This policy explains how and why we collect, use, hold and disclose your personal information and how we comply with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) (Privacy Act) and the Australian Privacy Principles (APPs).

“We”, “us” and “our” means We Do Virtual Assistants Pty Ltd ACN 674 378 726 of 18 Salisbury St, WERRIBEE VIC 3030 (WDVA).

You acknowledge and consent to us collecting, holding, using and disclosing your personal information in accordance with this policy or as otherwise permitted under the Privacy Act or other law.

1. WHAT IS PERSONAL INFORMATION?
   Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
   
   
2. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
   We collect information about you and your interactions with us, for example, when you use any of our services, call us or otherwise visit our website. The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services
   and details of enquiries or complaints you make.
   
   We may collect information about how you access, use and interact with the website. This information may include:
   
   (a) the location from which you have come to the site and the pages you have visited; and
   
   (b) technical data, which may include IP address, the types of devices you are using to access the, device attributes, browser type, language and operating system.
   
   We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.
   
   
3. WHY DO WE COLLECT, HOLD AND USE YOUR PERSONAL INFORMATION?
   We collect, hold and use your personal information so that we can:
   
   (a) provide you with services, and manage our relationship with you;
   
   (b) contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
   
   (c) comply with our legal obligations and assist government and law enforcement agencies or regulators; or
   
   (d) identify and tell you about other services that we think may be of interest to you.
   
   If you do not provide us with your personal information or if you do not wish for your personal information to be collected and used in a way contemplated by this policy, we may not be able to provide our services to you, communicate with you or respond to your enquiries.
   
   
4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
   (a) We will collect personal information directly from individuals whenever they interact with us.
   
   (b) We also collect personal information:
   
   (i) from you, our clients when we provide services to you. This includes personal information about your customers and clients (Your Clients);
   (ii) via a file-sharing arrangement with a client and when a client provides access to their customer relationship management (CRM) and software systems and third-party websites to enable us to provide services;
   (iii) when sent to us by email or other communication from third parties;
   (iv) from publicly available sources of information;
   (v) when we are required to do so by law; and
   (vi) from our own records.
   
   
5. CONSIDERATIONS WHEN YOU SEND INFORMATION TO US
   (a) If you provide us with the personal information of another person (including Your Clients):
   (i) you must disclose to that person that you are providing personal information (including sensitive information) to us and that the information may be disclosed off-shore in accordance with the terms of this policy;
   (ii) you must ensure that you are authorised to disclose that personal information to us and that the relevant person has consented to the disclosure to us; and
   (iii) we accept that personal information on the basis set out above.
   
   (b) While we do all we can to protect your privacy and the privacy of Your Clients, including investing in specialist security software, no data transfer over the internet is 100% secure.
   
   (c) If you or Your Clients provide personal information to us electronically, there are ways you and Your Clients can help maintain the security of the information. These include:

(i) always close your browser when you have finished your user session;
(ii) do not provide personal information by using a public computer;
(iii) never disclosing your user name and password to another person; and
(iv) not sending information to WDVA or our personnel and team members email or other web-based mail accounts, or any other means of transferring client informationother than through file-sharing applications specifically provided and approved by WDVA.

(d) You are responsible for all actions taken using your username, email or password. If at any time you believe your username or password has been compromised, change your password and contact us immediately.

(e) If we suspect that there is a data breach leading to the protection of personal information stored or held by us being compromised, we will implement a data breach response plan, which will include:
(i) notifying you and Your Clients that may be affected by such a breach;
(ii) if necessary, notifying the relevant regulatory authorities of a suspected breach, which may include the Office of the Australian Information Commissioner (OAIC); and
(iii) undertaking appropriate remedial action, depending on the type, amount and nature of the personal information that is at risk.

6. HOW DO WE STORE AND HOLD PERSONAL INFORMATION?
   (b) We may hold your information in either electronic or hard copy form.
   
   (c) We store most information about you in computer systems and databases operated by either us, our related entities or our external service providers.
   
   (d) We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure. These processes and systems include:
   
   (i) the use of identity and access management technologies to control access to systems on which information is processed and stored;
   (ii) requiring all employees to comply with internal information security policies and keep information secure;
   (iii) requiring all employees to complete training about information security; and
   (iv) monitoring and regularly reviewing our practise against our own policies and against industry best practice.
   
   (e) We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs. We may, however, retain personal information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes.
   
   (a) The transmission of data and information via the internet is not completely secure. Although, we take steps to protect your data and information, we are not always able to provide a guarantee in relation to the security of your data and information transmitted to us. As such, to the extent permissible by law and subject to our obligations under the Privacy Act, we will not be liable for any claim or loss arising from security of data and information sent and received from us over the internet or for any unauthorised access or interception of that data and information and any transmission is at your own risk.

7. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION, AND WHY?
   We may transfer or disclose your personal information in certain circumstances including:
   
   (a) to third parties including service providers who assist us in operating our business and providing our services and those service providers of yours that you require us to work with;
   
   (b) to our personnel and our related companies;
   
   (c) using it for the purposes for which we collected it (eg. to provide our services or respond to a query);
   
   (d) where we are required or authorised by law to do so;
   
   (e) where you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
   
   (f) where we are otherwise permitted to disclose the information under the Privacy Act.
   
   If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.
   
   
8. DO WE DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
   (a) We may disclose your personal information to recipients which are located outside Australia.
   
   (b) We provide services to you and Your Clients under our Services Agreement. These services are performed by our related party company incorporated in the Philippines, Virtual Assistant Broker Solutions OPC.
   
   (c) To provide our services we, including Virtual Assistant Broker Solutions OPC, receive personal information from you about Your Clients. This may include sensitive information.
   
   (d) We have security processes in place for the protection of that personal information, including supervising staff, security software, disabling USBs, staff training and use of password protection.

9. DO WE USE YOUR PERSONAL INFORMATION FOR MARKETING?
   (a) We may use your personal information to offer you services we believe may interest you, but we will not do so if you tell us not to. These services may be offered by us, our related companies, our other business partners or our service providers.
   
   (b) If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, email admin@wedovas.com.au and we will remove your details from our marketing database.
   
   (c) We do not use personal information of Your Clients for marketing purposes.
   
   
10. ACCESS TO AND CORRECTION OF YOUR PERSONAL INFORMATION
    (a) You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.
    
    (b) There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
    
    (c) We will respond to your requests to access or correct personal information in a reasonable time and an appointment will be made if necessary for clarification purposes.
    
    (d) You or Your Clients should also contact us immediately if someone has gained access to you or Your Client’s personal information or You or Your Clients would like to discuss any issues about our privacy policy.
    
    
11. COMPLAINTS
    (a) If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us.
    
    Our contact details are set out below.
    
    (b) We endeavour to ensure that any complaints about privacy issues will be dealt with efficiently, seriously and confidentially. We will investigate your complaint, having regard to the information you have provided us and any other information which may be available, that could assist us in investigating your complaint, including requesting further information from
    you.
    
    (c) We will notify you of the outcome of our investigation and any subsequent internal investigation and any actions we may have taken or propose to take with respect to your complaint.
    
    (d) If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
    
    (e) To the extent permitted by law, we will not be liable to you or to any third party for any loss (including but not limited to consequential loss or loss of profits) or claim arising from our collection, disclosure, management and use of personal information in accordance with this policy. Where liability is not able to be excluded by law, to the extent allowed by law and without limiting your rights under Australian Consumer Law, our liability to you in any circumstances will be limited to re-performance of any services we have provided to you.
    
    
12. CONTACT DETAILS
    
    If you have any questions, comments, requests or concerns, please contact us at:
    We Do Virtual Assistants Pty Ltd ACN 674 378 726
    18 Salisbury St, WERRIBEE VIC 3030
    c/o Privacy Officer: Justin Shiong
    Email: admin@wedovas.com.au

13. CHANGES TO THIS POLICY
    (a) This document sets out our current Privacy Policy.
    
    (b) From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. You should review our Privacy Policy when you visit our website or provide us with personal information.