Privacy Policy (Updated 30th August 2023)
oVRcome is committed to respecting your privacy. oVRcome and its related companies and affiliates ("we", "us", "our") work to responsibly manage and protect your information, to be transparent about our privacy practices, and to ensure our privacy standards are up to date. We will only collect, store, use, and disclose your Personal Information in accordance with this Privacy Policy and the Privacy Act 2020 (New Zealand).
oVRcome’s privacy policy applies to all current and former customers of oVRcome. The information, material, and content provided in the pages of the App may be changed at any time with or without notice, including this privacy policy. Any revision to this privacy policy shall take effect as at the date when the change is made to the App or our website. Your continued access to or use of the oVRcome App will indicate that you consent to any changes in our privacy policy.
The following Privacy Policy has been set up to protect your Personal Information when you use any services provided by oVRcome, including when you submit, or when we collect, that information. Information may be collected via our "Online Services", which include:
- the information offered through and provided by our website or any related website that we offer information and products from, from time to time ("Website");
- mobile operating applications including those for smartphones, tablets, and other handheld devices ("Apps");
- social media platforms and pages, including Facebook, Twitter, Youtube, and Instagram;
- email communications and subscription services; and
- Wi-Fi services, including communication via wireless networks.
By providing us with Personal Information, you consent to the collection, storage, use, and disclosure of Personal Information in accordance with this Privacy Policy. In this policy, "Personal Information" means information about an identifiable individual. By way of example, this type of information includes your name and contact details and any information that you upload about yourself to oVRcome.
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Changes to this Privacy Policy
We may modify, amend, change, or replace any of the terms, conditions, or provisions of this Privacy Policy periodically. We will notify you of any such changes by posting an updated version on our website and in the app. Please check this Privacy Policy periodically for changes as it is your responsibility to do so. By continuing to use any of our Online Services following notification of any changes to this Privacy Policy constitutes acceptance of those changes. If you do not agree with any aspect of the updated Privacy Policy, you must immediately cease all use of our Online Services.
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WHAT INFORMATION DO WE COLLECT?
Information provided about yourself, such as your name, sex, age, address, email address, telephone number, payment details, and personal preferences will be collected if you choose to provide it. We will also collect your Personal Information in order to run the Online services in a clinical setting, including your country of origin, ethnicity, and details about your fears and phobia including type, severity, and anxiety levels. For example, this may be provided when you create an account and register via our Website or use our Online Services.
When you install the oVRcome app, we will collect and record information from your use of the App to improve your results and experience and increase the benefit to you of using our services. For example, you will need to rate your anxiety levels as you journey through the App. If you choose not to provide all of the information requested, you may find that you cannot enjoy the full benefit of our Online Services.
INFORMATION COLLECTED ABOUT YOU
When visiting our Website or other Online Services, we may collect additional information, such as your Internet service provider (ISP) address, the name of the web page directing you, and your clicks and activity on our site. Clickstream data and other related information regarding visits to our Apps and related Online Services may be collected. As well, usage and performance data through our Apps using various platform-specific tracking technologies available to the Apps may be collected.
Information may be collected via third parties (including our third-party affiliates or partner companies and from marketing or advertising companies) who may provide us with such information as a part of their relationship with us. We may combine this information with other information that we hold. Third-party service providers may be allowed to use technologies including mobile monitoring and tracking technologies in relation to our Online Services. These third-party service providers may collect information sent by your browser or mobile device. Additional information may be collected about you when you use our Online Services.
COOKIES AND OTHER MONITORING TECHNOLOGIES
We may collect aggregated information by using cookies. Cookies are unique identification numbers that are placed on the browsers of internet users. While the cookies do not identify users personally, they may link back to a database record about said users. We may use cookies to track any aspect of our website or other Online Services. We may use services such as Google Analytics, which will issue cookies from their own servers and which will be able to track website visitors throughout relevant websites. We do not control how those cookies are issued, or the data that they store. We may use "web beacons" (electronic images also known as pixel tags or clear gifs) to recognize a cookie on your computer when you view or act upon a web page, an advertisement that we have placed on a third-party web page, or an email or other electronic communication that we have sent.
We may also use Local Shared Objects, sometimes referred to as "Flash" cookies. The use of Local Shared Objects can help deter, detect, and prevent fraud and can support our Online Services. oVRcome reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. We reserve the right to use these pixels in compliance with the policies of the various social media sites.
HOW IS YOUR PERSONAL INFORMATION USED?
We collect your Personal Information so that we can provide you with Online Services and related services related to your condition. In doing so, we may use the Personal Information we have collected from you for purposes related to the Online Services including to:
- administer and improve the Online Services and help you with your support needs, including by way of adding new features and capabilities to the Online Services;
- notify you of new or changed services offered in relation to the Online Services;
- carry out marketing or training in connection with the Online Services;
- assist with the resolution of any technical support issues or other issues relating to the Online Services;
- comply with all laws and regulations in applicable jurisdictions; and
- communicate with you.
By using the Online Services, you consent to your Personal Information being collected, stored, used, and disclosed in this way and for any other use you authorize. We will only use your Personal Information for purposes described in this Privacy Policy, or with your consent.
IN WHAT CIRCUMSTANCES MIGHT WE DISCLOSE YOUR PERSONAL INFORMATION?
We do not sell, trade, or rent your Personal Information to others. Other companies and individuals may be used to perform services on our behalf, such as delivering packages, sending mail and emails, and processing payments. They will have access to your Personal Information needed to perform these services, but we will never authorize them to use your Personal Information for other purposes. However, we may provide statistics about our customers, sales, traffic patterns, and related site functions to reputable third parties. We will remove any identifying information about you before we provide statistical information to any such third party.
We will not disclose your Personal Information unless we believe on reasonable grounds that you have provided your authorization. However, do be aware that we may be required to disclose your Personal Information without your consent in order to comply with any court orders, subpoenas, or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your Personal Information.
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STORAGE AND SECURITY
oVRcome stores all data in the AWS cloud-based server hosted in Australia. By using the App, you understand and agree that your data is processed in Australia and that Australia may not have the same level of privacy protection as your own country of residence. We are committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorized access, modification, or disclosure. Every aspect of the oVRcome server URL uses SSL and/or TLS security. The server only communicates over HTTPS. We accept no responsibility for any loss, misuse, unauthorized access or disclosure, alteration, or destruction of Personal Information which you have submitted.
WHAT ABOUT LINKS TO OTHER WEBSITES?
Our Online Services may contain links to other websites. These websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the Privacy Policy on all third-party websites to ensure you are comfortable with third-party cookies. These websites will not be under our control.
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We provide linked websites solely for your information and convenience and do not run, manage, or take responsibility for them. We specifically disclaim responsibility for their content, privacy practices, and terms of use, and we make no endorsements, representations, or warranties about their accuracy, content, or thoroughness. Your disclosure of Personal Information to third-party websites is at your own risk.
EMAIL COMMUNICATIONS
We are committed to respecting your choices and providing transparency in how your data is used for marketing purposes.
When using our Website to complete a phobia test, subscribe to a 7-day challenge, or express interest in participating in one of our clinical trials, your consent will be requested and obtained before using your personal information for marketing initiatives. Our marketing efforts are limited to upselling product subscriptions.
When subscribing to our programs, your details will not be used for marketing purposes, as our main marketing goal has already been achieved. Your email will only be used to communicate with you about your oVRcome journey. Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable.
HOW YOU CAN REQUEST ACCESS OR CORRECT YOUR PERSONAL INFORMATION
You may request access to the Personal Information we hold about you, or request that we update, delete or correct any Personal Information we hold about you, by setting out your request in writing and sending it to us at support@ovrcome.io.
We will review your request as soon as possible, within a reasonable timeframe. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
We will only keep your Personal Information for as long as we require it for the purpose for which it was required. However, we may be required to keep some of your Personal Information for specified periods of time, for example under certain laws relating to companies, money laundering, and financial reporting legislation.
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REPORTING CHILD ACCESS WITHOUT PARENTAL CONSENT
Protecting the privacy and safety of children is of utmost importance to us. While our age-specific programs are designed for, and intended for use by, children, they require parental supervision. We require parents to onboard any users under the age of 18. If you become aware of any instance where a child accessed our app and provided personal data without proper parental consent, please report it to us immediately by emailing support@ovrcome.io. Upon receiving reports of unauthorized child access, we will investigate each incident and remove the data as required.
MANAGING A PRIVACY BREACH
If we have a privacy breach that is likely to cause anyone serious harm, we are legally required to notify the Privacy Commissioner and any affected persons as soon as we are practicably able to do so. The Compliance Officer or the CEO will notify the Commissioner via the website (https://www.privacy.org.nz/responsibilities/privacy-breaches/notify-us/)
Feedback / Queries
If you have any questions regarding our Privacy Policy, please email us at support@ovrcome.io.