1. About this Privacy Policy

1.1 Digitori Labs is committed to maintaining the security of Personal Information provided to us. When you share Personal Information with us, we treat it with care and take our responsibility to protect it seriously.


1.2 This Privacy Policy clearly describes our privacy practices and how we collect, use, process and manage your Personal Information.


1.3 We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (NDB).


1.4 By using our Services, you agree to the collection, storage and processing of your Personal Information as described in this Privacy Policy.


1.5 This Privacy Policy is incorporated by reference into the Digitori Labs Terms of Use (“Terms”).


1.6 Any reference herein to “we”, “our”, or “us” means Digitori Labs (ABN: 55 235 711 384) (“Digitori Labs”). Any reference to “you” or “your” means you, as a User of the App.


2. Definitions

2.1 “App” means the Salvator mobile application.


2.2 “Content” means any information or data submitted or uploaded by a User to the App, or otherwise to Digitori Labs, in connection with the Services.


2.3 “NDB” means the Privacy Amendments (Notifiable Data Breaches) Act 2017 (Cth).


2.4 “Personal Information” means information about an individual whose identity is apparent or can reasonably be ascertained from that information.


2.5 “Privacy Laws” means the Privacy Act 1988 (Cth), Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). 


2.6 “Sensitive Information” has the same meaning as provided for under the Privacy Act 1988 (Cth).


2.7 “Services” means the services provided by Digitori Labs, including the provision of the App, the Salvator device, and any other related products or services.


2.8 “User” means a user of the App.


3. Purpose of this Privacy Policy

3.1 This Privacy Policy details how we safeguard your Personal Information and our privacy obligations to you in compliance with the Privacy Act. It will give you an understanding of:


(a) the types of Personal Information that Digitori Labs collects and holds; (b) how and when Digitori Labs collects, discloses, uses, stores and otherwise handles Personal Information; (c) the purposes for which Digitori Labs collects, holds, uses and discloses Personal Information;(d) how you may access your Personal Information, and seek correction of your Personal Information; (e) how we store your Personal Information and keep it secure; (f) how you can make a complaint, and how Digitori Labs will deal with any such complaint.


4. The types of Personal Information we collect

4.1 We collect Personal Information that you provide to us when we provide you with our Services. This may include Personal Information such as your:


(a) name; (b) billing and shipping address;(c) phone number; (d) email address; (e) date of birth; and (f) payment details such as your credit or debit card details.


4.2 We collect Personal Information from you when we provide you with our Services, including but not limited to; when you provide us with feedback, when you change your email preferences, when you respond to our surveys, when you communicate with our customer support team, and any other types of Personal Information you provide to us while interacting with us through your use of our App and our Services.


4.3 We may collect Sensitive Information from you in order to provide you with our Services. This may include, for example, information relating to your health. We do not use your Sensitive Information for direct marketing.


4.4 If you are under the age of 15, we request that you obtain and provide parental consent as required by the Privacy Act.


4.5 It is the obligation of Users to ensure:


(a) compliance with the Privacy Laws; (b) they have obtained consent from any applicable third party before disclosing any Personal Information through the App.


5. Marketing and Advertising Communications

5.1 We collect your Personal Information, including your email address, for the primary purpose of providing our Services to you, and also for secondary purposes relating to marketing and advertising communications, in circumstances where you would reasonably expect such use or disclosure.


5.2 We process Personal Information about your preferences for receiving advertising and marketing data from us and third parties. This marketing data may include your browsing and purchase history.


5.3 Where we collect your Personal Information for marketing and personalisation services, we use this marketing data to:


(a) deliver relevant App content and advertisements to you; (b) market our Services to you, and from which you can unsubscribe from at any 2 time; (c) customise your experience of the App according to your browsing preferences and User history.


5.4 You can ask us to stop sending you marketing messages by contacting us or following the opt-out links of any marketing messages sent to you.


5.5 We will obtain your express consent before we share your Personal Information with any third party for their own marketing purposes.


6. How we collect Personal Information

6.1 We collect Personal Information from you in a variety of ways, including when you interact with us electronically or in person, when you access our App, and when we provide our Services to you.


6.2 Personal Information may be provided by you directly or may be sent to us automatically when you visit and use our App.


6.3 We may also receive Personal Information from third parties. If we do, we will protect that Personal Information in accordance with this Privacy Policy.


7. How we use your Personal Information

7.1 We use your Personal Information, and you consent to us using your Personal Information, to:

(a) provide you with our App and Services; (b) administer our business activities and internal record keeping; (c) process transactions involving our business and through our App where you have purchased our Services; (d) manage, research and develop our Services, including through data analytics; (e) provide you with information about our App and Services; (f) communicate with you by a variety of measures, including, but not limited to, by telephone, email, SMS or mail; (g) meet legal, regulatory and compliance obligations; and (h) investigate any complaints.


7.2 If you choose to withhold your Personal Information, it may not be possible for us to provide you with our Services, or for you to access certain parts of our App, or for us to respond to your queries.


8. Disclosing your Personal Information to third parties

8.1 We will only disclose your Personal Information to third parties for the purposes described in this Privacy Policy.


8.2 We may disclose your Personal Information to third parties where you have consented to that disclosure, or where such disclosure is for the primary purpose for which it was collected, or a related secondary purpose.


8.3 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, or otherwise to government bodies that require us to report data processing activities.


8.4 Information that we collect may from time to time be stored, processed in or transferred between parties located in Australia or countries outside of Australia.


8.5 We may share your Personal Information with third-party service providers to help us provide our Services, and to provide you with a payment platform.


8.6 When we disclose your Personal Information to third parties, we do so on the basis that it is treated with confidence, and is used only for the limited purpose of providing support for our Services, and in a manner consistent with this Privacy Policy.


8.7 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 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.


9. Data Ownership

9.1 You own all rights, title and interest in any Personal Information or Content that you provide to us.


9.2 You grant to Digitori Labs, or to any third parties used by us to provide our Services, a non-exclusive, worldwide, perpetual, and royalty free licence to use, copy, transmit, and store any Personal Information and any Content that you provide to Digitori Labs to enable the supply of the Services in accordance with our Terms and this Privacy Policy.


9.3 Digitori Labs, or any related entities, owns all rights, title and interest in any data or information that we create, generate, compile, derive or produce in connection with any supply of our App or Services, including data and information that is:


(a) aggregate or raw or statistical relating to usage, analyses and results of the App or Services; (b) for the purpose of optimising delivery, commercialisation and performance of our App or Services; and (c) samples and prototypes, conclusions, techniques, know how, methods and undocumented findings generated in the usual course of our business.


10. How we secure your Personal Information and Data Breach

10.1 We are committed to ensuring that the Personal Information you provide to us is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data, and to protect this data from misuse, interference, loss and unauthorised access, modification and disclosure.


10.2 A reportable “Data Breach” is a security incident where the integrity of Personal Information is compromised through being destroyed, lost, altered, corrupted, disclosed or accessed by an unauthorised person where it is likely to result in serious harm to any individual affected.


10.3 We have procedures and systems in place, including a data breach incident response plan, specific data breach policies, and procedures and personnel to deal with an actual or suspected “Data Breach”, and we will notify you and the applicable regulator in accordance with our obligations under the Privacy Act and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) (‘NDB Scheme’).


10.4 Please report any actual or suspected data breaches for investigation to Digitori Labs by using the Contact Us section provided on our App.


11. Cookies

11.1 We use cookies on our App. Cookies are small files that are stored on your computer or mobile device when you visit our App to keep track of your actions and preferences.


11.2 The types of cookies that we may use are:


(a) Functionality cookies. These are cookies that are essential for us to enable you to use our App effectively. An example of this would be when you make a purchase on our App or when you log into your account on our App.

(b) Analytics cookies. We use these cookies to measure and analyse how customers use our App. These cookies help us to monitor and improve the performance of our App, including through the use of data analytics for the number of visits to our App and traffic sources.

(c) Customer preference cookies. These cookies allow our App to record your choices and provide you with enhanced features, such as news and updates relevant to your preferences.


11.3 We use cookies and similar technologies:


(a) to bring you relevant content and improve your user experience; (b) to collect information, such as your IP address and browser type, device information and language; (c) to analyse data about webpage traffic; (d) for advertising and marketing purposes; and (e) to perform data analytics and improve our App.


11.4 You can configure your Internet browser to accept all cookies, reject all cookies, or notify you when a cookie is set. If you disable cookies from being stored on your computer or on your device, you may not be able to use the full functionality of the App.


12. Third-Party Analytics Tools and Third-Party Remarketing Tools

12.1 We use technologies and third-party services that may use Google Analytics, pixels, tags and web beacons (code snippets) on our App to customise content and advertising, to provide social media features, and to analyse traffic to our App, including about how you use and interact with our App.


12.2 We may also share information about your use of the App with our trusted social media, advertising and analytics partners.


12.3 Analytics Tools. We use third-party analytics tools to:

(a) analyse usage trends on the App, including the tracking and reporting of website traffic, ad conversion tracking, traffic analysis and marketing optimisation;

(b) collect this data in aggregate form so that it cannot identify any individual user.


12.4 Third-party analytics tools collect non-Personal Information, such as how often you visit our App, the web pages you visit, add-ons, and other analytics data that assists us in improving our products and services.


12.5 Remarketing Tools. We use third-party remarketing tools to position targeted ads to visitors that have already visited our App. We use our email database to create custom audiences on social media and online platforms, such as Facebook, LinkedIn and Instagram to promote our App and Services.


12.6 These third-party remarketing tools might include, but are not limited to:


(a) AdWords Remarketing (Google Inc.); (b) Facebook Custom Audience (Facebook, Inc.); and (c) Facebook Remarketing (Facebook, Inc.).


12.7 We reserve our rights to change, modify, add or remove any third-party analytics tools and third-party remarketing tools. By using our App, you consent to the processing of any information these tools will collect in the way and for the purposes described above.


13. Links

13.1 Our App may provide links to other websites that may be of relevance and interest to you. Links to other websites do not constitute sponsorship or endorsement or approval of other websites.


13.2 We have no control over, and are not responsible for, the privacy practices or the content of any linked websites.


14. Access to and how you can control your Personal Information

14.1 You may request details of Personal Information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth).

14.2 If you would like a copy of your data, or you believe that your data is inaccurate, out of date, incomplete or irrelevant, please Contact us using the contact details provided below.


14.3 In order to access your Personal Information, you will need to provide us with your details so that we can verify your identity.


14.4 We may charge a reasonable fee for providing you with a copy of your Personal Information records.


15. Complaints About Privacy

15.1 Please contact us using the contact details below if you have any questions or concerns about our collection, use or disclosure of Personal Information. We will aim to resolve your complaint within 30 days.


15.2 If you remain dissatisfied, you may refer your complaint in writing to the Office of the Australian Information Commissioner.


16. Changes to this Privacy Policy

We may need to update this Privacy Policy from time to time to accurately reflect our own data collection and processing practices or any changes to the Privacy Act. Amendments to this Privacy Policy are effective when they are posted on our App or website.


© 2018 Digitori Labs. ALL RIGHTS RESERVED.

Privacy Policy last updated 27 November 2018.