Privacy Policy

Bo Innovations Pty Ltd trading as Visuals2Go

1. We Respect Your Privacy

 

1.1. Bo Innovations Pty Ltd (Australian Company Number: 621 205 865) trading as Visuals2Go (“Visuals2Go”) respects your right to privacy and is committed to safeguarding the privacy of our customers and software application users. This policy outlines how we collect and manage your personal information.

1.2. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR) and the USA Children’s Online Privacy Protection Act (COPPA).

1.3. “Personal information” is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, photos, images or any other type of information that can reasonably identify an individual, either directly or indirectly. It excludes general, non-identifiable data.

2. Collection of Personal Information

 

Our Software Application

 

2.1. Visuals2Go does not collect personal information from users who download or subscribe to our software application, Visuals2Go (“APP”), via the Apple App Store. For both the free and subscription versions of our APP, users may use a pseudonym and are not required to provide any identity information to access the APP’s functions.

 

2.2. The subscriptions for our APP are managed by Apple. Due to its stringent privacy policy, Apple does not share user data with us. Consequently, we have no access to any specific user data and have no control over how Apple collects, uses and handles your personal information in relation to the subscription.

 

2.3. Visuals2Go only has access to holistic, non-identifiable data, which we may use to improve our services periodically.

 

2.4. Visuals2Go may display pop-up messages in the APP, inviting the users to register for our Free Webinar series. For registration, we may collect your email address, first name and occupation. Users may select to subscribe to our mailing list during registration. We need to send access to our webinars via the email address you provide. If you select to subscribe to our mailing list, we will also send you relevant promotional materials, including free tutorials on how to use our APP.

 

2.5. We do not target children under 13 for any of the webinars and promotions mentioned above.

 

Our Website

2.6. Visuals2Go may invite the users to register for our Free Webinar series, Free Training series and other promotional activities through our website. We also invite users to subscribe to our mailing list to receive news, tutorial materials and other promotion materials. We may collect personal information including your email address, first name, last name, location and occupation, as reasonably necessary for registration and subscription purposes.

 

2.7. Visuals2Go offers various paid plans and memberships for our advanced services. We may collect information reasonably necessary for processing payments for memberships or our advanced services, including but not limited to first name, last name, credit card information and billing details.

 

2.8. We do not target any children under 13 for any of the services mentioned above.

3. Non–solicited Personal Information

 

3.1 We may, from time to time, receive personal information you provide during electronic or in-person interactions, even though we do not actively request it. In such cases, we will destroy or de-identify this information as soon as practicable, if it is lawful and reasonable to do so. In any other case, we will protect it as outlined in this Privacy Policy.

3.2 Visuals2Go may, from time to time, receive personal information from third parties. In such instances, we will destroy or de-identify this information as soon as practicable, if it is lawful and reasonable to do so. In any other case, we will protect it as outlined in this Privacy Policy.

4. Use of Your Personal Information

 

4.1. Visuals2Go may use personal information collected from you to provide information, updates and our services. We may also inform you of new and additional products, services and opportunities available to you. We may use your personal information to enhance our products and services and better understand your needs.

4.2. Visuals2Go may present advertisements in the free version of the APP, ensuring they do not obstruct the users’ access to any functionalities. These advertisements are not targeted towards children under 13, and strategic measures are in place to prevent their integration into the core learning process. For example, we ensure that the advertisements only appear in settings and when users choose to print the cards. We will use our best endeavours to minimize the possibility for children under 13 to be exposed to the advertisements. For the subscription version of the APP, no advertisements are displayed.

4.3. In line with our commitment to providing you with choice and control over your personal information, you have the option to opt out of receiving direct marketing communications from us at any time. If you do not wish to receive such communications, you can unsubscribe by using the unsubscribe function within the electronic marketing material or by contacting us directly at info@visuals2go.com. We will ensure that your request is promptly processed and that you are not included in future direct marketing communications.

4.4. Visuals2Go has no control over the age of our users for both the APP and Website. While our intention is not to target children under 13 for our services, we acknowledge that children under 13 may inadvertently provide their personal information to us without parental consent. We will adopt reasonable steps to prevent children under 13 from providing their personal information. For example, we will ask the users to accept terms and conditions that they are over 13 when they attempt to register our webinars, subscribe to the email list and register our memberships either via the APP or the website.

 

4.5. Visuals2Go may invite you to follow our accounts on third-party social media through our website. If you interact with our accounts on third-party social media, we cannot ensure the security of any information you choose to make public in a social media feature. Also, we cannot ensure that parties who have access to such publicly available information will respect your privacy. Visuals2Go may contact you by a variety of measures including, but not limited to telephone, email, SMS or mail if we identify a risk to your privacy.

5. Disclosure, Transfer and Storage of Your Personal Information

 

5.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services. We will notify you if we need to disclose your personal information to third parties for a purpose that is not outlined in this privacy policy and will seek your consent in advance. We only share your personal information with third parties who have adequate privacy protections in place.

5.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, or warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

5.3. We may also use your personal information when necessary and reasonable to protect the copyright, trademarks, legal rights, property or safety of Visuals2Go, its APP, website and customers or third parties.

5.4. Information that we collect may from time to time be stored, processed by or transferred to parties located in countries outside of Australia. We currently only transfer your personal information to the USA to enable our data processor to manage our mail subscriptions. But we may engage other third parties located in countries other than the USA in the future.In situations where your information is to be shared with an overseas entity, we will seek your explicit consent, clearly specifying the nature of the information to be shared and the purposes for such transfer. You have the right to refuse consent to such a transfer. By providing your personal information to us, you acknowledge and consent to the disclosure of your information outside of Australia and understand that Visuals2Go cannot guarantee that overseas recipients of your information will always comply with Australian Privacy Principles. However, we will take all reasonable steps to ensure that your personal information is handled in a manner that is consistent with these Principles.

5.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

5.6. By providing us with personal information, you consent to the terms of this Privacy Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to the third parties mentioned above, we will request that the third party follow this Privacy Policy regarding handling your personal information, as well as compliance with applicable laws and regulations.

6. General Data Protection Regulation (GDPR) for the European Union (EU)

 

6.1. Visuals2Go will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

6.2. We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.

6.3. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.

6.4. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.

6.5. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.

6.6. We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.

6.7. We do not collect or process any personal information from you that is considered “Sensitive Personal Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin.

6.8. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children under 13.

7. Your Rights Under the GDPR

 

7.1. If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Visuals2Go complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.

 

7.2. Except as otherwise provided in the GDPR, you have the following rights:

(a) to be informed how your personal information is being used;

(b) access your personal information (we will provide you with a free copy of it);

(c) to correct your personal information if it is inaccurate or incomplete;

(d) to delete your personal information (also known as “the right to be forgotten”);

(e) to restrict processing of your personal information;

(f) to retain and reuse your personal information for your own purposes;

(g) to object to your personal information being used; and

(h) to object against automated decision making and profiling.

 

7.3. Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.

 

7.4. We may ask you to verify your identity before acting on any of your requests.

8. Hosting and International Data Transfers

 

8.1. Information that we collect may from time to time be stored, processed in or transferred to parties or sites located in countries outside of Australia. These may include but isnot limited to the USA. Our data processor who manages our mail list subscriptions is situated in USA. Transfers to other countries will be protected by appropriate safeguards.

9. Security of Your Personal Information

 

9.1. Visuals2Go is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

 

9.2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the US law and the Australian Privacy Principles. We take reasonable steps to ensure that the recipient has adequate technical measures in place to protect personal information against unauthorised use, loss and theft. We will assess the privacy laws of the countries where the data is being transferred, and where required, implementing contractual arrangements to ensure the protection of your personal information.

 

9.3. 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 the personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

10. Access to and Quality of Your Personal Information

 

10.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and, where applicable, the EU GDPR. To access your personal information, please email us at info@visuals2go.com. We will provide you with a copy of the information we hold about you in a timely manner, subject to any exceptions provided under applicable law.

 

10.2. In providing you with access to your personal information, we will take reasonable steps to verify your identity to ensure that personal information is provided only to the correct individual.

 

10.3 We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.However, we will always provide reasons for any refusal and information about our complaints process should you wish to challenge such a decision.

 

10.4 If you believe that any information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at info@visuals2go.com. We are committed to maintaining the accuracy, completeness, and currency of your personal information and will take reasonable steps to update or correct it promptly upon your request.

11. Complaints About Privacy

 

11.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to info@visuals2go.com. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

12. Changes to the Privacy Policy

 

12.1. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. We will notify you when we make significant changes via pop-up messages in the APP or email if you subscribe to our mailing list, and you may opt out of our services if you do not accept the terms of such updates.

13. Website

 

13.1. When you visit our website

When you come to our website (https://www.visuals2go.com), 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.

 

13.3. Cookies

We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third-party services such as Google AdWords. These ads may appear on this website or other websites you visit.

 

13.4. Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Visuals2Go is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

14. Sharing of Albums

14.1. Visuals2Go allows users to share images, albums and cards with other users. The sharing feature is a useful tool to transfer albums and cards to other users. However, if you are using the sharing feature to share your images please do so with the utmost care and diligence especially if it contains images of children under 13. All information that is shared is via Apple iCloud, which is encrypted, however sharing any images with other users using the Visuals2go application is at your own discretion and risk. We are not responsible for any information or images that are shared between users.

15.Children’s Online Privacy Protection Act (COPPA) and the United States (USA)

15.1.  Our product is designed and intended to support individuals with communication and learning difficulties, but we recognize that our users may include children under 13. We never knowingly collect, sell, share, or store individual child data either through the website or through our APP. We mean for adult users to download the software application and use our websites to support the actual learners. We only collect, store and use the personal information of the adult parents or guardians to provide our services. We suggest parents or guardians closely monitor the interactive activities of their children on our APP or website.

15.2. Visuals2Go have no control over the age of our users for both the APP and Website. While our intention is not to target children under 13 for our services, we acknowledge that children under 13 may inadvertently provide their personal information to us without parental consent. We will adopt reasonable steps to prevent children under 13 fromproviding their personal information. For example, we will ask the users to accept terms and conditions that they are over 13 when they attempt to register our webinars, subscribe to the email list and register our memberships either via the APP or the website.

15.3. Visuals2Go will notify the parent should we detect personal information of a child under 13, and destroy or de-identify the personal information received as soon as possible. If you become aware that a child under 13 is using our application without parental or legal guardian supervision and consent, please let us know by contacting us at https://www.visuals2go.com/contact-us/, so we can take appropriate action to notify the parent and destroy or de-identify the personal information received.

15.4. Visuals2Go may present advertisements in the free versions of the Application, ensuring they do not obstruct the user’s access to any functionalities. These advertisements are not targeted towards children under 13, and strategic measures are in place to prevent their integration into the core learning process. For example, we ensure that the advertisements only appear in settings and when users choose to print the cards. We will use our best endeavours to minimize the possibility for children under 13 to be exposed to the advertisements. For subscription versions of the software application, we do not display any advertisements.

15.5.  We will notify you if our approach is not to collect, sell, share, or store any personal data of children under 13 changes and obtain prior parental consent as required by relevant laws and regulations.

16. Data Breach Response

 

16.1. If personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and take all steps required by applicable laws and regulations.

16.2. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Data. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and engage in remedial measures.