Privacy Policy

1 About this policy

Iota Vale Pty Ltd (ABN 67 701 451 961) ("Iota Vale", "we", "us", "our") respects your privacy. This policy explains how we collect, use, disclose and protect personal information when you:

• visit iotavale.com.au (the "website");
• contact us, or engage us to provide consulting, development or managed services (our "services"); or
• download or use an app we publish on the Apple App Store or Google Play (our "apps").

We handle personal information in line with the Australian Privacy Principles in the Privacy Act 1988 (Cth). If you're in the European Economic Area, the United Kingdom or another place with its own privacy laws, section 12 explains the additional rights you may have.

Section 14 sets out the details for each app. Those details form part of this policy.

2 The information we collect

2.1 Information you give us

• Contact details: your name, email address, phone number, organisation and role, and the content of messages you send us.
• Account information (for apps with accounts): your email address, display name, sign-in identifiers and settings. If you sign in with Apple or Google, we receive an identifier and only the details you choose to share. With Sign in with Apple, you can hide your email address from us.
• Content you create in our apps: the information you enter, upload or save, so the app can store it and sync it across your devices.
• Support requests: what you tell us when you ask for help, including any attachments.
• Client and supplier information: the business contact details of people we work with while providing our services.

2.2 Information collected automatically

• Crash and diagnostic data: when an app crashes or hits an error, we collect technical details such as device model, operating system version, app version and the error trace, so we can fix the problem.
• Usage data: events such as screens viewed and features used. We use this data in aggregate to understand how our apps are used and to improve them.
• Website analytics: our website uses Cloudflare Web Analytics, which counts page views without cookies, without fingerprinting, and without identifying you or following you across other websites.
• Server and security logs: our hosting providers process IP addresses and request details to deliver the website and apps and keep them secure.

2.3 Purchases and subscriptions

In-app purchases and subscriptions are processed by Apple or Google. We never receive or store your payment card details. We receive information about each transaction, such as the product, date, price, country, subscription status and a transaction identifier, so we can unlock and manage what you bought.

2.4 Information we don't collect

We don't intentionally collect sensitive information, such as health or biometric information, unless an app needs it for a feature you choose to use and asks for your consent first. Section 14 would describe any such case. We don't buy personal information from data brokers.

3 How we use personal information

We use personal information to:

• provide, maintain and improve the website, our services and our apps;
• create and manage accounts, and store and sync your content;
• process purchases, restore purchases and manage subscriptions;
• respond to enquiries and provide support;
• diagnose crashes, fix bugs, and keep our systems secure, including detecting and preventing fraud and abuse;
• understand usage in aggregate so we can decide what to build next;
• send service messages about your account, security, purchases or changes to our terms;
• send marketing emails, but only if you've opted in. Every marketing email includes an unsubscribe link; and
• comply with our legal obligations and enforce our terms.

We do not sell personal information. We don't use it for targeted advertising, and we don't track you across apps and websites owned by other companies.

4 AI features in our apps

Some of our apps may include features powered by artificial intelligence. Where an app does, section 14 explains which data is sent to which AI provider and why.

We don't use your content to train AI models, and we use AI providers whose terms prohibit them from training on it, unless you explicitly agree otherwise. We don't use AI to make decisions about you that have legal or similarly significant effects.

5 Who we share personal information with

We share personal information only as needed with:

• service providers who host, store or process information for us, such as cloud hosting and databases, email delivery, crash reporting and analytics. They may use it only to provide services to us, and must protect it;
• Apple and Google, to deliver our apps and process purchases;
• professional advisers, such as lawyers, accountants and auditors, who are bound by confidentiality;
• authorities and others, where the law requires it or where it's needed to protect the rights, property or safety of any person; and
• a buyer or successor, if our business or an app is sold or restructured. Your information would stay protected by this policy.

Section 14 lists the main service providers for each app.

6 Overseas disclosure

Some of our service providers store or process information outside Australia, including in the United States. When we disclose personal information overseas, we take reasonable steps to make sure it's handled in a way that's consistent with the Australian Privacy Principles, for example through contractual protections.

7 Cookies and similar technologies

The website doesn't use advertising or tracking cookies, and its analytics are cookie-free.

Our apps may store identifiers and settings on your device, for example to keep you signed in. These are needed for the app to work.

8 How long we keep information

We keep personal information only for as long as we need it for the purposes in this policy, or as the law requires.

9 How we protect information

We protect personal information with measures such as encryption in transit and at rest, least-privilege access, multi-factor authentication for administrative access, logging and monitoring, and prompt security updates.

No system is perfectly secure. If a data breach is likely to cause serious harm, we'll notify the people affected and, where the law requires it, the Office of the Australian Information Commissioner (OAIC).

10 Your choices and rights

• Access and correction: you can ask for a copy of the personal information we hold about you, or ask us to correct it.
• Deletion: you can delete your app account in the app, at Settings > Account > Delete account, or follow the steps on our Account and Data Deletion page at iotavale.com.au/legal/account-deletion.
• Analytics: where an app offers the option, you can turn analytics off in its settings. You can also limit data sharing through your device's privacy settings.
• Marketing: you can unsubscribe at any time using the link in any marketing email.
• Anonymity: you can browse the website without telling us who you are. Some app features need an account.

To make a request, email us (see section 15). We may need to verify your identity first. We'll respond within 30 days, and we don't charge for requests.

11 Children

Our website and apps aren't directed at children under 13, or under 16 in the EEA and UK. We don't knowingly collect personal information from them. If you believe a child has given us personal information, contact us and we'll delete it.

12 If you're outside Australia

European Economic Area and United Kingdom. We process personal information on these legal bases: to perform our contract with you (for example, to provide your account and purchases), for our legitimate interests (for example, security, fixing bugs and improving our apps), with your consent (for example, optional analytics or marketing), and to comply with the law. You may have the right to access, correct, erase, restrict or object to processing, to data portability, and to withdraw consent at any time. You can also complain to your local data protection authority.

United States. We don't sell personal information or share it for cross-context behavioural advertising. Depending on where you live, you may have the right to know, access, correct and delete personal information. We won't discriminate against you for exercising these rights.

13 Changes to this policy

We may update this policy from time to time. We'll change the "Last updated" date above, and if a change is significant we'll let you know in the app or by email before it takes effect.

14 App-specific information

We haven't published any apps yet. Before each app is released, we'll add its details here: the data it collects and why, the service providers it uses, and how to delete your account.

15 Contact and complaints

For privacy questions, requests or complaints, email hello@iotavale.com.au with "Privacy" in the subject line.

We'll acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If you're not satisfied with our response, you can contact the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.