Privacy Policy
V1.0 - Last updated 30 September 2022
This Privacy Policy describes how ZeemoChat Pty Ltd Pty Ltd ACN 654 994 493 (we, our, us ) manages personal information about individuals whose data is collected and processed by us and:
(a) our apps available in the Google Play Store and Apple App Store (Apps); and
(b) our website at https://www.zee-mo.com (Website),
(together, the Zeemo Platform ).
We are committed to complying with our privacy obligations in accordance with all applicable data protection laws, including the Australian Privacy Principles contained in Schedule 1 to the Privacy Act 1988 (Cth) (each, an APP).
We may review our Privacy Policy periodically and reserve the right to change the Privacy Policy at any time at our discretion by posting such changes on the Website. Changes will be effected immediately when posted on the Website and your continued access, browsing or use of the Website and/or Apps thereafter will constitute your acceptance of those changes. Our policy is to be open and transparent about our privacy practices.
The Zeemo Platform brings together individuals seeking consulting services (Customers) and experts able to provide those consulting services (Experts) via functionality that enables Customers to identify Experts relevant to their requirements, and to arrange and attend at video chat meetings (ZeemoChat Meetings) with them. The Zeemo Platform gives Experts the opportunity to leverage their knowledge, experience and expertise and to get paid for attending ZeemoChat Meetings with Customers.
1 Consents
1.1 Our Customers and Experts are required to comply with all applicable privacy laws.
1.2 We rely on our Customers and Experts to obtain all relevant privacy consents and authorisations from their personnel and other data subjects (if any) required by law, in order for the personal information that is provided to us and entered into the Zeemo Platform to be collected, disclosed and otherwise processed by us.
1.3 We also rely on Customers and Experts to ensure that all personal information about their personnel and other data subjects (if any) held by us is accurate, up to date, complete, relevant and not misleading.
1.4 We encourage each of our Customers and Experts to ensure that personnel and data subjects (if any) are familiar with their privacy policies so that data subjects understand how they will collect, use and otherwise process personal information about them, via our Platform or otherwise.
1.5 Data subjects, when referred to in this Privacy Policy, are a reference to any third party whose personal information is entered into the Zeemo Platform by a Customer or Expert.
2 The types of personal information that we collect and hold about Customers, Experts and other data subjects
2.1 We collect and hold the following types of personal information:
(a) Content provided to us and/or entered into the Zeemo Platform about data subjects : All information, including personal information, that is provided to us or entered into the Zeemo Platform (either by Experts, Customers or otherwise) is stored in systems managed by us. The types of personal information collected or held by us may include names and contact details, as well as any other personal information provided to us or entered into the Zeemo Platform by, about or on behalf of, a data subject.
(b) Information about Customers, Experts and their personnel : We collect contact details of our Customers and Experts and their personnel (if any), such as names, contact information, professional and educational background and billing information, including credit card and other payment method details. Credit card details and other payment method details are not held by us, but are held by payment gateway providers that we use. Other than the last 4 digits of a credit card, all such credit card and payment method information is not accessible by us.
(c) Information required for the support, maintenance and security of the Zeemo Platform : In order to support and maintain the Zeemo Platform and operate the Zeemo Platform, we collect and process end user information including IP addresses, email and physical addresses, telephone numbers, user access logs, usernames, passwords, and information included by Customers and Experts in technical support tickets and error messages.
3 How we collect personal information
3.1 Our policy is to not collect personal information by means that are unfair or unreasonably intrusive in the circumstances.
3.2 We collect information about prospective Customers and Experts from public and private databases and when they otherwise voluntarily disclose it to us or authorise us to collect it, in order for us to market, sell and operate the Zeemo Platform.
3.3 When a prospective Customer or Expert registers an account on the Zeemo Platform, we collect personal information about them and their data subjects (if any) in one or more of the following ways:
(a) when a Customer, Expert and/or their end user enter personal information into the Zeemo Platform that we host;
(b) when a Customer, Expert and/or their end user provides personal information to us (for example, as part of the onboarding process for new Customers or Experts);
(c) when it is provided to us by third parties on behalf of a Customer or Expert or pursuant to an agreement with a Customer of Expert for it to be entered into and/or processed by the Zeemo Platform;
(d) when it is voluntarily disclosed to us (such as via telephone, e-mail and online forms).
4 How we use personal information
|
Category |
How we use and process that personal information |
Our reason for collecting the personal information |
|
Personal information about prospective Customers, Experts and their personnel (if any) |
To inform, market and promote the Zeemo Platform to prospective Customers and Experts and onboard them onto the Zeemo Platform. To investigate privacy breaches and comply with applicable law. Backing up and restoring data that includes personal information. To carry out security audits, investigate security incidents and implement security processes and procedures that require access. |
Necessary for our legitimate interests (in order to operate and grow our businesses). |
|
Personal information about Customers, Experts and their personnel (if any) |
To setup and configure accounts on the Zeemo Platform for a Customer or Expert. To communicate with Customers, Experts and their personnel (if any) about their current and prospective use of Zeemo Platform, including with respect to their current and anticipated usage of it, and to discuss and implement product and services requirements. To allow Experts to market their consulting services on the Zeemo Platform; To allow Customers to setup ZeemoChat Meetings with Experts; To provide Customers, Experts and their personnel (if any) with technical support and maintenance services including by responding to help desk tickets, scheduling upgrades and enhancing the Zeemo Platform. To send out billing information and notices to Customers, Experts and/or their personnel (if any) and to process payments. To discuss our security requirements. To provide Customers, Experts and/or their personnel (if any) with information about promotional offers and new products and solutions that we make available. In order to identify Customers, Experts and/or their personnel (if any) when contacted with technical support questions. To administer our contractual relationships with Customer and Experts (and to enforce our contractual rights and their contractual obligations). To investigate privacy breaches and comply with applicable law. Backing up and restoring data that includes personal information. To carry out security audits, investigate security incidents and implement security processes and procedures that require access to data subject personal information. |
Necessary for our legitimate interests (in order to operate, administer and grow our businesses including to operate the Zeemo Platform, IT systems and networks, manage our suppliers and hosting environments and ensure the successful delivery of our products and services). Performance and enforcement of contracts with our Customers and Experts. Compliance with our legal obligations. |
|
Personal information about other data subjects |
As required to provide and support the functionality of the Zeemo Platform for a Customer or Expert and to process the personal information of data subjects on behalf of a Customer or Expert via the Zeemo Platform. To provide technical support services to our Customers and Experts that require us to view and/or update data subject data held by us in the Zeemo Platform. To administer our contractual relationships with Customer and Experts (and to enforce our contractual rights and their contractual obligations). To investigate privacy breaches and comply with applicable law. Backing up and restoring data that includes data subject personal information. To carry out security audits, investigate security incidents and implement security processes and procedures that require access |
Performance of our contracts with a Customer or Expert. Necessary for our legitimate interests (in order to administer our businesses including to allow our Customers and Experts to operate the Zeemo Platform, and to enable us to operate our IT systems and networks, manage our hosting environments and ensure the successful delivery of our services). To comply with our legal and statutory obligations. |
5 How we hold and secure personal information
5.1 We hold and store personal information that we collect in our offices, computer systems and third party owned and operated hosting facilities.
5.2 We take reasonable steps to protect personal information that we hold using such security safeguards as are reasonable in the circumstances to protect against loss, unauthorised access, modification and disclosure and other misuse, and we implement technical and organisational measures to ensure a level of protection appropriate to the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.
5.3 We:
(a) only use reputable cloud hosting providers to host personal information;
(b) implement passwords and access control procedures, anti-virus, firewall and security controls for email and other applicable computer software and systems;
(c) maintain files, in both hardcopy and electronic form, at our offices and other access-controlled premises;
(d) operate online records managements systems on secure networks;
(e) regularly perform security testing;
(f) maintain physical security measures in our buildings and offices such as visitor access management, cabinet locks, surveillance systems and alarms to ensure the security of information systems (electronic or otherwise);
(g) require our employees, agents and contractors to comply with the privacy and confidentiality provisions in their employment and subcontractor agreements that we enter into with them;
(h) use SSL encryption on our systems;
(i) have data backup archiving and disaster recovery processes in place;
(j) if appropriate in the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, content and purpose of the processing, we will encrypt personal information; and
(k) with respect to personal information that we no longer require or where we are otherwise required to destroy it under applicable law, we ensure that such personal information is securely destroyed.
6 Disclosure of personal information
6.1 We will disclose personal information to our employees who assist us in the performance of our services. We ensure that they are aware of their information security responsibilities, are appropriately trained to meet those responsibilities and have entered into agreements which require them to comply with privacy and confidentiality obligations which apply to personal information that we provide to them.
6.2 We only disclose personal information that we collect to third parties as follows:
(b) in order to provide real-time video conference and chat facilities that are integrated into the Zeemo Platform, we have integrated Agora Lab, Inc.'s technology into the Zeemo Platform. Agora hosts all ZeemoChat Meetings and processes all audiovisual content in every ZeemoChat Meeting. You can read Agora Lab, Inc.'s privacy policy at https://www.agora.io/en/privacy-policy/;
(c) when performing contracts we may outsource certain obligations to third party contractors in accordance with our contractual rights (such as hosting, software development and other professional services). Professional services carried out by them may require access to Customer, Expert and data subject personal information;
(d) when providing information to our legal, accounting or financial advisors/representatives or insurers, or to our debt collectors for debt collection purposes or when we need to obtain their advice, or where we require their representation in relation to a legal dispute;
(e) where a person provides written consent to the disclosure of personal information about them;
(f) where it is brought to our attention that specific personal information needs to be disclosed to protect the safety or vital interests of any person;
(g) to avoid prejudice to the maintenance of the law by any public sector agency, including the prevention, detection, investigation, prosecution, and punishment of offences;
(h) for the enforcement of a law imposing a pecuniary penalty;
(i) for the protection of public revenue;
(j) for the conduct of proceedings before any court or tribunal (being proceedings that have been commenced or are reasonably in contemplation); or
(k) where required by law.
7 Third party products and websites
7.1 The Zeemo Platform may include links to third party websites or applications and integrations with third party products and services. Our linking to those websites or applications does not mean that we endorse or recommend them. We do not warrant or represent that any third party complies with applicable data protection laws. Customers, Experts and their data subjects should consider the privacy policies of any relevant third party prior to sending personal information to them.
8 Interacting with us without disclosing personal information
8.1 If you do not provide us with your personal information, you can only have limited interaction with us. For example, you can browse our Website without providing us with personal information, such as the pages that generally describe the Zeemo Platform that we make available, and our Contact Us page. However, when you submit a form on our Website or become a Customer or Expert, we need to collect personal information from you in order to identify who you are, so that we can operate the Zeemo Platform, and for the other purposes described in this Privacy Policy.
8.2 You have the option of not identifying yourself or using a pseudonym when contacting us to enquire about the Zeemo Platform but not if you wish to actually use the Zeemo Platform or any part thereof as an Expert. You can use the Zeemo Platform as a Customer on an anonymous basis by using a pseudonym when subscribing to the Zeemo Platform.
9.1 We may transfer personal information to our contractors and service providers who assist us with the supply and provision of the Zeemo Platform, and to assist us with the operation of our business generally, where we consider it necessary for them to provide that assistance. We will take reasonable steps to ensure that such recipients do not breach the APPs in relation to personal information or other relevant State and Territory laws (as applicable). At present we transfer your personal information to our interstate contractors and service providers within Australia, other than to our software developers in Egypt and to Agora Lab, Inc. in the United States of America.
10 How to access and correct personal information held by us
10.1 Customers, Experts, their personnel and other data subjects who wish to access and correct the personal information held by us about them should contact us.
10.2 Prior to contacting us or submitting a request for access to correct any personal information held about them, Customers, Experts and their personnel can update the personal information about them by logging into their account on the Zeemo Platform, where such functionality is available. However, we encourage you to contact us in any event and we would be happy to assist you.
10.3 All other data subjects who wish to access and correct the personal information held by us about them should contact us.
10.5 In addition to clause 10.4 , we retain personal information in connection with the Zeemo Platform as follows:
(a) Personal information about Customers, Experts their personnel and other data subjects will be held while the applicable Customer or Expert has a registered account with us and thereafter for a period of 5 years for tax purposes; and
(b) We will only keep personal information for longer periods than specified above, where required under applicable law.
10.6 As an alternative to deleting personal information, we may elect to de-identify it where permissible by law. We will de-identify certain types of personal information for the purpose of improving the Zeemo Platform and for provision to third parties for marketing and research purposes.
10.7 Where you require personal information to be returned, it will be returned to you at that time, and we will thereafter delete all then remaining existing copies of that personal information in our possession or control as soon as reasonably practicable thereafter, unless applicable law requires us to retain the personal information, in which case we will notify you of that requirement and only use such retained data for the purposes of complying with those applicable laws.
10.8 We will handle all requests for access to personal information in accordance with our statutory obligations. You can request to receive a copy of your personal information by emailing [ [email protected] ]. We may require payment of a reasonable fee by any person who requires access to their personal information that we hold, except where such a fee would be contrary to applicable law. We will not charge you for the making of any such request. We will endeavour to provide a response to any request for access to personal information within 72 hours from the time a request is made.
11 Our contact details
11.1 Any person who wishes to contact us for any reason regarding our privacy practices or the personal information that we hold about them, or make a privacy complaint, may contact us as follows:
Contact: Privacy Representative
Email: [ [email protected] ]
11.2 We will endeavour to resolve any privacy complaint with the complainant within a reasonable time frame given the circumstances. This may include working with the complainant on a collaborative basis or otherwise resolving the complaint.
11.3 If the complainant is not satisfied with the outcome of a complaint or they wish to make a complaint about a breach of the Australian Privacy Principles, they may refer the complaint to the Office of the Australian Information Commissioner who can be contacted using the following details:
Telephone: +1300363 992
Email: [email protected]
Address: GPO Box 5218, Sydney NSW 2001
