Privacy Policy  

1. Overview 

Vygo Pty Ltd ACN 609 658 531 (collectively, Vygo, we, us, our) is committed to protecting  your privacy. We have prepared this Privacy Policy to describe to you our practices  regarding personal information we collect from users of our services, including the Vygo  app (App) and website (collectively, Platform), and all other services provided by Vygo (Services). If your institution has its own set of custom privacy notices then these will take  precedence. 

The processing of Personal Data shall always be in line with the Australian Privacy  Principles contained in the Privacy Act 1998 (Cth) (Privacy Act), the General Data  Protection Regulation (GDPR), and in accordance with country-specific data protection  regulations applicable to Vygo.  

We have implemented a number of technical and organisational measures to ensure the  most complete protection of Personal Data processed through the Services.  

2. User Consent 

Where we rely on your consent as the lawful basis to process your data under the GDPR we  will always ask for you to positively affirm your acceptance. By clicking to accept this Privacy  Policy you acknowledge and agree to be bound by this Privacy Policy. 

We note that all contact or other data forms where consent is required to be given by you  include no pre-checked checkboxes so that you are able to freely, affirmatively opt-in. We  will also provide you with notice on the Services specifically detailing what it is that you are  consenting to in clear and plain language as well ensuring that each matter that requires  consent is clearly distinguishable. 

For all areas of the Services where consent is given it is just as easily able to be withdrawn  through the appropriate account settings on the Services. 

If you believe that consent has not been given freely or in breach of the terms of this Privacy  Policy, please contact us. 

3. What personal data we collect 

We will only collect personal information from you if it is reasonably necessary for one or  more of our functions or activities. 

Personal Data means any information that allows someone to identify you, including, for  example, your name, address, telephone number, e-mail address, as well as any other non public information about you that is associated with or linked to any of the foregoing data. 

3.1 Information you provide to us 

(a) Account and User Content 

You need to create an account with us to use some of our Services. 

During your account registration and use of the Services, you may enter your details  on the different forms or provide us with additional content.  

We may collect this Personal Data from you, such as your name, e-mail, phone  number, identification number and mailing addresses, phone number, password,  university/institution and class records and other relevant details when you register to  use the Services. This data is used to enable us to identify and verify you and 

© Law Squared 2019 1 

provide you with support, services, mailings, sales and marketing actions, and  billings. Certain functionality of the Vygo Services requires your Personal Data to  function properly. 

When you create or share content, or upload content such as photos, videos,  comments, meta data (geographic tags) we may also collect this data.  

The legal basis for this processing is based on: 

− your consent through your voluntary submission of the form and agreeing to  these terms; 

− the Personal Data being necessary for the performance of a contract to which  you are a party;  

− for carrying out pre-contractual measures; and/or 

− any other legitimate interests as detailed below. 

(b) Payment Data 

When you make a purchase, we (or our third party service provider) will collect all  information necessary to complete the transaction, including your name, credit card  information, debit card information, billing information and/or Stripe information. 

The Personal Data we collect will be the data that you input in any payment area on  the Services. 

The legal basis for this processing is based on: 

− your consent through your voluntary submission of the form and agreeing to  these terms;  

− the Personal Data being necessary for the performance of a contract to which  you are a party including the payment of goods or services; and/or 

− any other legitimate interests as detailed below. 

This Personal Data is needed to enable us to process your payment for the goods or  services.  

(c) Contact and Messaging Data 

If you provide us with feedback or contact us via e-mail, or other means including by  phone call or by contracting with us, we will collect your name and e-mail address, as  well as any other content included in the e-mail or conversation, in order to send you  

a reply. If you contact or message another user through the Platform, we will also  collect this data. We will store and process your communications and information as  needed. We may also collect contact information if you choose to upload, sync or  import it from a device. 

The legal basis for this processing is based on: 

− either through your consent through your voluntary submission of the form and  agreeing to these terms or by your voluntary submission of data to us in other  means; 

− the Personal Data being necessary for the performance of a contract to which  you are a party;  

− for carrying out pre-contractual measures; and/or 

− any other legitimate interests as detailed below. 

By submitting a form or contacting us such Personal Data is transmitted on a  voluntary basis and you consent to its collection. 

(d) Subscription Data 

When you use the Services, you may have the ability to subscribe to various  newsletters or other forms. We may collect the data when you input your details for  subscription purposes. 

The Personal Data is processed for the purpose of informing you regularly by means  of a newsletter or other offer form. The personal information collected during the  subscription will only be used for marketing materials or for reasons made known on  the form. 

The legal basis for this processing is based on: 

− your consent through your voluntary submission of the form and agreeing to  these terms; and/or 

− any other legitimate interests as detailed below. 

By submitting the form and voluntarily providing us with your data, you are providing  consent to the use of such data by us. For the purpose of revocation of consent there  is a corresponding unsubscribe link found in each subscription email. Please review  the consent section above in this Privacy Policy for how we deal with consent. Where  we use your data for direct marketing, we will ensure that it is in compliance with  relevant laws. Where you are a customer of ours, we may be required to send you  emails for legitimate reasons including but not limited to billing, reminders and  account verification. 

We retain information on your behalf, such as domain names, URLs, time zone preferences,  Service invoices, transactional history, messages and any other information that you store  using your Account.  

We may also collect Personal Data at other points on our Services that state that Personal  Data is being collected. In some circumstances, Personal Data is provided to us by third  parties such as our related entities, service providers or other organisations conducting  activities on your behalf. With your expressed consent, your Personal Data may be used and  disclosed to us this way. The purposes as outlined above may include the processing of  such Personal Data to the extent necessary for us to comply with a law, regulation or legal  request or to protect the safety of any person or to prevent fraud. In certain jurisdictions, we  may ask for a government issued ID in limited circumstances including when setting up a  wireless account and activating your device, for the purpose of extending commercial credit,  managing reservations, or as required by law. 

3.2 Information we collect as you use our services  

(a) Meta Data including Location Data 

Some of our Services (including the App) may allow you to add or may have  metadata added to your content including hashtags (to mark keywords), geotags (to  mark your location), comments or other data. This helps our Services and your  content to be more searchable. We may also use such data to identify any breaches  of our Terms and Conditions or your institution's policies or codes of conduct.  

We use location data to help target and tailor the Services to your particular location  and jurisdiction and to ensure that users are meeting in places that comply with our  requirements and policies. With your consent we may also collect information about 

your precise location using methods including GPS, wireless networks, cell towers,  Wi-Fi access points and other sensors. 

(b) Log Data 

To make our Services more useful to you, our servers (which may be hosted by a  third-party service provider) gather some information automatically and store it in log  files. This information includes Internet Protocol (IP) addresses, browser type and  language, Internet service provider (ISP), referring and exit websites and  applications, operating system, date/time stamp, and clickstream data. 

We use this information to understand and analyse trends, to administer the  Services, to learn about user behaviour regarding the Services, to improve our  product and services, and to gather demographic information about our user base as  a whole. Vygo may use this information in our marketing and advertising services. 

In some of our email messages, we use a “click-through URL” linked to content on  our Services. When customers click one of these URLs, they pass through a  separate web server before arriving at the destination page on our website. We track  this click-through data to help us determine interest in particular topics and measure  the effectiveness of our customer communications. If you prefer not to be tracked in  this way, you should not click text or graphic links in the email messages. 

(c) Analytics 

We use third party analytics tools to collect information anonymously and report  Platform trends without identifying individual visitors. These tools collect information  sent by your device or our Services, including the web pages you visit, add-ons, and  other information that assists us in improving the Services. 

3.3 Information we collect from others 

(a) Data and content other people upload  

We may also collect information and communications that other people provide when  they use our Services. This can include information about you such as when others  send messages, documents and information to you. We may also collect your  information if you are invited to participate in our Services this may include  information such as your name, mailing address, phone number, email address,  contact preferences and is used for the purpose of enabling us to provide our  Services to you. 

We will only collect information about you directly from you, except where it is unreasonable  or impracticable to do so.  

4. How we use your Personal Data 

4.1 Use of personal information 

We will only use or disclose your personal information for the purposes for which we  advised you we were collecting it for as noted in this Privacy Policy and including to:  

− maintain your Account and contact details; 

− remember information so you don’t have to re-enter it during your visit or the next  time you visit the Service; 

− provide personalised content and information to you and others; 

− send marketing communication to you;

− conduct our business, generate content and provide customer support and  payment options (including updates and improvements); 

− administer contracts including to negotiate, execute and/or manage a contract  with you and your institution (if applicable);  

− communicate with you; 

− provide you with access to protected areas of the Platform or other Services; − conduct surveys to determine use and satisfaction; 

− detect, investigate and prevent potentially unlawful acts or omissions or acts or  omissions with the potential to breach our Terms and Conditions, this Privacy  Policy or any other policy; 

− enforce our Terms and Conditions, this Privacy Policy or any other policy; − verify information for accuracy or completeness; 

− comply with our legal obligations; 

− monitor metrics; 

− combine or aggregate your personal information with information we collect from  third parties and use it for the purposes set out in this Privacy Policy; 

− protect a person’s rights, property or safety; 

− process transactions to which you are a party; 

− resolve disputes and to identify, test and resolve problems; 

− improve our Services; and 

− any other purpose made known in this Privacy Policy or other policy. 

We agree to not use or disclose this information for a secondary purpose unless you  consent to us doing so, or another exception applies under applicable laws.  

For the purposes of the law, some information we hold about you may be considered 'sensitive' and therefore subject to greater protection. In the event that we hold  sensitive information about you, we will only disclose or use that information with  your consent or if another exception applies under applicable laws. 

We will also use or disclose your personal information or sensitive information if we  are required to do so by law or a court / tribunal order, or if we reasonably believe  that the use or disclosure of the information is reasonably necessary for an  enforcement related activity or on behalf of an enforcement body, in which case we  will make a written note of the use or disclosure or another exception applies under  relevant laws. 

4.2 Creation of anonymous data 

We also collect data in a form that does not, on its own, permit direct association with  any specific individual. We may collect, use, transfer, and disclose non-personal  information for any purpose.  

We may collect information regarding customer activities on our Services including  the Platform. This information is aggregated and used to help us provide more useful  information to our customers and to understand which parts of our Platform,  products, and Services are of most interest. Aggregated data is considered non personal information for the purposes of this Privacy Policy.

5. Disclosure of your Personal Data 

We may disclose your Personal Data to third parties for the purposes contained in this  Privacy Policy, including without limitation to:  

(a) Universities and other institution partners 

We may share some or all of your Personal Data with your university or other  institution subject to obligations consistent with this Privacy Policy and any other  appropriate confidentiality and security measures. 

(b) Intercom 

We use third-party analytics services to help understand your usage of our services.  In particular, we provide a limited amount of your information (such as sign-up date  and some personal information like your email address) to Intercom, Inc. (Intercom)  and utilize Intercom to collect data for analytics purposes when you use the Platform.  

As a data processor acting on our behalf, Intercom analyses your use of the Platform  and tracks our relationship by way of cookies and similar technologies so that we can  improve our service to you.  

For more information on Intercom's use of cookies, please  

visit https://www.intercom.com/terms-and-policies#cookie-policy.  

We may also use Intercom as a medium for communications, either through email, or  through messages within the Platform. The Intercom Messenger Apps and Apps in  Inbox products may also provide you with access to other third party applications  such as Stripe. You should consult these third parties' privacy notices for further  information on their use of your personal data. As part of our service agreements,  Intercom collects publicly available contact and social information related to you,  such as your email address, gender, company, job title, photos, website URLs, social  network handles and physical addresses, to enhance your user experience. For more  information on the privacy practices of Intercom, please  

visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are  governed by Intercom’s terms of use which can be found  

at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of  having this information collected by or submitted to Intercom, please contact us. 

(c) Service Providers 

We may share your Personal Data with services providers to:  

− provide you with the Services that we offer you including the Platform; − to conduct quality assurance testing;  

− to facilitate creation of accounts; 

− to provide technical support;  

− and/or to provide other services to Vygo. 

The service providers (and if necessary, data processors) include:  

− information technology service providers such as web host providers and  analytical providers; 

− mailing houses; 

− advertising partners;

− market research organisations to enable them to measure the effectiveness of  our advertising and business impact; and 

− specialist consultants. 

These third party service providers are required not to use your Personal Data other  than to provide the services requested by Vygo.  

(d) Affiliates and Acquisitions  

We may share some or all of your Personal Data with our parent company,  subsidiaries, joint ventures, or other companies under a common control (Affiliates),  in which case we will require our Affiliates to honour this Privacy Policy. In the event  we are involved in a merger, acquisition or sale of assets we may disclose Personal  Data collected by us to such entities that we propose to merge with or be acquired by  and will assume the rights and obligations regarding your Personal Data as  described in this Privacy Policy. This includes the disclosure of information to our  clients where we act as a data processor. 

(e) Third parties including those you choose to share your data with 

We may disclose your Personal Data to third parties to whom you expressly ask to us  to send the Personal Data to or to third parties you choose to send your Personal  Data to.  

We may also, with your consent or at your direction, disclose your personal  information to your authorised representatives. 

(f) Other disclosures  

Regardless of any choices you make regarding your Personal Data (as described  below), Vygo may disclose Personal Data if it believes in good faith that such  disclosure is necessary: 

(i) in connection with any legal investigation; 

(ii) to comply with relevant laws, regulations, enforceable governmental  requests or to respond to subpoenas or warrants served on Vygo; 

(iii) to protect or defend the rights or property of Vygo or users of the  Services;  

(iv) to investigate or assist in preventing any violation or potential violation of  the law, this Privacy Policy, or our Terms and Conditions;  

(v) to protect the safety of any person or to protect the safety or integrity of  our platform including for security reasons;  

(vi) detect, prevent or otherwise address fraud, security or technical issues. 

We may share your Personal Data with such third parties subject to obligations  consistent with this Privacy Policy and any other appropriate confidentiality and  security measures, and on the condition that the third parties use your Personal Data  only on our behalf and pursuant to our instructions. 

We will take reasonable steps to ensure that anyone to whom we disclose your  personal information respects the confidentiality of the information and abides by the  Privacy Act, the GDPR or equivalent privacy laws.

We will not share, sell, rent or disclose your personal information in ways different  from what is disclosed in this Privacy Policy. 

Where we act as a data processor the client may also provide us with instructions  with regards to disclosure. 

6. If we can't collect your data 

If you do not provide us with the personal information described above, some or all of  the following may happen: 

− we may not be able to provide the requested products or services to you, either to  the same standard or at all; 

− we may not be able to run the competitions and promotions in a way that benefits  you; 

− we may not be able to provide you with information about products and services  that you may want; or 

− we may be unable to tailor the content of our Services to your preferences and  your experience of our Services may not be as enjoyable or useful. 

7. Cookies Policy 

7.1 What are cookies?  

A cookie is a small piece of text sent to your browser by a website that you visit. It  helps the website to remember information about your visit, like your preferred  language and other settings. That can make your next visit easier and the site more  useful to you. Cookies play an important role. Without them, using the web would be  a much more frustrating experience. 

7.2 Use of cookies 

Vygo’s Services including websites, online services, interactive applications, email  messages, and advertisements may use “cookies” and other technologies such as  pixel tags and web beacons. These technologies help us better understand user  behaviour, tell us which parts of our applications people have visited, and facilitate  and measure the effectiveness of advertisements and web searches.  

We treat information collected by cookies and other technologies as non-personal  information. However, to the extent that Internet Protocol addresses or similar  identifiers are considered personal information by local law, we also treat these  identifiers as personal information. Similarly, to the extent that non-personal  information is combined with personal information, we treat the combined information  as personal information for the purposes of this Privacy Policy. 

Vygo and our partners also use cookies and other technologies to remember personal information when you use our Services. Our goal in these cases is to make  your experience with Vygo more convenient and personal. For example, knowing  your first name lets us welcome you the next time you visit the Vygo platform.  Knowing someone using your computer or device has shopped for a certain product  or used a particular service helps us make our advertising and email communications  more relevant to your interests. And knowing your contact information, hardware  identifiers, and information about your computer or device helps us personalize your  operating system and provide you with better customer service.

Pixel tags enable us to send email messages in a format customers can read, and  they tell us whether mail has been opened. We may use this information to reduce or  eliminate messages sent to customers. 

7.3 How to manage cookies 

Some people prefer not to allow cookies, which is why most browsers give you the  ability to manage cookies to suit you. If you want to disable cookies and you’re using  the Safari web browser, go to Safari preferences and then to the privacy pane to  manage your preferences. For other browsers, check with your provider to find out  how to disable cookies. Please note that certain features of the Vygo Services will  not be available once cookies are disabled. 

8. Third party websites 

When you click on a link to any other website or location, you will leave our website and go  to another site and another entity may collect Personal Data or Anonymous Data from you.  We have no control over, do not review, and cannot be responsible for, these outside  websites or their content. Please be aware that the terms of this Privacy Policy do not apply  to these outside websites or content, or to any collection of data after you click on links to  such outside websites. 

9. Managing your Personal Data 

Subject to the Privacy Act and the GDPR you may request to access the personal  information we hold about you by contacting us. All requests for access will be processed  within a reasonable time. 

(a) Accessing or rectifying your Personal Data 

We may, if required, provide you with tools and account settings to access, correct,  delete, or modify the Personal Data you provided to us. You can find out more about  how to do this by contacting us. In the event that you are unable to access your  Account to access or rectify your Personal Data, you may submit a request to us to  correct, delete or modify your Personal Data and download the data for you. 

(b) Deletion 

We keep data for as long as it is needed for our operations. If you deactivate and  delete your Account, your data will no longer be visible on your Account. Please keep  in mind that third parties, including your institution, may still retain copies of  information you have made public through our Services or which we have shared  with them in accordance with this Privacy Policy. 

If you wish to have us delete your data, please contact us.  

(c) Object, restrict or withdraw consent 

If you have an Account on the Services, including the Platform, you will be able to  view and manage your privacy settings. Alternatively, if you do not have an Account,  you may manually submit a request to us if you object to any Personal Data being  stored, or if you wish to restrict or withdraw any consent given for the collection of  your Personal Data. 

You may withdraw your consent to the processing of all your Personal Data at any  time. If you wish to exercise this right, you may do so by contacting us.

You may withdraw your consent or manage your opt-ins by either viewing your  account on the Services or clicking the unsubscribe link at the bottom of any  marketing materials we send you. 

(d) Portability 

We may, if required and possible, provide you with the means to download the  information you have shared through our services. Please contact us for further  information on how this can be arranged. 

In certain instances, we may not be required or able to provide you with access to your  personal information. If this occurs, we will give you reasons for our decision not to provide  you with such access to your personal information in accordance with the Privacy Act and  the GDPR. 

There is no application fee for making a request to access your personal information.  However, we may charge an administrative fee for the provision of information in certain  circumstances such as if you make repeated requests for information or where the  information is held by a third party provider. 

Where we act as a data processor, we do so on behalf of our client and in accordance with  their instructions. This means that should you wish to access, review, correct, transfer,  modify or delete any Personal Data we process on behalf of a client you should contact the  client with your request. 

10. Direct marketing materials 

We may send you direct marketing communications and information about our products and  services that we consider may be of interest to you. These communications may be sent in  various forms, including mail, SMS, fax and email, in accordance with applicable marketing  laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of  communication, we will endeavour to use that method whenever practical to do so. In  addition, at any time you may opt-out of receiving marketing communications from us by  contacting us (see the details below) or by using opt-out facilities provided in the marketing  communications and we will then ensure that your name is removed from our mailing list.  

11. Storage and Security of Your Personal Data 

Vygo stores personal data in Google Firebase. 

Vygo takes the security of your personal information very seriously. We will take all steps  reasonable under the circumstances to protect your personal information from misuse,  interference, loss; and unauthorised access, modification or disclosure. We will process  Personal Data securely and apply and maintain appropriate technical and organisational  measure to protect Personal Data.  

The transmission and exchange of information is carried out at your own risk. We cannot  guarantee the security of any information that you transmit to us or receive from us. Although  we take measures to safeguard against unauthorised disclosures of information, we cannot  assure you that personal information that we collect will not be disclosed in a manner that is  inconsistent with this Privacy Policy. 

12. International Transfer and Disclosure of Personal Data 

Where we are required to use suppliers outside of Australia, we ensure that all our suppliers  are required to adhere to the Australian Privacy Principles in the Privacy Act. 

Where we transfer Personal Data from within to outside of the European Union or EFTA  States, we ensure an adequate level of protection for the rights of data subjects based on  the adequacy of the receiving country’s data protection laws. 

We may disclose personal information to our related bodies corporate and third party  suppliers and service providers located overseas for some of the purposes listed above. We  take reasonable steps to ensure that the overseas recipients of your personal information do  not breach the privacy obligations relating to your personal information. 

We may disclose your personal information to entities located outside of Australia, including  the following: 

− our related bodies corporate; 

− our data hosting and other IT service providers, located in various countries; and − other third parties located in various foreign countries. 

We may disclose your personal information to entities within Australia who may store or  process your data overseas. 

13. Notifiable Data Breaches 

We take data breaches very seriously. Depending on where you reside our policy is: 

(a) If you reside in Australia 

In the event that there is a data breach and we are required to comply with the  notification of eligible data breaches provisions in Part IIIC of the Privacy Act or any  other subsequent sections or legislation which supersede this Part IIIC, we will take  all reasonable steps to contain the suspected or known breach where possible and  follow the following process set out in this clause.  

We will take immediate steps to limit any further access or distribution where  possible. If we have reasonable grounds to suspect that the data breach is likely to  result in serious harm to any individuals involved, then we will take all reasonable  steps to ensure an assessment is completed within 30 days of the breach or sooner if  possible. We will follow the guide published by the Office of the Australian  Information Commissioner (if any) in making this assessment.  

If we reasonably determine that the data breach is not likely to result in serious harm  to any individuals involved or any remedial action, we take is successful in making  serious harm no longer likely, then no notification or statement will be made.  

Where, following an assessment and undertaking remedial action (if any), we still  have reasonable grounds to believe serious harm is likely, as soon as practicable, we  will provide a statement to each of the individuals whose data was breached or who  are at risk. The statement will contain details of the breach and recommendations of  the steps each individual should take. We will also provide a copy of the statement to  the Office of the Australian Information Commissioner. 

(b) If you reside in the European Union of EFTA States:  

We will endeavour to meet the 72-hour deadline as imposed by the GDPR, to report  any data breach to the supervisory authority where a data breach occurs that will  likely be a risk to you. 

Further, where there is likely to be a high risk to your rights, we will endeavour to  contact you without undue delay.  

We will review every incident and take action to prevent future breaches.

14. Automated individual decision-making, including profiling 

If you reside in the European Union or EFTA States, you shall have the right not to be  subject to a decision based solely on automated processing, including profiling, which  produces legal effects concerning you, or similarly significantly affects you, as long as the  decision is not necessary for entering into, or the performance of, a contract between us, or  is not authorized by Union or Member State law to which we are subject and which also lays  down suitable measures to safeguard your rights and freedoms and legitimate interests, or is  not based on your explicit consent. If you wish to exercise your rights, please contact us. 

15. Integrity and Retention of Data 

We take all reasonable steps to ensure that the personal information we collect about you is  accurate, up to date and complete. Where we collect that information from you directly, we  rely on you to supply accurate information. Vygo makes it easy for you to keep your personal  information accurate, complete, and up to date. Where we use or disclose your personal  information, we will also ensure that your personal information is relevant. We will retain your  personal information for the period necessary to fulfil the purposes outlined in this Privacy  Policy unless a longer retention period is required or permitted by law. 

We may retain your information for fraud prevention or similar purposes.  16. Contact Information 

Vygo welcomes your comments or questions regarding this Privacy Policy.  

If you have a question regarding this Privacy Policy or you would like to make a complaint,  please contact us by email by using our contact details on the Services or below. 

16.1 If you reside in Australia 

You can confidentially contact our Privacy Officer at: 

Privacy Officer Steven Hastie 

Entity Vygo Pty Ltd CAN 609 658 531 

Telephone (+617) 3250 6800 

Email team@vygoapp.com 

Office Address Level 3, 32 Duncan Street, Fortitude Valley QLD 4006 Postal Address As above 

Website vygoapp.com 

If we do not resolve your enquiry, concern or complaint to your satisfaction or you  require further information in relation to any privacy matters, please contact the Office  of the Australian Information Commission at: 

Telephone: 1300 363 992 

Email: enquiries@oaic.gov.au 

Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000 

Postal Address: GPO Box 5218, Sydney NSW 2001 

website: www.oaic.gov.au

16.2 If you reside in the European Union of EFTA States:  

The data controller that is responsible for your Personal Data is: 

Vygo Pty Ltd CAN 609 658 531 

Level 3, TCB Building, 315 Brunswick St, Fortitude Valley QLD 4006 

If you wish to raise a concern about our use of your information you have the right to  do so with your local supervisory authority.  

17. Changes to this Privacy Policy 

This Privacy Policy is subject to occasional revision and Vygo reserves the right, at its sole  discretion, to modify or replace any part of this Agreement. It is your responsibility to check  this Privacy Policy periodically for changes. Continued use of our Services including the  Platform shall indicate your acknowledgement of that it is your responsibility to review the  Privacy Policy periodically and become aware of any modifications. We may amend this  policy from time to time. Not all changes to our privacy policy will require your consent, for  example where office security procedures are changed. We will notify you of any change to  our information handling policy that requires your consent before being implemented.