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Privacy Policy

Nebo Privacy Policy

Who we are

Nebo Global Pty Ltd (ACN 612 324 679) (“Nebo Global” or “we”) owns and operates the Nebo software application which provides a voyage tracking and social platform for the boating community (the “Nebo App”). Nebo Global is based in Perth, Western Australia.

The services offered by Nebo Global include the Nebo App, the website located at www.nebo.global (the Nebo Website), any Nebo mobile services and any other features, content or applications offered from time to time by Nebo Global using the Nebo App or in connection with the Nebo App (collectively, the “Nebo Services”).

This document should be read in conjunction with Nebo’s Terms of Use, which are available on Nebo Global’s website at www.nebo.global.

Words defined in the Terms of Use have the same meaning within this Privacy Policy unless otherwise defined.

1. What is this Privacy Policy about?

At Nebo we respect the privacy of your personal information in our care and are committed to protecting the privacy of the personal information we collect and receive.

The purpose of this Privacy Policy is to explain:
(a)              the application of this Privacy Policy
(b)              the kind of information we collect about you, how we collect it, and how we use it;
(c)              how we may disclose that information;
(d)              how you can access the information we hold about you;
(e)              when we may use your information to contact you;
(f)               the protection of your personal information; and
(g)              our use of cookies to collect information, and how you can control or delete these cookies (if implemented within the Nebo Services).

This policy also informs you of your rights to privacy and describes how we comply with our privacy requirements as set out in the Privacy Act 1988 (Cth) (the Privacy Act) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth).

2. Consent

By using Nebo Services you consent to the privacy practices set out in this policy.  If you do not agree with the policy and consent please discontinue use of the Nebo Services.

 

3. Privacy and your personal information

Personal information is information or an opinion that identifies an individual or allows their identity to be worked out from the information.  The information that Nebo collects about you depends on how you use the Nebo App and Nebo Services.

You can visit and browse our website without disclosing any personal information.

Personal Information we may collect includes:

(a)              basic personal details such as your name, address and email address,

(b)              your vessel name,  vessel type and vessel’s home port;

(c)              you and your vessel’s location as indicated by your mobile device , including real time logging of GPS coordinates, routes, times, dates and duration at locations at which such devices are located;

(d)              voyages you and your vessel have taken, as indicated by your mobile device;

(e)              other unique identifiers for vessels;

(f)               opinions about the Nebo Services and our products and staff; and

(g)              any information sent to us through correspondence.

 

Generally, we do not collect sensitive information.  If we think any sensitive information is reasonably necessary to allow us to perform our functions or activities, we are required by the Privacy Act to ask for your consent to collect that information and to tell you what we will do with it. We will comply with the Privacy Act in this regard

4. How Nebo Global collects your personal information

Nebo Global  collects personal information about you in a number of ways, including:

  • from you directly by personal contact when you create an account as well as through mail, telephone, email and online communications and interactions;
  • your account activity when you use the Nebo Services including features intended to create a log of your journey such as GPS coordinates and route information from the device you chosen to have the App installed on; and
  • information from your social networks which you choose to connect to your Nebo account.

5. Why Nebo Global Collects Your Personal Information

Nebo Global collects your Personal Information for a variety of purposes including :

  • to deliver products or provide our services for instance, we use your location, route information, GPS coordinates, times, dates and duration at locations at which such devices are located to create a log of your journey;
  • to share your submissions with other users of our services and to facilitate communication between you, including on social media, provided you have opted in to this feature;
  • to communicate with you regarding service issues and updates;
  • to measure our performance and to improve our services;
  • for verification purposes;
  • to develop new services;
  • to generate revenue;
  • for analysis of usage of our services;
  • for marketing and promotion purposes;
  • to perform other administrative functions;
  • to comply with legal requirements; and
  • for purposes directly related to any of the above.

We may not be able to do these things without your personal information and may not be able to manage your profile, receive payments or contact you.

If you do not want to receive marketing and promotional material from Nebo Global, you may opt out of receiving this type of communication at any time by clicking the ‘unsubscribe’ link provided in those electronic communications.

 

6. Use and disclosure of your personal information

The Nebo App and Nebo Services are designed to include information being shared with others.  How much information you share is up to you.  Your username does not need to be your real name and you are not required to give details of your social media profiles or include personal information about yourself.  If you do these things, that information may be accessible by other users.

We disclose your personal information to third parties for the following purposes:

o        to provide the products or services you wish to use;

o        to customise and promote our services which might be of interest to you;

o        to assist us to run competitions and offer giveaways;

o        to provide support to you in connection with your use of the Nebo Services;

o        if permitted or required by law; or

o        for any other purpose, with your consent.

We may also provide your personal information to our related bodies corporate and our service providers who assist us with customer contact, archival, auditing, accounting, legal, business consulting, banking, delivery, data processing, website or technology services. We will take reasonable and practicable steps to ensure third parties we deal with take steps to protect your privacy. All of our employees are required to maintain the confidentiality of any Personal Information held by us.

We may also need to disclose your Personal Information to our advisors, including our accountants and lawyers.

If you use a Nebo Service overseas then your Personal Information may be made available to Nebo Global’s overseas partners and suppliers. Where these overseas partners and suppliers are located outside of the European Union (EU) or the European Economic Area (EEA) Nebo will put in place appropriate measures in accordance with its legal requirements.  In particular Nebo uses external service providers for the following purposes:

Nebo Global uses hosting companies that may have servers that are physically located overseas, including in the United States of America. Nebo Global also uses service providers and contractors located overseas, and your Personal Information may be disclosed to them. Nebo Global will take reasonable steps to ensure that any overseas recipient complies with the Privacy Act. You should also be aware that where data are hosted overseas, access to and use of that Personal Information will be governed by laws that apply in those overseas locations.

Nebo Global may share aggregated, non-personally identifiable information publicly or privately, for example, to show trends about the general use of Nebo Services.

7. Direct Marketing

From time to time we may use the personal information collected from you for direct marketing purposes.  If we do contact you in this way, it will only be in relation to matters that customers would reasonably expect us to contact them directly about.

We will ask for your consent before we use your personal information for marketing purposes if we have not collected that personal information directly from you.

If you receive marketing offers from us and do not wish to receive them in the future, please use the ‘unsubscribe’ link provided in those electronic communications.

8. Security of Your Personal Information

We may hold your personal information in physical and electronic form both at our premises and with the assistance of our service providers. We implement a range of measures to protect the security of that information. We are also required to take reasonable steps to destroy or de-identify information when no longer needed for any permitted purpose.

If you are considering sending us any personal information electronically, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard http). You agree that, even though Nebo Global uses reasonable endeavours to secure your Personal Information, Nebo Global cannot guarantee that any information sent or accessed electronically is secure.

You may also assist Nebo Global in keeping your Personal Information secure by maintaining the confidentiality of your account information and notifying Nebo immediately if there is any unauthorised use of your account, or any other breach of security relating to your account.

We require our external service providers with access to personal information to have data processing agreements that require them to take necessary and reasonable steps to protect the personal information provided to them.

In the unlikely event of a suspected data breach, Nebo Global will within 30 days assess and evaluate whether a breach has occurred and will, if required, notify the relevant data protection authority unless the breach is not likely to present any risk to your rights.

9. Cookies

Data collection devices, called “cookies”, are files placed on your electronic devices to collect information. Nebo Global may use cookies to enhance the use of the Nebo Services. Cookies can record information about your visit to assist us in better understanding your needs and requirements. You should be aware that any Internet browser you use will generally be set to automatically accept cookies.

If you do not want any cookies to be placed on your electronic devices, you can alter your browser settings to refuse to accept cookies. However, this may also limit the way you can use the Nebo Services if we use cookies.

10. Destroying personal information

Nebo Global will destroy, or take reasonably commercial steps to de-identify, personal information when this is no longer required by us.

11. Links

The Nebo Services may contain links to Third Party Websites. Nebo  is not responsible for the information on these sites, or their privacy policies. Nebo  may keep track of your interactions with Third Party Websites provided on the Nebo Services in order to improve the Nebo Services and to aggregate statistics.

12. Accuracy of your information

Nebo Global takes all reasonable precautions to ensure that the personal information it collects, uses and discloses is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. We therefore recommend that you:

  • let us know if there are any errors in your personal information we hold; and
  • keep us up-to-date with changes to personal information you have previously

13. Your rights in relation to personal information

13.1 Your Australian privacy rights

Under the Privacy Act you have the right to request access to your personal information that is held by us about you. You also have the right to request correction of any of your personal information that we hold.

Please contact us if you would like to request access to the personal information we hold about you. You will need to put your request in writing for, security reasons, and send it to the Privacy Officer as detailed in par 14 below.  Please provide us with as much detail as you can about the particular information you seek, in order to help us retrieve it.  We will use commercially reasonable endeavours to provide the information within 10 business days of receiving your request. Please note that Nebo Global may charge a fee to cover the cost of meeting your request.

You are able to change or update your account information at any time through the Nebo Services.

13.2 Your European privacy rights

If you are a data subject in Europe under the General Data Protection Regulations 2016/679 (‘GDPR’) you have the right to:

  • request access to and obtain copies of the personal information we have collected from you in an easily readable format;
  • modify or rectify your personal information if it is no longer accurate;
  • exercise the “Right to be Forgotten” and request that we erase your personal information if you believe it is no longer required for the purposes for which we originally collected it; and
  • object to or restrict the collection or processing of the personal information we have collected from you

Please contact us if you wish to exercise any of these rights. Please send your request to our Data Protection Officer using the contact details set out in paragraph 14.

14. Queries and Complaints

If you believe that the privacy of your Personal Information is not effectively protected, you are concerned that your privacy has been compromised through the dissemination of your Personal Information, or you simply have a query regarding data protection or privacy, please contact the Data Protection Officer at the contact details below:

Outside the European Union:

info@nebo.global

Attention –  Privacy Officer

 

Within the European Union:

We have appointed GDPR-Rep.eu as our representative according to Art 27 GDPR. If you would like to exercise your GDPR data privacy rights, please visit
https://gdpr-rep.eu/q/12646524

GDPR-Rep.eu

iuro | Dr. Andreas Mätzler

Attorney at Law

c/o Nebo Global

Schellinggasse 3/10

1010 Vienna, Austria

Email: office@gdpr-rep.eu

Website: https://www.gdpr-rep.eu

Please add the following subject to all correspondence:

GDPR-REP ID: 12646524

 

We take all enquiries seriously and will attend to your question or complaint promptly.

If you are not happy with the way we deal with your privacy complaint you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commission (OAIC).  More information about making a complaint to OAIC is available at http://www.oaic.gov.au/privacy/privacy-complaints

15. Amendments

Nebo  may review and amend this Privacy Policy from time to time. If Nebo Global does make amendments, the amended Privacy Policy will be published on the Nebo Global website.

You agree that it is your responsibility to check for updates to Nebo Global’s Privacy Policy. You further agree that your continued use of the Nebo Services is acceptance of Nebo Global’s amendments to the Privacy Policy.

Policy last updated September 2018

 

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