Privacy Policy

1. We respect your privacy 

 

1.1 WABLE PTY LTD (ABN 78 664 030 826) (Wable) is committed to safeguarding the privacy of users of the Wable mobile application (Application) and our website (www.hellowable.com) (Website). 

 

1.2 We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) and the United Kingdom’s General Data Protection Regulation (UK GDPR), as implemented by the Data Protection Act 2018 of the United Kingdom. 

 

1.3 This Privacy Policy sets out how we collect and treat your personal information when you: 

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• create an account with Wable; 

• use the Application and/or use our Website and any services offered on them; or 

• participate in any event, activity or promotion created by Wable. 

 

1.4 Wable's principal place of business is M1/55 Homer Street Moonee Ponds VIC 3039 and its registered office is Highview Accounting & Financial - Unit 1, 2 Codrington Street Cranbourne VIC 3977. 

 

1.5 Our privacy officer is Holly Fowler who can be contacted here: admin@hellowable.com.

 

1.6 ‘Personal information’ or 'personal data' is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly. It does not include data where identity has been removed (i.e. anonymous data). 

 

1.7 By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Privacy Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Privacy Policy regarding handling your personal information. 

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2. What personal information we collect 

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2.1 We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

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• Identity Data including your name and date of birth. 

• Contact Data including email address, telephone number and address. 

• Financial Data including financial, banking and credit card details. 

• Profile Verification Data including facial recognition/face liveness.

 

2.2 Profile Data including your sexual preference/orientation, gender, lifestyle interests, occupation, profile images, information about your personal affairs, information about when you post or interact with content on the Application and/or our Website, conversations between you and other users, information you provide when you respond to surveys and/or promotions, provide feedback or communicate with our customer support, and any other information you include in your profile. 

 

2.3 Technical Data including your last known location while using the Application, mobile unique device ID, internet protocol (IP) address, device identification, your login data, browser type and version, operating system, websites visited immediately before coming to our Website, time zone setting, browser plug-in types and versions and other technology on the devices you use to access the Application and Website. 

 

2.4 Usage Data including information about how you use the Application and Website. 

 

2.5 Marketing and Communications Data including your preferences in receiving marketing from us and third parties and your communications preferences. 

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2.6 We may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map with relevant advertisements. 

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2.7 Facial verification data – for safety and security, we require all users to complete a facial verification check which involves users providing a video of their face during the sign-up process. This verification is called a Liveness Check.  

A Liveness Check refers to the process of verifying the authenticity of a biometric sample, typically in the context of facial recognition, by ensuring that the presented data is from a live human being who is present during verification rather than a fake identity created. We do not add the facial verification data to a user's profile, or share that data with any third parties. We retain the scans for 14 days so that we can verify you for the safety of our platform. The data is safely secured for 14 days, after which time the data is deleted securely.  

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3. Cookies 

 

3.1 We may from time to time use cookies or other similar technologies such as pixels in the Application and/or on our Website. Cookies are very small files used to identify you when you come back to the Application or our Website and to store details about your use of the Application and our Website. Cookies are not malicious programs that access or damage your mobile device or computer. Most web browsers automatically accept cookies and similar technologies, but you can choose to reject them by changing your browser settings. However, this may prevent you from taking full advantage of the Application and our Website. 

 

4. Third party sites 

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4.1 The Application and our Website may have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Wable is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave the Application or our Website, to read the privacy statements of each and every website that collects personal identifiable information. 

 

5. Failure to provide personal information 

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5.1 Some of the personal information that you may provide might be optional (e.g. phone number, sexual preference). However, where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e. provide you with access to the Application and/or Website or to create an account). In this case, we may have to cancel your use of these but we will notify you if this is the case at the time. 

 

6. Collection of personal information 

 

6.1 Wable will, from time to time, receive and store personal information from and about you including by the following methods: 

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• Direct interactions. You may give us your Identity, Contact, Financial, Profile and Marketing and Communications Data by filling in forms on the Application or our Website or by corresponding with us. 

• Automated technologies or interactions. As you interact with the Application and Website, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. 

• Third parties or publicly available sources. We will receive personal information about you from various third parties such as: 

• Profile Data (in particular Instagram) through an API; 

• Technical Data from analytics providers such Google Firebase (located in the United States) and Adjust (headquartered in Germany); and 

• Identity Contact and Profile Data from pixels used on social media sites such as Facebook and Instagram to target people likely to be interested in becoming a Wable user. 

 

7. Use of your personal information 

 

7.1 Wable may use personal information collected to: 

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• allow you to interact with other users on the Application (including by permitting other uses of the Application and/or our Website to view the content you have submitted to the Application and/or our Website); 

• provide updates to you in relation to the Application and our Website; 

• provide you with information; and 

• to enable authorised parties to better use the functionality of the Application and our Website. 

• We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs. 

• Wable may contact you by a variety of measures including, but not limited to email, text-message, telephone or by post. 

 

7.2 If you are located in the United Kingdom (‘UK’), please see sections 10, 11 and 12 for more details of how we process your personal data. 

 

8. Disclosure of your personal information and international transfers 

 

8.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy. Subject to this clause 5, personal information is only supplied to a third party when it is required for the delivery of our services or for the functionality of the Application and/or our Website. 

 

8.2 We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request. 

 

8.3 We may also use your personal information to protect the copyright, trade marks, legal rights, property of Wable or the safety of our customers or third parties. 

 

8.4 If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances. 

 

8.5 The personal information we hold is stored and hosted on Amazon AWS. This can be replicated across multiple countries to provide performance optimisation (i.e. speed of access) to you by hosting a server in closer geographical proximity to where you are located. The server is currently located in Asia Pacific but is also soon to be located in Europe. 

 

8.6 We allow Google Firebase (based in the United States) and Adjust (headquartered in Germany) to collect statistics on user behaviour anonymously and without personally identifying any users. 

 

8.7 The Terms of Service governing your access and use of the Application and our Website provides further details about disclosure of your personal information. 

 

9. Security of your personal information 

 

9.1 Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia and the United Kingdom. If you are located in the UK, we only transfer your personal data to countries which have been deemed to provide an adequate level of protection for personal data or where we have adequate safeguards in place. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. If you would like more details about the transfer of your personal data, please contact our data protection officer privacy officer. 

 

9.2 Wable is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. 

 

9.3 Although we comply with data protection laws and are confident in our security measures, the transmission and exchange of information is carried out at your own risk and like any business we cannot absolutely guarantee the security of any information that you transmit to us, or receive from us. 

 

10. UK's General Data Protection Regulations (UK GDPR) 

 

10.1 This section 10 and sections 11 and 12 apply if you are a resident of the UK. 

 

10.2 Wable will comply with the principles of data protection set out in the UK's General Data Protection Regulation (‘UK GDPR’) for the purpose of fairness, transparency and lawful data collection and use. 

 

10.3 Wable is the controller of the personal data of users of the Application and Website. Our authorised representative is Wable. 

 

10.4 You may choose to provide us with what is known as ‘special categories of personal data’ under the UK GDPR. Of these types of data, we are most likely to collect details about your sexual orientation and health. We do not intend to process other kinds of special categories of personal data however it is possible you will provide us with these, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and/or trade union membership. Profile Data that you choose to provide us with may include some of these types of personal data. 

 

10.5 We do not knowingly collect or process the personal information of persons under the age of 18 years. 

 

10.6 Under the UK GDPR we cannot retain your personal data in a form that identifies you for longer than is necessary to fulfil the purposes for which we collected it. This may include for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirement. 

 

10.7 Generally we retain your personal data for the duration of you having your account with us and 7 years from the date you close your account. Users can deactivate, hide, delete or make a request to permanently delete their account, either themselves or with the help of technical support. We assess our database annually to delete any accounts which have been inactive for over 12 months. 

 

10.8 We may anonymise personal data which means that it is no longer associated with you. We do this for statistical or research purposes so we can improve the services we offer to you. We can use anonymous data indefinitely without further notice to you. 

 

11. Lawful basis under the UK GDPR 

 

11.1 Under the UK GDPR, we must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it. We have set these out below: