JX2 Technology Pty Ltd ABN 61 944 720 595 as trustee for JX2 Technology Pty Ltd Unit Trust trading as Vintrace (Vintrace, us, we, our) takes your privacy seriously and seeks to comply with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the European Union General Data Protection Regulation (EU) 2016/679 (GDPR). This Privacy Policy describes how we collect, use, disclose, store, and handle your personal information provided to us, or otherwise collected by us offline or online, including through our website (Site).
By accessing, browsing or otherwise using the Site, you accept this Privacy Policy without limitation or qualification. If you do not accept this Privacy Policy, you may not be able to use our Site, any of our products and services, or their full functionality.
Download our Privacy Policy here
In this Privacy Policy, 'personal information' has the meaning set out in the Privacy Act. In general terms, personal information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable. Personal information generally corresponds with 'personal data' as defined in the GDPR.
Some types of personal information are designated as 'sensitive information', which are subject to additional protection under the Privacy Act. Sensitive information generally corresponds with 'special category data' as defined in the GDPR.
When we refer to the collection, use, disclosure, storage and handling of personal information in this Privacy Policy, we mean any operation or set of operations that is performed on personal information, whether or not by automated means. This corresponds with 'processing' as defined in the GDPR.
The types of personal information we may collect about you include:
Generally, we will not collect sensitive information about you. However, in certain circumstances, we may need to collect limited sensitive information. For example, if you apply to become an employee of Vintrace, we may collect personal information about your membership with any political, professional or trade associations or unions, and procure police checks to confirm your criminal record.
We also collect technical information and general analytics, such as:
We may collect these types of personal information directly from you when you:
Where it is reasonable to do so, we will only collect personal information about you directly from you and not from third parties. In limited circumstances, we may collect personal information about you from third parties such as mutual contacts, or if someone makes contact with us on your behalf, or your referees provided through the recruitment process if you apply for a job with us.
We may use cookies on our Site from time to time to collect technical information and general analytics. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.
We may use web beacons on our Site from time to time to collect technical information and general analytics. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor visitors’ behaviour and collect data about how visitors use the web page. For example, web beacons can be used to count the number of users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
In general, we use your personal information for purposes connected with our business.
To the extent the GDPR applies, we will only use personal information about you if we have a legal basis to do so, for example:
Some of the specific purposes for which we may collect, hold, use and disclose personal information are as follows:
We may also use or disclose your personal information for other purposes you have consented to or as otherwise permitted or required by law. We may also use or disclose your personal information for other purposes to which you have consented, or as otherwise permitted or required by law.
Technical information and general analytics are used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are on the Site, and to improve the Site and Vintrace's products and services.
To the extent the GDPR applies, we do not envisage that any decisions will be taken about you using fully automated means; however, we will notify you in writing if this position changes.
We may disclose personal information to third parties in connection with the purposes described above. This may include disclosing your personal information to:
If we disclose your personal information to third parties, Vintrace will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for disclosure and in a manner consistent with applicable laws. For example (where commercially practical), by including suitable privacy and confidentiality clauses in our agreement with a third-party service provider to which we disclose your personal information.
To the extent the GDPR applies, the third party will only process your personal information following written instructions from us. We require that the third party either comply with the GDPR or another mechanism set out by applicable EU or Swiss data protection laws to transfer and process personal information.
Please note that we use the following third parties to process your personal data:
We may disclose your personal information to third parties outside Australia or the EU, such as third-party processors (for example, Xero, MailChimp or HubSpot).
Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Australian Privacy Principles stated in the Privacy Act in relation to such personal information.
To the extent the GDPR applies, we only disclose your personal information outside of the EU where the EU Commission has made an adequacy decision to ensure an adequate level of protection in that country, or where there are appropriate safeguards in place to protect your personal information.
Choice and consent: Please read this Privacy Policy carefully. You do not have to provide personal information to us; however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will handle it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. If you are unsatisfied with the outcome, we will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Our responsibilities as a ‘controller’ under the GDPR
Controllers are defined by the GDPR as natural or legal persons, a public authority, agency or other body to which personal information or personal information has been disclosed, whether via a third party or not, and who determines the purposes and means of processing personal information. We are a controller under the GDPR as we collect, use and store your personal information to enable us to provide you with our goods and/or services.
As a controller, we have certain obligations under the GDPR when collecting, storing and using the personal data of EU citizens. If you are an EU citizen, your personal information will:
Where appropriate, we also apply these principles to the way we collect, store and use the personal information of our Australian customers or clients.
Specifically, we have the following measures in place, in accordance with the GDPR:
Your rights and controlling your personal data
We are committed to ensuring that the personal information we collect is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We cannot guarantee the security of any information transmitted to or by us over the Internet. The transmission and exchange of data is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
Please notify Vintrace immediately if you become aware of any breach of security.
Where a breach of security gives rise to a 'data breach', being an incident when personal information, in any format, held by an agency or organisation is lost or subjected to unauthorised access, modification, disclosure or other misuse or interference, Vintrace will comply with its obligations under the Notifiable Data Breaches Scheme under the Privacy Act.
Generally, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy) unless an extended retention period is required by law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security.
Our Site may contain links to other websites. We do not have any control over those websites, and we are not responsible for the protection and privacy of any personal information you provide while visiting those websites. Those websites are not governed by this Privacy Policy.
Where applicable laws allow for an exemption to comply with certain legal obligations (for example, the employee records exemption under the Privacy Act in Australia), Vintrace may rely on such an exemption.
This Privacy Policy will not apply to the extent that it is inconsistent with any applicable law.
At any time and at our discretion, we may vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
Vintrace
Shop 5, 65 Little Oxford Street
Collingwood, Victoria, 3066, Australia
E: info@vintrace.com
P: +61 3 9015 9625
Last update: October 22 2021
The most common feedback we get from our new clients is, "Why didn't I start using vintrace years ago?".
Contact us and we'll arrange a live demonstration online or at your place of business.
Already use vintrace? Click here to get in touch.