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Privacy Policy

Overview

Rumi Insights Pty Ltd ACN 640 313 435 (“Rumi”, “we”, “us”, “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding Personal Data we collect from users of our Platform and Services. Capitalised terms not defined in this Privacy Policy have the meanings given in our Terms of Service.

The processing of Personal Data shall always be in line with the Australian Privacy Principles contained in the Privacy Act 1998 (“Privacy Act”), the General Data Protection Regulation (“GDPR”), and in accordance with country-specific data protection regulations applicable to Rumi. For the purpose of the GDPR, the Data Controller is Rumi.

User Consent

Where we rely on your consent as the lawful basis to process your data we will always ask for you to positively affirm your acceptance. By clicking “I accept the Privacy Policy” or similar you acknowledge and agree to be bound by this Privacy Policy. Consent forms use no pre-checked checkboxes so that you can freely opt-in, and consent can be withdrawn just as easily through the appropriate account settings on the Platform.

Children

Our Service is not offered to persons under the age of 18 or who cannot form legally binding contracts under Applicable Law. We do not knowingly collect Personal Data from such visitors. If you become aware that a child has provided us with information please contact us; any information in breach of this provision will be deleted.

Types of Data We Collect

“Personal Data” means any information that allows someone to identify you, including your name, address, telephone number, e-mail address, and any other non-public information associated with or linked to the foregoing. “Anonymous Data” means data that is not associated with or linked to your Personal Data. We collect both Personal Data and Anonymous Data. We do not knowingly collect sensitive information from visitors.

Information you provide to us

  • Account Data: You do not need an account to browse the website. If you participate on the Platform you create an account and may provide your name, e-mail and mailing addresses, phone number, password and other information on the registration/application form.
  • Communication and participation data: Information you provide while participating in Forums and communicating with other Users, including information relating to the subject of the relevant Forum such as medical opinions. Please do not transmit individually identifiable medical information without prior authorisation from the respective patient.
  • Payment Data: Payments are only made by Sponsors. When a Sponsor pays by bank transfer, we collect all information necessary to complete the transaction, including the Sponsor’s name and billing information.
  • Additional Data: If you provide feedback or contact us via e-mail, phone or by contracting with us, we collect your name, e-mail address and the content of the communication in order to reply.
  • Subscription Data: Where you subscribe to newsletters we collect the data you input for subscription purposes, used only for marketing materials or the reasons made known on the form.

The legal basis for processing is generally your consent through voluntary submission, the necessity of the data for performance of a contract, pre-contractual measures, and/or our other legitimate interests.

Information we collect as you use our services

  • Log Data: Our servers (which may be hosted by a third party) collect information including your browser type, operating system, IP address, domain name, and a date/time stamp for your visit - used to operate and improve our services, ensure security, maintain back-ups and communicate with you.
  • Google Analytics: We use Google Analytics and Google Analytics for Display Advertising. Google Analytics collects information anonymously and reports website trends without identifying individual visitors.
  • Facebook pixels: We use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms.
  • Third party services: If you log in with, or associate your Account with, a Third Party Service, we may receive information about you from that service in accordance with its terms.
  • Submission data: We may collect Personal Data about your submissions by extracting it from your Account (e.g. how many Forums you have created or been part of), used in aggregate to determine metrics.

Use of Your Personal Data

In general, Personal Data you submit is used to respond to your requests or to help us provide the Services in a personalised, safe and efficient manner. This includes to conduct our business; facilitate the online discussion Platform; administer contracts; for marketing purposes; to create and secure your Account; to identify you; to research, develop and improve our Platform and Services; to customise content; to provide the Services; to send administrative and support notifications; to respond to your inquiries; to send newsletters, surveys and offers; to detect, investigate and prevent unlawful acts or breaches; to enforce our terms and policies; to verify information; to comply with our legal obligations; to aggregate or anonymise your data; to resolve disputes; and to protect a person’s rights, property or safety.

Creation of Anonymous Data

We may create Anonymous Data records from Personal Data by excluding personally identifiable information. We use this Anonymous Data to analyse request and usage patterns and reserve the right to use and disclose Anonymous Data for any purpose in our sole discretion.

Disclosure of Your Personal Data

We may disclose your Personal Data to third parties for the purposes contained in this Privacy Policy, including:

  • Service Providers - to provide the Services, conduct quality assurance testing, facilitate account creation, provide technical support and other services. Providers include contractors providing email and call-centre support, IT service providers such as web hosts and analytics providers, mailing houses, market research organisations and specialist consultants, who are required not to use your Personal Data other than to provide the requested services.
  • Affiliates and Acquisitions - our parent company, subsidiaries, joint ventures or companies under common control, and in the event of a merger, acquisition or sale of assets.
  • Third parties with your consent - including other Participants and the Sponsor of a Forum you share information with, and your authorised representatives.
  • Other disclosures - where we believe in good faith it is necessary in connection with a legal investigation, to comply with laws or respond to subpoenas or warrants, to protect our rights or property, to prevent violations, or to protect the safety or integrity of our platform.

We will not share, sell, rent or disclose your Personal Data in ways different from what is disclosed in this Privacy Policy.

If we can’t collect your data

If you do not provide us with the Personal Data described above, we may not be able to provide the requested services to the same standard or at all, run competitions and promotions to your benefit, provide you with information about products and services, or tailor the content of our Services to your preferences.

Cookies Policy

We use cookies and URL information to gather information about the date and time of your visit and what you searched for and viewed. Cookies are small pieces of information a website sends to your computer’s hard drive. We use both session cookies and persistent cookies to provide a more personal and interactive experience. Persistent cookies can be removed via your browser’s help file. We sometimes use cookies to show remarketing communications via third-party networks like the Google Display Network and Facebook; you may opt out via the Network Advertising Initiative opt-out page.

Third Party Sites

When you click a link to any other website you leave our Platform, and another entity may collect data from you. We have no control over and are not responsible for those outside websites or their content or privacy practices. We encourage you to read their privacy policies before using them.

Managing Your Personal Data

Subject to the Privacy Act and the GDPR, you may request to access the Personal Data we hold about you by contacting us. You may access, rectify, delete or modify your Personal Data (where reasonably practicable), request deletion of your data, object to or restrict processing, withdraw consent at any time, and request portability of information you have shared. We may need to verify your identity, may charge a reasonable fee in certain circumstances, and may retain information for fraud prevention or similar purposes.

Security of Your Personal Data

Rumi is committed to protecting the security of your Personal Data. We and our third-party service providers use industry-standard security technologies and procedures, and require you to enter a password to access your Account. No method of transmission over the Internet or electronic storage is 100% secure, so while we use reasonable efforts to protect your Personal Data we cannot guarantee its absolute security.

International Transfer and Disclosure of Personal Data

Where we transfer Personal Data outside the European Union or EFTA States, we ensure an adequate level of protection based on the adequacy of the receiving country’s data protection laws. We may disclose Personal Data to our related bodies corporate and third-party suppliers and service providers located overseas, and take reasonable steps to ensure overseas recipients do not breach the privacy obligations relating to your data.

Notifiable Data Breaches

If you reside in Australia and we are required to comply with the notifiable data breaches provisions in Part IIIC of the Privacy Act 1988 (Cth), we will take all reasonable steps to contain the breach and follow our notifiable data breach policies. If you reside in the European Union or EFTA States, we will endeavour to meet the 72-hour deadline imposed by the GDPR to report any data breach to the supervisory authority, and will contact you without undue delay where there is likely to be a high risk to your rights.

Automated individual decision-making, including profiling

If you reside in the European Union or EFTA States, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, subject to the exceptions in the GDPR. If you wish to exercise your rights please contact us.

Retention of Data

We keep Personal Data from active accounts as long as reasonably needed for our operations and to fulfil the purposes set out herein. We will also keep Personal Data from deactivated accounts where legally required and where necessary to stop fraud, collect outstanding fees, troubleshoot problems, or otherwise enforce our policies.

Contact Information

Rumi welcomes your comments or questions regarding this Privacy Policy. If you have a question or would like to make a complaint, please contact us by email using our contact details on the Platform or below.

If you reside in Australia, you can confidentially contact our Privacy Officer at: Privacy Officer, Rumi Insights, 6 Middlemiss Street, Lavender Bay NSW 2065. Email: privacy@meetwithrumi.com.

If we do not resolve your enquiry to your satisfaction, you may contact the Office of the Australian Information Commissioner - Telephone: 1300 363 992; Email: enquiries@oaic.gov.au; Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000; Postal Address: GPO Box 5218, Sydney NSW 2001; Site: www.oaic.gov.au.

If you reside in the European Union or EFTA States, the data controller responsible for your Personal Data is Rumi Insights Ltd ACN 640 313 435, 6 Middlemiss Street, North Sydney NSW 2060. You can confidentially contact our Data Protection Officer and our EU Representative at privacy@meetwithrumi.com. You also have the right to raise a concern with your local supervisory authority.

Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision and Rumi reserves the right, at its sole discretion, to modify or replace any part of this Agreement. It is your responsibility to check this Agreement periodically for changes. Continued use of our Platform or Services indicates your acknowledgement that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications.