an alleged breach of the Privacy Act, we ask that you send us your complaint in writing to the email address li