Visuals2Go Privacy Policy

1. About This Privacy Policy

1.1

Bo Innovations Pty Ltd (ACN 621 205 865), trading as Visuals2Go ("Visuals2Go", "Bo Innovations", "we", "us" or "our"), respects your privacy and is committed to protecting personal information entrusted to us.

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information in connection with:

1. Visuals2Go;
2. Visuals2Go Next;
3. any successor, replacement, renamed or rebranded version of the Visuals2Go application;
4. our websites;
5. Visuals2Go accounts;
6. subscriptions and memberships;
7. training, webinars and educational resources; and
8. other associated products and services,

collectively referred to as the "Services".

1.2

We handle personal information in accordance with applicable privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles where they apply to us.

Where applicable to our activities or users, we may also be subject to privacy requirements in other jurisdictions.

1.3

"Personal information" generally means information or an opinion about an identified individual or an individual who is reasonably identifiable.

Depending on how the Services are used, this may include names, email addresses, photographs, audio recordings, account information and other information capable of identifying an individual.

2. Information We May Collect

The information we collect depends on how you interact with Visuals2Go and which Services you use.

2.1 Account Information

When you create or maintain a Visuals2Go Account, we may collect information such as:

1. your name;
2. email address;
3. username or account identifier;
4. authentication and account-security information;
5. subscription or membership status;
6. account preferences; and
7. other information reasonably necessary to establish, maintain or support your Account.

We recommend that Accounts used to support children or other individuals be created and managed by a parent, guardian, educator, therapist, carer, organisation or other appropriately authorised person where appropriate.

2.2 Subscription and Transaction Information

Where you purchase a Subscription, membership, Commercial Licence or other paid Service, we may receive or hold information relating to the transaction, such as:

1. the product or Subscription purchased;
2. subscription status;
3. transaction identifiers;
4. purchase dates;
5. renewal or expiry information; and
6. billing or payment-related information made available to us by the relevant payment provider.

Where payment is processed by an app store or third-party payment provider, payment-card details may be collected and processed directly by that provider rather than by Visuals2Go.

We do not necessarily receive your complete payment-card information from those providers.

2.3 User-Created Content

The Application may allow users to create, upload, record, store, synchronise or share content such as:

1. photographs;
2. images;
3. text;
4. names or labels;
5. voice and audio recordings;
6. visual cards;
7. albums;
8. communication resources; and
9. other personalised content.

We refer to this as "User Content."

User Content may contain personal information about the Account holder or another person, including a child, student, client, family member or person receiving communication support.

2.4 Support and Communications

If you contact us, we may collect:

1. your name;
2. email address;
3. information contained in your enquiry;
4. technical information you provide;
5. correspondence between you and Visuals2Go; and
6. other information reasonably necessary to respond to your request.

2.5 Training, Webinars and Educational Activities

If you register for training, webinars, educational resources or other Visuals2Go activities, we may collect information such as:

1. your name;
2. email address;
3. occupation or professional role;
4. organisation;
5. location; and
6. information reasonably necessary to administer the activity.

2.6 Website and Technical Information

When you access our website or Services, we or our service providers may automatically receive technical information such as:

1. device type;
2. operating system;
3. browser type;
4. IP address;
5. general usage information;
6. pages or features accessed;
7. crash or diagnostic information; and
8. cookie or similar technology information.

Where reasonably possible, we may use aggregated or de-identified information for analytics and product improvement.

3. User Content Relating to Other People

3.1

Visuals2Go is designed to support communication and learning and may be used by parents, carers, educators, therapists and other support persons to create personalised resources for another individual.

As a result, User Content may contain information about someone other than the Account holder.

3.2

If you upload, record, store or share personal information about another person through Visuals2Go, you are responsible for ensuring that you have appropriate authority, permission or consent to do so where required.

This is particularly important where the information relates to:

1. children;
2. students;
3. therapy clients;
4. people with disability; or
5. other individuals whose information is being managed by someone else.

3.3

We encourage users to minimise the amount of identifying information included in communication resources where it is not necessary for the intended communication or educational purpose.

4. How We Collect Personal Information

We may collect personal information:

1. directly from you when you create an Account;
2. when you enter information into the Application;
3. when you upload or create User Content;
4. when you purchase or manage a Subscription or Service;
5. when you contact us;
6. when you register for training, webinars or resources;
7. through our websites;
8. through cookies and similar technologies;
9. from app stores and payment providers;
10. from service providers acting on our behalf; and
11. where authorised or required by law.

5. Why We Collect and Use Personal Information

We may collect, hold and use personal information where reasonably necessary to:

1. create and administer Accounts;
2. authenticate users;
3. provide the Application and Services;
4. store, synchronise and display User Content;
5. provide features requested by users;
6. administer Subscriptions and purchases;
7. provide customer and technical support;
8. respond to enquiries;
9. maintain the security and integrity of our Services;
10. identify and troubleshoot technical problems;
11. improve the functionality, reliability and user experience of Visuals2Go;
12. provide training, webinars and educational resources;
13. communicate important information about Accounts or Services;
14. comply with our legal obligations;
15. protect our rights, users and Services; and
16. carry out other purposes disclosed to you when information is collected.

6. Account, Onboarding and Marketing Communications

6.1 Account and Service Communications

If you create a Visuals2Go Account, we may use your contact details to send communications reasonably necessary to provide, administer or secure your Account and Services.

These may include:

1. account verification;
2. authentication or security notices;
3. password-reset information;
4. Subscription and billing information;
5. important service notifications;
6. information about material changes to the Application;
7. changes to our Terms or Privacy Policy; and
8. other necessary administrative communications.

6.2 Getting Started and Support

We may also send getting-started, onboarding, educational or support communications designed to help you set up and use Visuals2Go.

These may include:

1. tutorials;
2. getting-started instructions;
3. demonstrations of Visuals2Go features;
4. information about communication and educational features;
5. tips for using the Application; and
6. support resources.

Where these communications are optional, you may unsubscribe using the unsubscribe facility provided.

6.3 Marketing and Promotional Communications

We may send marketing or promotional communications where you have consented to receive them or where we are otherwise permitted to do so by applicable law.

Marketing communications may include information about:

1. new products or Services;
2. paid plans or upgrades;
3. special offers or promotions;
4. Commercial Licences; and
5. other Visuals2Go products or opportunities.

You may unsubscribe from marketing communications at any time using the unsubscribe facility provided in the message or by contacting us.

Unsubscribing from marketing does not prevent us from sending communications reasonably necessary to operate your Account or provide Services you use.

7. Children and Visuals2Go

7.1

Visuals2Go is designed to support people with communication and learning needs, and we recognise that many individuals who benefit from the Application may be children.

However, Visuals2Go is intended to be downloaded, registered, purchased and administered by an adult or another appropriately authorised person where required.

7.2

A child may use the communication and educational features of the Application under the supervision or authority of a parent, guardian, educator, therapist, carer or other responsible person.

7.3

Where an adult Account holder creates User Content relating to a child, that content may include photographs, voice recordings, names, communication resources or other information about the child.

The Account holder is responsible for ensuring they have appropriate authority to create, upload, store or share that information.

7.4

We do not sell children's personal information.

We do not intentionally use a child's personalised User Content for direct marketing to that child.

7.5

We do not require a child receiving communication support to independently create a Visuals2Go Account where the Account is appropriately created and managed by an adult on their behalf.

7.6

If you believe that a child's personal information has been provided to us without appropriate authority or consent, please contact us so that we can investigate and take appropriate action.

8. User Content, Cloud Storage and Synchronisation

8.1

Some Visuals2Go features may allow User Content and Account information to be stored or synchronised using cloud-based infrastructure.

This enables functionality such as accessing content across supported devices, maintaining an Account or restoring and synchronising content.

8.2

Depending on the Service and platform being used, information may be processed or stored using infrastructure operated by third-party technology providers.

8.3

We use User Content only for purposes reasonably necessary to provide, maintain, secure and support the Services, except where you have separately authorised another use or where use is permitted or required by law.

8.4

We do not claim ownership of User Content merely because it is uploaded to or stored through Visuals2Go.

9. Sharing Content

9.1

Visuals2Go may provide functionality allowing users to share cards, albums, images or other resources with another person or user.

9.2

You should take particular care before sharing content containing personal information, including photographs or information relating to children, students or clients.

9.3

When you intentionally share User Content with another person, that person may be able to access or retain the information you choose to share.

You are responsible for deciding whether sharing that information is appropriate and for obtaining any necessary authority or consent.

9.4

Once information has been intentionally provided to another user, Visuals2Go may not be able to control what that recipient subsequently does with their copy.

10. Disclosure to Service Providers

We may disclose personal information to third parties where reasonably necessary to operate our business and provide the Services.

These may include:

1. cloud-hosting and infrastructure providers;
2. database and data-storage providers;
3. email and communications providers;
4. customer-support providers;
5. analytics and technical-service providers;
6. app stores and payment providers;
7. professional advisers;
8. contractors and suppliers supporting our Services; and
9. government, regulatory or law-enforcement bodies where disclosure is authorised or required by law.

We seek to limit disclosures to information reasonably necessary for the relevant purpose.

11. Overseas Storage and Disclosure

11.1

Some of the third-party service providers used to operate Visuals2Go may store, process or access information outside Australia.

Where personal information is likely to be disclosed to overseas recipients, we will handle those disclosures in accordance with applicable privacy laws.

11.2

Countries in which our service providers or their infrastructure may be located can change over time.

Where practicable and required by law, we will identify countries in which overseas recipients of personal information are likely to be located.

11.3

We take reasonable steps as required by applicable law when engaging service providers that process or receive personal information on our behalf.

12. App Stores and Third-Party Services

12.1

Visuals2Go may be distributed through third-party app stores including the Apple App Store and Google Play.

Those providers may independently collect and process information in accordance with their own privacy policies.

12.2

Visuals2Go may also integrate with or link to third-party websites, videos, search services or other online services.

The privacy practices of independent third parties are governed by their own privacy policies and are not controlled by Bo Innovations.

13. Cookies and Website Analytics

13.1

Our websites may use cookies and similar technologies.

Cookies are small files used to recognise a browser or device, remember preferences, understand website use and provide website functionality.

13.2

We may use cookies or analytics tools to understand matters such as:

1. how visitors use our website;
2. which pages or features are accessed;
3. general website traffic;
4. technical performance; and
5. how our website and Services may be improved.

13.3

You may be able to restrict or disable cookies through your browser settings, although doing so may affect some website functionality.

14. De-Identified and Aggregated Information

We may create or use aggregated or de-identified information that does not reasonably identify an individual for purposes including:

1. understanding how Visuals2Go is used;
2. improving features and functionality;
3. analysing performance;
4. troubleshooting;
5. business planning; and
6. developing and improving our Services.

Where information has been appropriately de-identified so that it is no longer personal information, it may not be subject to the same privacy requirements as identifiable personal information.

15. Data Security

15.1

We take reasonable steps to protect personal information we hold from misuse, interference, loss, unauthorised access, modification and disclosure.

These measures may include appropriate technical, organisational and administrative safeguards.

15.2

No internet-based service or electronic storage system can be guaranteed to be completely secure.

Users should take reasonable steps to protect their Account credentials and devices.

15.3

If we become aware of a data breach involving personal information, we will investigate and take steps required by applicable law, including notification to affected individuals and regulators where legally required.

16. Data Retention and Account Deletion

16.1

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, to provide our Services, comply with legal obligations, resolve disputes, maintain appropriate business records or protect our legitimate interests.

16.2

Where available, you may request deletion or closure of your Visuals2Go Account.

Deleting an Account may result in loss of User Content associated with that Account.

16.3

Some information may need to be retained after Account deletion where required or permitted by law, including transaction, taxation, security, fraud-prevention or legal records.

16.4

Information contained in backups may remain for a limited period before being overwritten or deleted through our normal backup processes.

17. Access and Correction

17.1

You may request access to personal information we hold about you, subject to exceptions permitted by applicable law.

17.2

If you believe personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to correct it.

17.3

We may take reasonable steps to verify your identity before providing access to, correcting or deleting personal information.

17.4

Where we refuse an access or correction request in circumstances permitted by law, we will provide information about the refusal where required.

18. Privacy Complaints

If you believe we have not handled your personal information appropriately, please contact us using the details below.

Please provide sufficient information for us to understand and investigate your concern.

We will review privacy complaints and respond within a reasonable period.

If you are not satisfied with our response, you may have the right to make a complaint to an applicable privacy regulator, including the Office of the Australian Information Commissioner where appropriate.

19. GDPR and Users in the European Economic Area

Where the GDPR applies to our processing of personal data, we will process personal data on an appropriate lawful basis.

Depending on the circumstances, this may include:

1. your consent;
2. performance of a contract;
3. compliance with a legal obligation; or
4. our legitimate interests where those interests are not overridden by applicable rights.

Where applicable, individuals may have rights including:

1. access;
2. correction;
3. deletion;
4. restriction of processing;
5. data portability;
6. objection to certain processing; and
7. withdrawal of consent where processing is based on consent.

These rights are subject to applicable legal requirements and exceptions.

20. United States and Children's Privacy

Where United States children's privacy laws, including the Children's Online Privacy Protection Act (COPPA), apply to our Services, we will take steps reasonably necessary to comply with those requirements.

Visuals2Go is intended to enable adults such as parents, guardians, educators, therapists and carers to manage Accounts and personalised communication resources for the people they support.

If our practices relating to children's personal information materially change, we will update this Privacy Policy and implement additional consent or notice mechanisms where required by applicable law.

21. Sale or Restructure of the Business

If Bo Innovations is involved in a merger, acquisition, restructure, financing, sale of assets or transfer of all or part of its business, personal information may be disclosed or transferred as part of that transaction where permitted by law.

We will take reasonable steps to protect personal information in connection with such a transaction.

22. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

1. changes to Visuals2Go or the Services;
2. changes to our information-handling practices;
3. new technology or service providers;
4. legal or regulatory changes; or
5. new features.

The current version will be made available through our website or Application.

Where a change is material and it is reasonably practicable to do so, we may notify Account holders through the Application, by email or another appropriate method.

The date at the beginning of this Privacy Policy indicates when it was last updated.

23. Contact Us

For questions, requests or complaints concerning privacy, please contact:

24. Meaning of Visuals2Go

References in this Privacy Policy to Visuals2Go, the Application or the Services include:

1. Visuals2Go;
2. Visuals2Go Next;
3. iOS, Android and other supported versions;
4. successor or replacement versions; and
5. any future renamed or rebranded version of the Visuals2Go application operated by Bo Innovations Pty Ltd.

A change to the Application's name, branding, version or platform does not affect the application of this Privacy Policy.