September 9, 2018

Privacy Policy

Last modified: 4th June 2022

This Privacy Policy relates to GhostTube Pty Ltd ACN 649 627 083.  In this Privacy Policy, ‘us‘, ‘we‘ and ‘our‘ means GhostTube Pty Ltd ACN 649 627 083.

We are committed to protecting your privacy and dealing with your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Australian Privacy Act 1988 (Privacy Act).  This Privacy Policy outlines how we will collect, hold, use and disclose personal information of individuals.  By providing us with your personal information you consent to us handling it in accordance with this Privacy Policy.

This Privacy Policy explains:

  • what personal information we collect from you
  • the purposes for which your personal information is collected
  • how we collect and store your personal information
  • how we use your personal information
  • when and to whom will we disclose your personal information
  • your right to access and correct the personal information that we hold about you
  • your right to have your privacy complaints investigated and resolved
  • your right to have your personal information protected from misuse or unauthorised access

In the event of an inconsistency between the Privacy Act or the APPs and our Privacy Policy the Privacy Act and the APPs will prevail.

This Privacy Policy applies to individuals, which means natural persons.

Types of personal information we collect

The personal information that we collect, and may hold, about you will depend on the circumstances and relationship between you and us and how you use our applications and websites (Platforms).  The kinds of personal information about you that we may handle include:

  • your personal details and identity information, including your name, e-mail address, and location information
  • your product and service information, including your purchase history with us
  • any personal information you may incidently disclose the content you choose to create or share on our Platforms (user generated content)

If you choose to provide other sensitive information, such as your religious or philosophical beliefs, political views, criminal record, sexual preferences or health information, in the content you create or share on our Platforms then you consent to our collection of this sensitive information.

We do not listen to, view, collect or store any audio or video captured using our Platforms unless you choose to share it with other users on those Platforms.  You can capture audio and video solely for your own use without sharing it and these recordings will remain on your local device only.

We will destroy or de-identify unsolicited personal information we receive unless we determine that it is information we could have solicited ourselves (or you advise we may hold it).  If this is the case the personal information will be stored and managed in compliance with the remainder of this Privacy Policy.

Note that GhostTube SLS captures depth information from your phone’s LiDAR sensors and Apple’s TrueDepth API for the purpose of providing depth-based video filters. These filters can be used to customise your videos and are useful for seeing objects in the dark. Although this technology is used in facial recognition, we do not use this information for facial profiling of any kind. The data is only used at runtime to generate the personalised video filters – It is not shared or uploaded to GhostTube’s servers or any of our affiliates or third parties.

Purposes for our collection of personal information

We collect personal information for the primary purpose of delivering services via our Platforms.  We collect and use your personal information to provide our services or information you request, to communicate with you, to facilitate and enhance your use of our Platforms, evaluate and improve our Platforms and to market or promote our Platforms, services and functions.  We also collect and use your personal information for other purposes to which you have consented, complying with our legal or regulatory obligations and as otherwise authorised or required by law.

If we are not provided with the personal information about you which we request then we may not be able to provide you with our services, provide you with information you have requested or effectively communicate with you.  Also, you may not be able to effectively use our Platforms.

Kinds of electronic information we collect

We also collect and hold information about visitors to our websites and users of our applications using a range of third party tools including cookies and session tools.  For example, we may collect your IP address, device ID, operating system, browser type, pages accessed on our websites, documents downloaded on our websites, previous visits, referring website and visit date and time.

We collect and hold this information for the purpose of maintaining and improving our Platforms and enhancing your experience browsing our websites and using our applications.  You may set your browser to disable cookies but some parts of our website may not function properly if cookies are disabled. 

How we collect and store your personal information

We collect information you voluntarily provide to us, when you create an account on our Platforms, complete an on-line application or form, send us an email, send us information by post or post information to our Platforms.  If you log in to our Platforms using your log-in details for another platform or online services (such as with Facebook or AppleID) we may collect this information.  We may also collect information from you if you make an enquiry about our services, complete a survey or subscribe to receive information from us.

We collect information about a person as much as possible from the person.  However, where an individual is under the age of 18 information may be obtained from parents or guardians or where an individual has a disability which limits his or her capacity to provide information it may be collected from responsible persons or agencies legally able to provide such information.

We will provide the option of not identifying yourself, or of using a pseudonym, unless impracticable to do so or we are required to verify your identity or age in order to deliver our services to you.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, up to date and complete.  One way we do this is by collecting information about a person as much as possible from the person.  We also need you to be proactive and advise us promptly of any changes to your personal information.

We will take reasonable steps to protect the information from misuse, interference, loss, unauthorised access, modification or unauthorised disclosure using various security measures which include access restrictions, secure databases, password access, anti-virus software and data encryption.

If we hold any personal information that we no longer need for any of our purposes then we will take reasonable steps to destroy or de-identify the information unless we are required by law to retain the information.

How we use your personal information

By providing us with your personal information you consent to us using and disclosing it for the purpose of delivering our services to you, providing you with information about our services, functions and activities, sending you marketing or promotional material, communicating with you and personalising your experiences with us.

We will describe how you may at any time request not to receive any further communications from us.  We will give effect to your request not to receive any further such communications from us as soon as practicable.

Direct Marketing

We may, within reasonable expectations or with your consent, also use your personal information so we can provide you with direct marketing information which may be of interest to you. We will not disclose that information to others unless you have consented, or we are required to disclose it by law.

The provider through which you access our Platforms, such as Apple Inc or Google LLC, may use cookies and third party tracking to advertise, make recommendations and promote goods and services to you.  These activities are governed by the terms and conditions and privacy policies of those providers.

We will give you the opportunity not to receive this marketing information when we collect your details or on occasions when we send such material to you. We continue to be bound by the SPAM Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) when we undertake direct marketing and we comply with the provisions of these Acts.

When and to whom will we disclose your personal information

We may disclose your personal information to our service providers and third parties that assist us to carry out our functions and activities and deliver our services. Information about the organisations to whom we make such disclosures can be obtained from our Privacy Officer at support@ghosttube.com.

These third parties to which we may disclose your personal information may be located in Australia or other countries such as the United States of America.  We will only disclose personal information to a third party who is not in Australia if we reasonably believe that the recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the APPs protect the information and there are mechanisms which the individual can access to take action to enforce that protection of the law or binding scheme.

We will only share the personal information we collect from you with third parties as described in this Privacy Policy, with your consent or where authorised or required by law.  For example, we will not sell, trade or rent your personal information to any third party for marketing purposes without your consent.

Updates to our Privacy Policy

We may update our Privacy Policy from time to time to take into account changes in our information handling practices by publishing an updated version of our Privacy Policy on our Platforms.  You should regularly review the most recent version of our Privacy Policy available on our Platforms.

Your right of access to your personal information

To request access to or correction of your personal information, please contact our Privacy Officer at support@ghosttube.com. Proof of identity will be required.

In some circumstances, if specified in the APPs, we may not be required to give access to personal information.  For example, access may be refused where it would have an unreasonable impact on the privacy of others, threaten the health or welfare of anyone or we are required or permitted by law to withhold the information.  If we decide not to give you access to your personal information then we will give you written reasons for our decision.

Your right to have your privacy complaints investigated and resolved

We strive to meet or exceed the highest standards to protect your privacy. Please contact us at support@ghosttube.com if you have an enquiry or complaint about our handling of your personal information. Any complaint must be made in writing. We will treat privacy complaints with the highest priority and we commit to respond to any such complaint within 28 business days.

If you are not satisfied with our response to your complaint then you may take your complaint to the Office of the Australian Information Commissioner which may be contacted using the following contact details:

 

Office of the Australian Information Commissioner

Phone:             1300 363 992

Address:          GPO Box 5218, Sydney, NSW 2001

Online:            online privacy complaint form