1. Overview
2. What personal information do we collect?
3. How do we collect your personal information?
4. Why do we collect your personal information?
5. Who may we disclose your personal information to?
6. What if we can’t collect your personal information?
7. Marketing Communications
8. Data security
9. Access to and correction of personal information
10. GDPR
11. Other rights
12. Information retention
13. Additional services and links to other sites
14. Complaints
15. Cookies
16. Contact us

1. Overview

Metigy Pty Ltd ACN 617 973 270 and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)) (together referred to as Metigy, we, our, us), are committed to protecting your privacy.

This privacy policy (Privacy Policy) sets out how we handle your personal information. In particular, this Privacy Policy sets out how we will handle any personal information that is disclosed, collected or otherwise handled in connection with our engagement with and provision of services to you. This includes personal information disclosed to, collected by or otherwise used by the Metigy website: www.metigy.com (Website), the Metigy mobile app (App), or as may be processed through any other information technology platform we use to facilitate the provision of any or all of our products and services (Services).

This Privacy Policy should be read in conjunction with our Website terms and conditions available at https://metigy.com/terms-and-conditions/.

We suggest you read this Privacy Policy carefully, as it sets forth what personal information we collect, how and why we use it, and whom we share it with in relation to the Services. Additionally, this Privacy Policy sets out your rights in relation to your personal information and who to contact for more information or queries.

We regularly review our practices and procedures regarding how we collect, hold, use, disclose and otherwise manage personal information. As a result, this Privacy Policy may change from time to time and it is therefore important that you review it regularly. Any change to this Privacy Policy will become effective when we publish the revised Privacy Policy on our Website. You can check the effective date at the bottom of this page to see when the Privacy Policy was last updated. If we make any material changes to this Privacy Policy we will use reasonable endeavours to bring this to your attention when we do.

Your continued use of the Services, requesting our assistance or the provision of further personal information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.

2. What personal information do we collect?

Personal information means any information or an opinion about an individual from which that person can be identified or can reasonably be identified, whether true or not and whether recorded in a material form or not. We may collect and use different kinds of information in the course of providing the Services, and for you to be able to benefit from those Services (to the extent that it is reasonably necessary and relevant to the performance of the Services), which we have grouped together as follows:

• Contact information: includes your name, phone number, email address and your residential address or other address for both identification and registration purposes;
• Transaction information: includes details about payments from you and other details of products and services you have purchased from us, including payment information such as credit card details and billing addresses;
• Profile information: includes user generated information made available by social network services such as names, comments, posts, images or preferences, feedback and survey responses;
• Technical information: includes Metigy username and passwords, internet protocol (IP) address, your login data, browser type, time zone setting and location, third party access tokens and other technology on the devices you use to access the Website and/or the App;
• Usage information: includes information about the performance of the Website, App and Services, and how you use the Website, App and Services;
• Marketing information: includes your preferences in receiving marketing communications from us;
• Payment date: data necessary to process your payment if you pay for our Services, such as your payment instrument number (eg a credit card number), and the security code associated with your payment instrument. All payment data is stored by Chargebee and Stripe Payments;
• Required information: includes other personal information required to satisfy our obligations under relevant legislation; and
• any other personal information that you provide to us either directly or indirectly when using the Website.

The precise types of personal information we collect from or about you will depend on the nature of your interactions with us.

We do not collect any sensitive personal information about you (this includes details about your race or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices and criminal record information). Nor do we collect any information about your health, genetic background or biometric personal information.

Our services are not intended for use by children and should only be accessed by individuals of at least 18 years old (the Age Limit). If you are under the Age Limit, please do not use the Website and do not provide us your personal information. We will upon notice or discovery take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about those under the Age Limit without our knowledge.

3. How do we collect your personal information?

We may collect personal information directly from you wherever it is reasonable and practical to do so. We may collect personal information from you via:

• your use and access of the Website and the App, including during your registration and creation of an account as a user of the Website and/or the App;
• your response to any surveys or marketing materials we send out;
• information and recommendations uploaded to the Website and/or the App by yourself or by other users; and
• interactions between yourself, other users of the Website and/or the App, and our staff.

We may also collect your personal information from third parties including:

• third parties who provide services to Metigy that help us provide our services;
• other third parties who provide services via the Website; and
• via public sources or when you connect with a social network service or other platform when using and accessing the Website and/or the App.

4. Why do we collect your personal information?

We may collect, hold and use your personal information for a variety of reasons including in the most common circumstances listed below:

• to assess the performance of the Website, the App and the Services we provide, including in relation to data analysis, developing new products and services, managing the provision of our customer service, and analysing our customer base;
• to maintain system security and stability;
• to deliver targeted content based on user profiling and location;
• to process and respond to a complaint or request you may make, and to communicate with you and provide you with trouble-shooting support and customer service in general;
• to contact you in relation to our Services, particularly if we believe there are any products or services or any information we believe you might be interested in, as permitted by law;
• for the provision of Services or the administration of our business (including fulfilling and exercising our obligations and rights, exercising or defending legal claims and managing the relationship with you); or
• any other uses identified at the time of collecting your personal information.

The legal basis for collecting and using personal information will depend on the specific circumstances in which it is collected. However, we may collect personal information from you where:

• you have given consent for Metigy’s use of the personal information for one or more purposes;
• it is necessary for the performance of a contract to which you are party; or
• it is necessary for the legitimate interests pursued by Metigy and those interests are balanced against your rights to information privacy (e.g. to communicate useful content updates).

We will only collect, hold and use personal information for the purpose for which it was provided (which will normally be obvious at the time of collection), a related purpose, or as authorised, permitted or required by law.

5. Who may we disclose your personal information to?

We may disclose your personal information to various third parties. These third parties may include:

• technology partners in connection with our Services or services that these third parties perform for us;
• our lawyers, accountants and professional advisors;
• other third party service providers, such as third party branding service providers;
• to Metigy related companies that are either directly owned or controlled by Metigy;
• to law enforcement authorities where we are required to do so by law or pursuant to a legal process; or
• to any entity in the event that we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to require that the transferee uses the personal information you have provided to us in a manner that is consistent with this Privacy Policy.

Metigy may transfer your personal information to overseas countries in which we do business. Metigy may also subcontract certain activities and share your personal information with third parties located in countries outside of Australia. The countries in which these organisations are located will vary, but, in the course of our business operations, we generally disclose personal information to organisations located in Australia, the United States and Singapore. Such transfers are made in order to provide the Services and otherwise carry out the activities specified in this Privacy Policy.

6.What if we can’t collect your personal information?

If you do not provide us with the personal information we need, some or all of the following may occur:

• you may not be able to use some functions of the Website, the App or the Services; and
• we may not be able to provide you with other services, targeted content and relevant information.

7. Marketing Communications

In addition to the purposes set out above at section 4, we may collect, use and disclose your personal information to provide you with electronic marketing messages from time to time, to inform you of products, services or offers of Metigy, our related companies or commercial partners which may be of interest to you, either by notification via the App or email (Marketing Communications), in circumstances where we have collected the personal information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. 

You may receive Marketing Communications if:

• you have subscribed to our Marketing Communications (in which case we will keep you informed of the latest products, current offers and promotions at Metigy);
• you request information about our services when you choose to contact us (in which case you will not be added to a mailing list of any kind and will only receive emails in relation to the matter you have contacted us about); and
• the Marketing Communications are otherwise relevant to the reason(s) we hold your email address, where we are permitted to do so by law.

If you no longer wish to receive such material, you may opt out of receiving electronic messages from us at any time by contacting our Privacy Officer via the contact details at the bottom of this Privacy Policy or by using the opt out mechanism included in our electronic marketing messages.

8. Data security

We have put in place appropriate security measures to prevent your personal information from being accidently lost, used or accessed in an unauthorised way, altered or disclosed. In addition we limit access to your personal data to employees, agents, contractors and other third parties who have a business need for access. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Ultimately, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your personal information. You must take care to protect your personal information (for example, by protecting your usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.

9. Access to and correction of personal information

We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date. If you become aware of any errors in your personal information or, if you change your personal information, please let us know. If you have an account with us you can change your personal information details by logging into your account.

You can request access to any personal information we hold about you at any time. From time to time, we may need to reject your request to access personal information we hold about you, if we believe it to be necessary and to the extent allowed by law. To request access to any personal information that we may hold about you, please contact our Privacy Officer using the contact details at the bottom of this Privacy Policy. Depending on your request and where permitted by law, we may charge a small fee for complying with your request.

You may request us to amend any personal information we hold about you which you believe to be inaccurate, incomplete or out of date. To request an amendment to any personal information that we hold about you, please contact our Privacy Officer using the contact details at the bottom of this Privacy Policy. If we do not agree to amend your personal information, you may request that we make a note of your requested correction with the information we hold about you.

If we are unable to, or if we are unwilling to provide you with access to any of your personal information, or to correct any of your personal information, we will provide you with our reasons.

You may also contact our Privacy Officer using the contact details at the bottom of this Privacy Policy if you wish to obtain further information regarding our privacy practices and the way we handle your personal information.

For more information regarding privacy you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au or the appropriate data protection authorities in your jurisdiction.

10. GDPR 

If you are in the European Union (EU) (including the European Economic Area), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (GDPR). In providing our services to you, we may collect and process personal information as outlined in this Privacy Policy. Otherwise, including for individual users of our services, we will be a data controller for the purposes of the GDPR and this Privacy Policy includes information that must be provided to you when we collect your personal information.

You also have in certain circumstances the right to request that the personal information that is collected from you is erased, its further processing is restricted, or to object to its further processing and the right to data portability. You can also ask that personal information provided by you to us is transmitted to another party. You may also withdraw your consent where it has been provided as a condition of our processing your information or object to the further processing of your personal information in certain circumstances.

If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision. To make a request in respect of these rights or to make a complaint, please contact our Privacy Officer using the contact details at the bottom of this Privacy Policy. You also have the right to lodge a complaint with a relevant data protection supervisory authority (for example in the place you reside or where you believe we breached your rights).

11. Other rights

Subject to certain limitations and restrictions (e.g. depending on circumstances such as where you reside) you may have the right to exercise additional rights in relation to your personal information. These may include the right to:

• request erasure of your personal information;
• object to processing of your personal information;
• request restriction of processing of your personal information;
• transfer your personal information (i.e. the right to data portability);
• not be subject to automatic decision making; and
• withdraw consent.

If you wish to exercise or obtain details of any of the rights set out above, please contact our Privacy Officer via the contact details at the bottom of this Privacy Policy. The Privacy Officer may require further information in order to assess the applicability of the right to the relevant circumstances.

12. Information retention

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy and in each case in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods for taking legal action.

13. Additional services and links to other sites

From time to time, we may provide links or mechanics to interface with other websites for your information or convenience or offer additional services through separate websites linked to this Website and/or the App. These websites operate independently from our Website and App and may be subject to alternative terms of use, including terms concerning use of your personal information. We have not reviewed these third party sites and do not control and are not responsible for any of these websites, their content or their privacy policies. If you decide to access or interact with any of the third party sites listed on our Website or App, you do so at your own risk.

14. Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with our Privacy Officer using the contact details set out at the bottom of this Privacy Policy. Our Privacy Officer will confirm receipt of your complaint. If our Privacy Officer believes an investigation is necessary, we will open an investigation into your complaint. Our Privacy Officer may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, our Privacy Officer will contact you with the result of that complaint as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may be able to contact the Office of the Australian Information Commissioner at www.oaic.gov.au or the appropriate data protection authorities in your jurisdiction.

15. Cookies

Our website may use ‘cookies’ from time to time. Cookies could be used to collect personal information. A cookie is a small file that is stored on your device by a website. Cookies contain information which is readable by the website that issued the cookie to you and is commonly used to remember your details and preferences when you return to that website. Your web browser can be configured to reject cookies. If you set up your web browser to reject cookies certain functions of our Website may become unavailable to you.

We do not use browsing information to identify you personally. However, we may record information on how you use our Website or Services, including which pages you viewed, when you viewed them, whether you reached them via a search engine, and your computer’s assigned IP address.

16. Contact us

If you have any questions about this Privacy Policy, our privacy practices or if you would like to request access to or correction of any personal information we may hold about you, please contact our Privacy Officer:

14. Policy version