We respect your right to privacy and this policy sets out how we collect and treat your personal information provided to us whilst using this Site including the Deep Sphere platform. This policy also sets how your rights to access and manage, including transfer and deletion of, your personal information.
We are bound by and will comply with the Privacy Act 1988 (Cth) and any other relevant privacy rules and legislation as enacted from time to time. This includes the EU General Data Protection Regulation (GDPR) for persons located in the European Union and the California Consumer Privacy Act (CCPA) for persons located in the state of California.
Deep Sphere is a product and brand wholly owned and developed by Neuro Pro Pty Ltd (ACN 614 460 178) (Neuro Pro).
Winning Lab Pty Limited ACN 638 154 033 (Winning Lab) has an exclusive licence from Neuro Pro to use and commercialise, including by way of sub-licence, Deep Sphere, subject to terms of a separate licence agreement.
The Site may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites and you access these sites at your own risk. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that you visit to identify how it collects and uses personal information.
References to “you”, “your” or “user” means any person using or browsing the Site or using Deep Sphere.
“App” means the Deep Sphere web application and any other access points to the Deep Sphere platform.
“Personal information” is information we hold which is identifiable as being about you.
“Social Media” means social media forums, applications, functions and promotions (including, but not limited to, Facebook, LinkedIn, Google+ and Twitter).
“Deep Sphere survey” means the survey completed by an individual to receive a Deep Sphere result.
1. What personal information we collect
1.1 In the process of conducting our business, we are likely to collect personal information about you. The type of personal information we collect generally includes, but is not limited to:
(b) email address;
(c) any content or other media posted by you on the Site;
(d) your opinions, views or experiences posted by you on the Site;
(e) information you voluntarily provide to us via Social Media, SMS and email; and
(f) statistical information for the purposes of product development, risk assessment and audit requirements.
If you are accessing our products and services via our Site, we may use technology to collect information as to your activities, including the IP address of your computer (or other devices), your web browsing history on our websites and transactional data including your payment histories.
2. How we may collect your personal information
2.1 We collect personal information from or about you in a variety of ways, including:
(a) when your account owner provides your details to us or enters them through the Site or the Deep Sphere platform;
(b) when you interact with another user through the Site;
(c) when you access the Site;
(d) when you add any content to the site including (but not limited to) any post, Deep Sphere survey, comment or response to any questions;
(e) when you click on any links contained in emails that we send you;
(f) when you provide us with information through Social Media and widgets like the Social Media share buttons.
There may also be occasions when we collect personal information from publicly available sources or third parties, such as via our business partners or social media platforms such as Facebook or Twitter.
3. Use of your personal information
3.1 We use your information to provide our service to you.
3.2 We may provide your information to third parties, for example, to our business partners (such as Amazon Web Services) who assist us in the provision of our services to you. For example, Amazon Web Services assists us to perform tasks such as transmitting and storing your information securely in order to display it to you and your teammates, as well as making backups to prevent data loss. If your information was provided by your employer, your employer will have access to the information. If you have not consented to the provision of your information by your employer, please notify us immediately on firstname.lastname@example.org with your instructions to either delete or retain your personal information.
3.3 We provide content and services on a range of platforms (including social media networks) with interactive features to which you may contribute. If you post your personal information in publicly accessible places or social media platforms, your personal information will become publicly available (subject to, where applicable, any privacy settings you have in place in social media platforms). We will not be responsible for the protection of personal information you choose to publish this way.
3.3 We may also use your personal information to:
(a) process any actions you have made through the Site;
(b) manage our ongoing relationship;
(c) resolve complaints;
(d) develop products and services we think may be of interest to you;
(e) conduct quality assurance and market research activities;
(f) provide you with weekly updates as to your activity on the Site;
(g) to improve our service and notify you of any opportunities that we think you might be interested in;
(h) perform any of our other functions and activities relating to our business; and
(i) comply with laws and regulations.
4. Direct Marketing
4.1 By supplying us your information, you give us permission to contact you (including via email, SMS, MMS, social media and telephone) to provide you with information about products and services offered by us and our related corporate and business partners that we think may be of interest to you.
4.2 By signing up to start using Deep Sphere (including the Site), you consent or have consented to the use of any of your personal information which we have received from you whilst using the Site. If you are located in the EU you must confirm your consent by checking the appropriate box on the sign up page. If you wish to withdraw your consent to our use of your personal information you may do so at any time by contacting us on email@example.com. If you do not want us to use your personal information for direct marketing only, you can contact us at firstname.lastname@example.org and request that you be removed from any direct marketing list.
4.3 In the event that you do withdraw your consent to receive direct marketing only we will still contact you to manage our ongoing relationship. This may include product updates and other important announcements such as updates to our policies.
5. Disclosure of your personal information overseas
5.1 We may disclose your personal information to organisations outside of Winning Lab which assists us to deliver our products and services. These third parties are too numerous to list and they may change from time to time. We are likely to disclose your personal information to recipients in the following countries:
(b) New Zealand;
(c) United States of America;
(d) United Kingdom;
(e) EU; and
6. Security of your personal information
6.1 We take all reasonable steps to protect your personal information. However, since no system is 100% secure or error free, we cannot guarantee that your personal information is totally protected, for example, from hackers or misuse. If you enter personal information on our Site, you should exercise due care to safeguard any passwords, ID number, or other special access features associated with your use of our website. We exclude any liability whatsoever allegedly caused by a breach of security and/or any unauthorised access to your personal information and/or any other information placed by you on the Site.
6.2 As part of normal logging of network activity, some of our ystems may collect specific information about network and internet services accessed by individual users. This information may be stored for a period of time and analysed through AI/ML processes for suspicious behaviour. This information may be used in a forensic investigation, as may be required from time to time, in the event of a security incident or investigation.
6.3 We will take all reasonable steps to keep up to date with any advances in security technology.
6.4 You acknowledge and agree that you are completely responsible for maintaining the security of your login details and passwords and in no circumstances are we to be held liable for any unauthorised access to your account.
7. Data storage
7.1 Your information is stored securely in Australia via Amazon Web Services. Some personal information may be stored by our email system providers in the United States of America or other jurisdictions. Any information which we hold for you is stored on servers that are protected in controlled facilities. In addition, our employees and the contractors who provide services related to our information systems are obligated to respect the confidentiality of any personal information held by us. Notwithstanding the above, we explicitly disclaim any and all liability in relation to information contained on the site and will not be held responsible for any unauthorised access of your personal information.
8. Access to your personal information
8.1 You can access, update, or correct your personal information by contacting us on email@example.com. You can also request the deletion or transfer of your personal information by contacting us on firstname.lastname@example.org.
9. Complaints about privacy
9.1 If you have any complaints about our privacy practices, please feel free to send in details of your complaints to email@example.com. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
11. The Site
11.1 When you visit our website: When you view our website we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
11.3 Web Beacons
11.4 Third party sites
(a) You will comply with all relevant laws, including the General Data Protection Regulation and the Privacy Act 1988 (Cth) including without limitation that you have the express consent from any Employee Users to collect and use their data on the App.
(b) Our site has links to other websites not owned or controlled by us. We are not responsible for these sites or the consequences of you going on to those sites.
(c) We may also allow service providers like third party analytics, advertising and advertising partners, to place cookies on your computer using web beacons. We may, or may not allow third party service providers to, use mobile or tablet measurement software to obtain similar information to that which we obtain through cookies or web beacons.
If you have any questions at all, you can contact us in the following ways:
Email: Please use our contact form or email us at firstname.lastname@example.org
Phone: 1300 050 050
Post: Winning Lab, Level 2, 20A Danks St, Waterloo NSW 2017
Winning Lab Pty Ltd
ACN 638 154 033
Level 2, 20A Danks Street
Waterloo NSW 2017
For more information about privacy issues within Australia, please visit the Australian government website for the Office of the Information Commissioner. For more information about privacy issues within the EU, please visit https://www.eugdpr.og/. For more information about privacy issues within the State of California, please visit https://oag.ca.gov/privacy/ccpa and https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375