Privacy policy

Date of last effective update: August 13th, 2018.

 

 

Introduction

Welcome, this is the Privacy Policy (the “Policy”) of the website located at www.volve.io and, including its sub-domains and its mobile optimized version (collectively, the “Site”).  This Policy shall also supplement our Terms and Conditions of Use (the “Terms”) and any other guidelines and policies indicated by us from time to time, incorporated herein by reference.

All of our registered members must click on the “I agree” checkbox on our registration page (or similar box or means), thereby agreeing to our Privacy Policy and our Terms.  Accordingly, this Policy is a legally binding agreement between Volve Group Pty Ltd. (hereinafter, “Volve” also referred to as “our”, “us” and “we”) and you.

Overall, Volve.io works hard to earn and keep your trust, so it adheres to the following principles in order to protect your privacy:

  • We will not rent or sell your PI to third parties.
  • We will not disclose your contact information with other users or third parties without your consent.
  • Any PI that you provide to Volve.io will be secured with industry standard safety protocols and technology.

 

 

Scope of this Policy

Volve is an online platform designed for managing, organizing and simplifying your advertising and marketing campaigns.  Its functionalities include, but are not limited to, project management, content repositories, content creation and preview tools, forums, notes, posts, team management, the creation of aggregated databases, and other useful information.

Henceforth, this Policy is applicable to the information collected through your use of our Site, services and products, as applicable.  As used herein and elsewhere, the words “collect”, “use”, “process”, “treat”, “disclose” and analogous shall be related to personally identifiable information (the “PI”) and other data that we may collect from our users and/or visitors, including cookies inside a computer and mobile device IDs.

By registering with us or otherwise using our products and services, you consent to the collection, transfer, processing, storage, and disclosure of your PI as described in this Policy.

In order to provide our services, we use third-party platforms provided by Google Inc. and Dropbox Inc. via their licensed Application Programming Interfaces (API).  Such platforms are governed by their own terms, policies and personal data collection practices and policies.  Accordingly, by acknowledging your consent to this Policy of Volve, you are accepting the applicable terms and conditions of Google Inc. and Dropbox Inc.  Upon the case of any discrepancy or conflict among this Policy and the terms of Google Inc. and Dropbox Inc., the terms of the latter entities will govern.

We will keep a list of any sub-processors that will be involved in the processing of your PI due to the provision of our services and will inform you of any intended material changes concerning the addition or replacement of sub-processors before such changes are effective, thereby giving you the opportunity to object to such changes.

 

 

Information You Provide to Us

We may collect both “Non-Personal Information” and “Personal Information” about you. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, aggregate user statistics, analytics, demographic information, Site’s usage information, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks.  “Personal Information” includes PI that can be used to personally identify you, such as your name, address and email address.

When you sign up for any of our account options, you will be required to provide certain PI, including but not limited to, your name, surname, age, email address and phone number, among other PI.  We will store your personal data for the purposes of managing your collaboration with other users and persons, improve your user experience, send newsletters for users and contact you about inquiries for our services.  If you do not wish to disclose any personal data, then your sole remedies shall be to close this web tab, delete your account and/or exit the Site.

 

 

Information Collected by Us when You Use our Technology and Services

We may collect information provided to us by your browser and mobile device IDs when you view or use our services, such as the website you came from (known as the “referring URL”), the type of browser and device you use, the time and date of access, usage information, server and HTTP logs, along with data transmitted by the actions of the Google and Dropbox APIs.

We may also collect non-personally identifiable information with third parties, such as aggregate user statistics, analytics, demographic information, and web site usage information.  As our user, you will generally be able to control and select the amount and type of PI you may disclose to us.

Volve uses Google’s and Dropbox’s developer tools in order to integrate Google’s and Dropbox’s services with the ones offered by Volve.  Accordingly, we will create a “Volve” directory in your cloud storage account and we will also create sub-folders in order to upload the files your collaborators are uploading.  If such files are removed by you or your collaborators, our platform will remove them too.  If your account is disconnected or switched to another cloud storage account, we will remove these files and the Volve directory.

This means that Volve may or will collect the amount of total storage and available space that the user has on its cloud storage account, among other information provided from time to time by Google and Dropbox.  This is done in order to undertake several functionalities of our platform such as letting users know how much storage they have left and to send an email when their storage is full.

 

 

Information Collected from Payment Processors

We use payment partners in order to bill and process any payments and/or subscriptions made via our platform and our services.  These platforms will request you to disclose them sensitive information in order to complete purchases and operations related to our services.  Such third-party payment processing platforms are governed by their own safety standards, policies and terms of use.

We take great care in selecting our third party payment processing platforms, and stride to be aware of their operations and functionalities.  Nonetheless we strongly advise our users to engage in online safety measures and practices in order to protect their financial information.

 

 

Information Collected from Mobile Devices

When you access our platform via a mobile device, we may use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS 6 and later) instead of cookies in order to recognize you, track the number of relevant ads displayed, and their performance and display.

 

 

Use of the Collected Information

We use your information to provide and improve our services and products.  By storing your PI on our secure servers, we are able to shorten your login process and allow you to modify your personal profile online. We will generally collect, use and disclose your PI to:

  • Provide, operate, maintain, improve, and promote our platform and our products and services.
  • Verify your e-mail address; send password retrieval links and other account notices.
  • Improve your user experience and provide you with personalized support.
  • Develop, research, process, safeguard and improve our services.
  • Answer to comments, questions, and requests you submit to us.
  • Offer promotions, newsletters, sweepstakes entries and rewards, send service related announcements and contact you about inquiries for our products and services.
  • Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
  • Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.

The information we collect is not shared with or sold to other organizations for commercial purposes, except to provide services you’ve requested, when we have your permission, or under the following circumstances:

  • When it is necessary to share your PI in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of the specific application, or as otherwise required by law.
  • When we transfer your PI if Volve is acquired by or merged with another company. In this event, Volve will notify you before PI about you is transferred and becomes subject to a different privacy policy.

We also retain the right to transfer your PI if our company files for bankruptcy and some or all of our assets are sold to another individual or business.

If you do not wish to disclose any or part of your PI to us, you may still be able to use some of the functionalities of our products and services, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us.  Overall, your final remedies will be to close this web tab, delete your account with us and/or exit the Site.

 

 

Sharing Information with Facebook and Google for Marketing Purposes

We may share your PI with third parties for similar audience marketing purposes.  Similar audience marketing is also called lookalike audience marketing.  The third parties we share your PI with for this type of marketing include Facebook and/or Google.  Using your PI for similar audience marketing or lookalike audience marketing helps us find new audiences (users and customers) based on similar interests to yours, thus helping us improve our marketing services.  Your PI may be shared with Facebook and Google for this type of marketing.  By using our website and agreeing to our privacy notice, you are giving your consent for your PI to be used for the marketing purposes described within this section.

 

 

Storage of Your Information

As our user, you will generally be able to control and select the amount and type of PI you may disclose to us.  We continuously try to improve our user experience, and strive to provide you the best choices for the disclosure, edition or removal of the PI being processed by us.  Accordingly, we will undertake the open and transparent management of your PI and will: (i) inform you about how your personal information may be used and disclosed (including overseas); (ii) maintain the safety and integrity of your personal information; and/or (iii) enforce your individual right to access and correct your personal information.

We will retain your PI only for as long as it is reasonably necessary for our business purposes (e.g. as long as your account is active).  We will also retain and use your PI for our compliance obligations, to resolve disputes among our users, and enforce our contracts with authorized third parties.

 

 

Your Rights as Data Subject

The General Data Protection Regulation (GDPR) allows individuals in the EU greater control over their personal data and grants them a number of rights with regard to how that data is processed, stored, and accessed.

For the purposes of the GDPR, in the European Union, Volve is a “data controller” of PI you provide to us for the primary purposes of providing you with our devices.  We have secured the services of third party “data processors” in order to provide us with back-end functionalities, processing, storage and networking services.  These data processors include Noveo NSK, Noveo SPB, Noveo, Noveo Europe and Amazon Web Services.

Henceforth, we will implement the reasonable technical and organizational measures required to preserve the confidentiality and security of PI and in particular to prevent it from being destroyed, damaged or communicated to unauthorized third parties and to comply with the requirements of the GDPR and ensure data subjects’ rights protection, and more specifically protect PI against accidental or unlawful destruction, accidental loss, alteration, disclosure or unauthorized access, in particular where the processing involves the transmission of data through a network, and against any form of unlawful processing.

The section below covers the certain situations that you, as data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/.  You retain the right to access, amend, correct or delete your PI where it is inaccurate at any time.  To do so, please contact [email protected]

  • Right to be Forgotten: You can request us to be “forgotten”; that is, to have your entire PI removed from our Service.  If we are asked to do this, we will remove any PI you we collected from you as requester.  We will also need to contact any third parties, such as our cloud service providers, that process your PI on our behalf.  To ensure that any personal data in Volve’s possession can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request.
  • Right to Data Portability: Under the GDPR, our users located in the EU may request Volve to send them any PI in our possession.  In this case, we will provide you with any PI that you have in a commonly used, machine-readable format.
  • Right to Data Access: As a data subject, you can ask Volve to confirm how and where your PI is being stored and processed.  You also have the right to know how such that data is shared with third parties by us.
  • Right to Data Rectification: As data subject, you have the right to obtain from Volve, without undue delay, the rectification of inaccurate PI concerning you.
  • Right to be Informed: You have the right to be informed about the PI we collect from you, and how we process it.
  • Right to Object: You have the right to object to us processing your PI for the following reasons:
    • Processing was not based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
    • Direct marketing (including profiling);
    • Processing for purposes of scientific/historical research and statistics; and
    • Rights in relation to automated decision-making and profiling.
  • Automated Individual Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • Right to Complain: You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the GDPR.  If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.

You can rest assured that we will cooperate, assist and provide you with all necessary information necessary for the performance of data protection impact assessment in accordance with Article 35 of the GDPR and/or consultation of the relevant supervisory authority in accordance with Article 36 of the GDPR.

Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights.  If you request rectification, please indicate amendments to be made and attach documentation to back up your request.

Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our products and services within thirty (30) days.  Please take into account that we may not be able to delete all of your data from our secure databases or the databases of third parties to which your PI has already been disclosed.  If that is the case, please contact such third parties directly in order to request enforcement of your privacy rights.  In case of secure databases under our control where deletion is impossible, we will make such information inaccessible.

 

 

Safety of Your Information

We use industry standard protocols and technology to protect your registered user information and PI, such as Secure Socket Layer (SSL) technology and secure databases. Your PI is only accessible by a limited number of our employees who have special access rights.  Overall, we implement and maintain reasonable security measures to protect our databases and records from unauthorized access, acquisition, destruction, use or disclosure.

Notwithstanding the foregoing, please take into account that the Internet and related transmissions are not secure or error free communication means. Additionally, if you post information on a public forum, message board, blog or bulletin board, any PI you elect to disclose therein there may or will be read, collected and/or used by other users of such forums and could be used by third parties to send you unsolicited messages.

 

 

Lawful Disclosure of Information

We reserve our right to disclose your PI when we or our affiliates, clients, agents, contractors, licensors, officers, agents and/or representatives reasonably believe it necessary to protect our interests, or where you result to be in breach of our Terms and/or this Privacy Policy.

Accordingly, we will have the right to disclose any and all collected PI and/or data, under the following circumstances:

  • If required under applicable law, rules or regulations.
  • In response to a valid request or subpoena from a government or law enforcement agency.
  • To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices).
  • To defend the property, rights and integrity of any of our users, advertisers or licensors.

To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.

 

 

Email Communications & Opting Out

We collect the e-mail addresses of those who communicate with us via e-mail, aggregate information on what pages users’ access or visit, and information volunteered by the consumer (such as survey information and/or website registrations).

We will not share your information with third parties for marketing purposes without your permission.  With your consent, these third parties may offer promotions (including email promotions) or sell items or services to you through our services.

We will send you service-related announcements on occasions when it is necessary to do so.  For instance, if our service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our Service, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature.  Based upon the PI that you provide us, we may communicate with you in response to your inquiries to provide the services you request and to manage your account.  We will communicate with you by email or telephone, in accordance with your wishes.  We may also use your PI to send you updates and other promotional communications.

If you no longer wish to receive those email updates, you may opt-out of receiving them by following the instructions included in each update or communication.

 

 

Cookies & Web Beacons

We may store the so-called ‘cookies’ in your computer in order to track and collect data regarding your use of our products and services.  Cookies are small text files that our services transfer to you and that allow us to recognize you and obtain data such as the environment in which our products are operating, OS type and version.

By agreeing to accept our use of cookies, you are giving us, and the third parties we partner with, permission to place, store, and access some or all the cookies described below on your computer:

  • Strictly Necessary Cookies. These cookies are necessary for the proper functioning of the Site, such as displaying content, logging in, validating your session, responding to your request for services, and other functions.  Most web browsers can be set to disable the use of cookies.  However, if you disable these cookies, you may not be able to access features on our website correctly or at all.
  • Performance Cookies. These cookies collect information about the use of the Site, such as pages visited, traffic sources, users’ interests, content management, and other website measurements.
  • Functional Cookies. These cookies enable the Site to remember a user’s choices – such as their language, user name, and other personal choices – while using the Site.  They can also be used to deliver services, such as letting a user make a blog post, listen to audio, or watch videos on the Site.
  • Media Cookies. These cookies can be used to improve a website’s performance and provide special features and content.  They can be placed by third parties who provide services to us.
  • Advertising or Targeting Cookies. These cookies are usually placed and used by advertising companies to develop a profile of your browsing interests and serve advertisements on other websites that are related to your interests.  You will see less advertising if you disable these cookies.
  • Session Cookies. These cookies allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes, such as remembering what a user has put in their shopping cart as they browse a website.  Session cookies also permit users to be recognized as they navigate a website so that any item or page changes they make are remembered from page to page.  Session cookies expire after a browser session; thus, they are not stored long term.
  • Persistent Cookies. These cookies are stored on a user’s device in between browser sessions, which allows the user’s preferences or actions across a website (or, in some cases, across different sites) to be remembered.  Persistent cookies may be used for a variety of purposes, including remembering users’ choices and preferences when using a website or to target advertising to them.

We also store the so-called ‘beacons’, which are small files, sometimes only a pixel in size, embedded onto the pages of our websites.  Beacons are used to identify each of our pages in order to be analyzed by our system tools.

We may also collect and use the data contained in log files, which may include your IP (internet protocol) address, your ISP (internet service provider), the browser you used to visit our platform, the time you visited our platform and which sections you visited.

You can always configure your browser to refuse cookies and beacons.  For more information, please visit www.allaboutcookies.com.  Unlike cookies, mobile device IDs cannot be deleted, but you can select to reset your Advertising IDs in the “Settings” section of your mobile device.

We do not currently offer “do-not-track” or similar mechanisms.

 

 

Third-Party Service Providers

Our Site, platform and our services may display hyperlinks to the websites of our commercial partners and other third parties.  If you click on such links, you are choosing to visit such websites, and will be redirected there.

Please take into consideration that we are not responsible for the privacy and personal data practices undertook by such third parties (including any tools, cookies, information or content contained thereunto), and that we do not have control over the manner in which such third-parties may collect, process, treat or use your PI.

When you use such links to go to another website, our Policy and Terms are no longer into effect and your browsing thereof is in your own and final risk.  In addition, any banner or ad that we may have on our platform does not constitute any endorsement of any third-party thereof.

 

 

Advertising, Opt-out Choice

From time to time, we may use Google Analytics, Ad Words, Double Click and/or Ad Sense tracking codes, and other third-party software tools in order to collect information and marketing analytics about the manner in which you browse our platform and services.

The served ads will be targeted based on your previous browsing history, and may include retargeting codes.  For example, third-party vendors may show you Volve’s ads on certain websites across the Internet, even after you leave our platform.  The collected information is anonymized, meaning it cannot be tracked back to individuals.  Using such tools, we learn how to optimize, and serve ads based on a user’s past visits, providing you with a better user experience.

Our third-party vendors may also use cookies and beacons to track your Internet browsing in order to serve you ads based on what they or us believe to be of interest according to your browsing activities and consumer preferences.  Henceforth, by using this platform, along with our products and services, you hereby consent to such disclosure, treatment and storage of PI.  In order to enforce and uphold your right to privacy, you will always have the option to elect not to receive this type of advertising from us or third parties, now or in the future.

You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org.

For more information on how Google collects and processes your data, visit https://www.google.com/policies/privacy/partners/.  You can prevent Google Analytics from using your information by opting out at this link:  https://tools.google.com/dlpage/gaoptout.

 

 

Service Eligibility

Through the simple use of the platform and our products and services, you hereby represent and warrant that you are at least eighteen (18) years of age –or older– as of the date of first access thereof.  If you are still a minor (which may depend on the jurisdiction where you reside), you may access our products and services, only under the direct supervision of your parent or legal guardian.

We do not knowingly collect any kind of information from persons under the age of thirteen (13).  If we learn or have reason to suspect that any user is under the age of thirteen (13), we will delete any PI under that user’s account.

 

 

Changes in this Privacy Policy

We reserve the right to amend, change, suspend and/or update our platform, our products, our services, this Policy and/or our Terms, in whole or in part, from time to time and at our sole and final discretion. Your continued use thereof after the last effective date of modifications thereof indicates your acceptance of such modifications.  We will post any updates on our platform, and may also send you an email or otherwise notify you of any material changes to this Policy.

 

 

International Disclosure

Your PI may be accessed by us or our affiliates, agents, partners, advertisers or third-party service providers in Australia and other regions.  The European Union has not found Australia and some other countries to have an adequate level of protection of PI under Article 45 of the GDPR.  Volve relies on exceptions for specific situations as defined in Article 49 of the GDPR.

For European Union customers and users, by clicking the “I Accept” button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and accept that your PI may be transferred outside the European Union to Australia.  We will use your PI to provide the goods, services, and/or information you request from us to perform a contract with you or to satisfy a legitimate interest of our company in a manner that does not outweigh your freedoms and rights.

Wherever we transfer, process or store your PI, we will take reasonable steps to protect it.  We will use the information we collect from you in accordance with our Policy.  By using our Site, services, or products, you agree to the transfers of your PI described within this section.

 

 

Notice to New South Wales Users

Volve has its main business operations located in New South Wales, Australia (NSW).  For our customers in NSW, and in compliance with the Privacy and Personal Information Protection Act of 1998 (PPIP Act), we are responsible for any and all factual or suspected security data breaches into our PI databases, and are also required to notify our customers of any such factual or suspected breach.

Accordingly, we will adhere to the following principles when collecting, treating, processing and disclosing your PI:

  • We will only collect your PI for a lawful purpose.
  • We will only use your PI information for the reason we collected it.
  • We will inform you the information being collected, why and who will be using it and storing it and for what reason.
  • We will make sure that the collected PI is non-excessive.
  • We will make sure that your PI is kept safe, relevant, accurate and current.
  • We will store your PI securely, not kept longer than needed, and disposed of properly.
  • We will allow you access to your PI in a reasonable time-frame and without undue cost.
  • We will allow you to access, update, correct or amend your PI when needed.
  • We will only release your PI with your prior consent, unless for exceptional cases.

 

 

Governing Language

From time to time, this Policy may be translated into other languages for your convenience.  The English language version of each of these documents shall be the version that prevails and governs your use of Site and our products and services.  Upon the case of any conflict between the English language version and any translated version, the English language version will prevail.

 

 

How to Contact Us

If you have any questions or queries about us, our services, our Terms and/or this Privacy Policy, please contact us through our website www.volve.io; by post to Volve Group Pty Ltd., PO Box 892, Bondi Junction 1355 NSW, Australia; by email to [email protected] and by phone to +61 434 517 922.

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