Privacy Policy

trading as Reputationaire

  1. Introduction

    1. In this Privacy Policy, ‘us’ ‘we’ ‘our’ or Reputationaire means trading as Reputationaire.
    2. Reputationaire operates the website, the application, and any other solutions within the domain.
    3. Reputationaire provides a means by which users can store reputation data and access and exchange third party reputation data (Services).
    4. Personal Information includes information or an opinion about an individual that is reasonably identifiable. For example, your name, gender, postcode and contact details.
    5. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).
    6. By providing Personal Information to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
    7. We may modify our Privacy Policy at any time by publishing changes to the Services on our website. We recommend you check the Services periodically to ensure you are aware of our current Privacy Policy. Changes to this Privacy Policy are effective when they are posted to this page.
  2. Collection of Personal Information

      What Personal Information we collect

    1. We may collect Personal Information including, but not limited to, the following:
      (a) name;
      (b) street address;
      (c) email address;
      (d) telephone number and other contact details;
      (e) your device, device type, geo-location information, computer statistics on page views, IP address and standard web log information;
      (f) details of the products and Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and Services and respond to your enquiries;
      (g) information about your use of the Services, such as the pages you visit, the time and date of your visit and the internet protocol address assigned to your computer;
      (h) information relating to our ability to link various social media or internet profiles together as part of the Services; and
      (i) any incidental or residual information that is collected through your uses of the Services as outlined in paragraph 2.2.

    2. How we collect Personal Information

    3. We may collect these types of Personal Information about you from a variety of sources either directly from you through your use of the Services, or from third parties when you:
      (a) register and use the Services;
      (b) subscribe to receive alerts and information from the Services or a third party; and
      (c) contact us for any reason, including but not limited to, reporting of a problem with the Services, requesting further solutions or seeking our assistance.
  3. Use and disclosure of Personal Information

      Why we collect, use and disclose Personal Information

    1. We collect, hold, use and disclose your Personal Information in order to:
      (a) provide you access to and use of the Services;
      (b) improve and optimise the Services for users;
      (c) send you updates relevant to the Services and our related products or solutions;
      (d) send information requested by you, and any reminders, service and support relevant to the Services;
      (e) contact you in relation to marketing and promotional messages;
      (f) comply with our legal obligations, resolve any disputes between users;
      (g) notify you of any changes to the Services;
      (h) protect the rights, property or safety of Reputationaire, our customers or third parties; and
      (i) increase understanding of customer site usage through third party solutions such as Google Analytics and other analytical solutions (you can read more about how Google uses your Personal Information on their website.
    2. If there is a change of control in one of our businesses (whether by merger, sale, transfer of assets or otherwise), customer information, which may include your Personal Information, could be disclosed to a potential purchaser under a confidentiality agreement. We would only disclose your information in good faith and where required by any of the above circumstances;

    3. Direct marketing

    4. We and our carefully selected business partners may send you direct marketing communications and information about the Services. This may take the form of emails, SMS, mail, or other forms of communication, in accordance with the Spam Act 2003 (Cth) and Privacy Act.
    5. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided in our correspondence (e.g. unsubscribe link).

    6. To whom do we disclose your Personal Information

    7. We may disclose Personal Information for the purposes described in the Privacy Policy to:
      (a) our employees and related bodies corporate;
      (b) third party solution providers, including providers for the operation of the Services and/or our business or in connection with providing our products and solutions to you (we will never disclose your personal details to a third party except the necessary information required by providers of products or solutions you engage with);
      (c) anyone to whom our assets or businesses (or any part of them) are transferred;
      (d) specific third parties authorised by you to receive information held by us; and
      (e) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

    8. Anonymity of Personal Information and use of pseudonyms

    9. You are unable to create anonymous profiles as this would be inconsistent with the nature of the Services.
    10. Reputationaire does provide you with the ability to use a pseudonym when accessing the Services. The ability to maintain an effective pseudonymous account is dependent on your use of the Services, including the Personal Information contained in third party reputation data. Further information regarding opening and maintaining an account using a pseudonym is contained in our Terms and Conditions.
    11. If you choose to engage with Reputationaire using a pseudonym and wish to maintain pseudonymity, there may be limitations on your ability to fully utilise the Services. You may be more restricted in the kinds of platforms you can link to your profile and in building a comprehensive reputation vault.

    12. Disclosure and storage of Personal Information outside of Australia

    13. Personal Information that we collect may be stored outside of Australia, in servers located in places such as, but not limited to, the European Union.
    14. If your Personal Information provided to us is disclosed outside of Australia, we will take reasonable steps to ensure that any overseas recipient will deal with such Personal Information in a way that is consistent with the Australian Privacy Principles and does not breach the Privacy Act.
  4. Using our website and Cookies


    1. Cookies are small files that store information on your computer, mobile phone and other devices. Enabling your device to recognise you on the Services, as well as other solutions, devices and browsing sessions. You are able to disable these Cookies but the Services may not work as intended if you chose to do so.
    2. Cookies we use in the site generally fall into the following categories: Essential cookies, these are cookies that originate from our site that help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The site cannot function properly without these cookies. Session cookies are automatically deleted at the end of each browsing session, typically when the web browser is closed. Persistent cookies remain until the expiry date and time set by the web server. They can be manually deleted by the user.
    3. We may also use Cookies or other tracking technologies on the Services that help track and remember your preferences. Cookies may be used to serve relevant ads to Services visitors through third party solutions such as Google Adwords. These ads may appear on this Services or other Services you visit.
    4. Reputationaire uses remarketing solutions to advertise on third party websites to you after you visited our Services. We, and our third party vendors, use cookies to inform, optimize and serve advertisements based on your past visits to our Services.
    5. 3rd party cookies originate from a domain that is different to the site visited. We will treat all this information as Personal Information.
    6. We will handle any Personal Information collected by Cookies in the same way we handle all types of Personal Information under this Privacy Policy.
    7. Links

    8. The Service may contain links to websites operated by third parties. These links are placed for your convenience. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights on those linked websites.
  5. Security and Storage

    1. We may hold your Personal Information in either electronic or hard copy form. We generally collect and store electronic information through third party storage providers. We are 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. For example, we review and update our security measures in light of current technologies.
    2. Credit card information is not stored by us on our servers.
    3. Data Retention: We will store and process your Personal Information for as long as required by the agreed upon purpose(s) that it has been collected for. Therefore, as long as you are a registered user of our Services we will store and process your Personal Information in accordance with GDPR as seen in section 8.1.
    4. We may also retain your Personal Information beyond the end of your account's lifetime if you give consent, until such consent is withdrawn. Additionally, we may also retain Personal Information for a longer period in the case of a legal dispute or upon request by an authority.
    5. Once the retention period expires, your Personal Information will be erased from our servers. As we use encrypted and hidden blockchain to store some of your Personal Information, we cannot delete this data itself. However, deletion of your private password "pass phrase" key will render it undecryptable. We may still retain non Personal Information.
    6. A Data Breach is unauthorised access to or unauthorised disclosure of Personal Information, or a loss of Personal Information, that we hold.
    7. Under the Notifiable Data Breaches Scheme of the Privacy Act, we may be obliged to report Data Breaches to you and the Australian Information Commissioner if we become aware or believe that your data has been compromised.
    8. For more information about our obligation to manage Data Breaches, visit the Office of the Australian Information Commissioner’s website.
    9. Any non-Personal Information, communications and material you send to our Services or via email, or which we obtain from third parties without promises of confidentiality, may be kept, used and disclosed by us on a non-confidential basis. We are free to use and reproduce any such information freely, and for any purpose whatsoever. Specifically, we will be free to use any ideas, concepts, know-how or techniques contained in such information for any purpose, including developing, manufacturing or marketing products.

  6. Accessing or correcting your Personal Information

    1. You can access the Personal Information we hold about you by contacting the Services team using our contact details set out at section 10.1 of this Privacy Policy. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.
    2. If you think that any Personal Information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected within 30 days.
  7. Making a complaint

    1. If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your Personal Information, you can contact the Services team using our contact details set out at section 10.1 of this Privacy Policy. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
    2. For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner’s website.
  8. General Data Protection rights (EU residents)

      Principle GDPR Rights

    1. In this section, we have summarised the rights that you have under data protection law and the General Data Protection Regulations (GDPR). Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principal rights under data protection law are:
      (a) the right to access; (Exceptions may apply see section 8.2.1)
      (b) the right to rectification;
      (c) the right to erasure;
      (d) the right to restrict processing;
      (e) the right to object to processing;
      (f) the right to data portability;
      (g) the right to complain to a supervisory authority; and
      (h) the right to withdraw consent.

      1. You have the right to confirmation as to whether or not we process your Personal Information and, where we do, access to the Personal Information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Personal Information concerned and the recipients of the Personal Information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your Personal Information. You can access your Personal Information through using our contact details provided in section 10 of this Privacy Policy.) The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. In some circumstances as described in section 5.5 and 6.1 we may not be able to provide you with access to all your Personal Information in which case we will provide you with a reason as to why this is. The lack of access to all Personal Information may be due to the nature of the blockchain technology used by Reputationaire. As this information is anonymised, this data cannot be linked to a natural person. Reputationaire does not have direct access to the said information, due to the need for a private key "pass phrase" generated on the user device to gain access. Reputationaire does not need to provide an individual access to that data, due to anonymised data not being subject to GDPR regulations.
      2. You have the right to have any inaccurate Personal Information about you rectified and, taking into account the purposes of the processing, to have any incomplete Personal Information about you completed.
      3. In some circumstances you have the right to the erasure of your Personal Information without undue delay. Those circumstances include: the Personal Information are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the Personal Information have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
      4. In some circumstances you have the right to restrict the processing of your Personal Information. Those circumstances are: you contest the accuracy of the Personal Information; processing is unlawful but you oppose erasure; we no longer need the Personal Information for the purposes of our processing, but you require Personal Information for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Personal Information. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
      5. You have the right to object to our processing of your Personal Information on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the Personal Information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
      6. You have the right to object to our processing of your Personal Information for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your Personal Information for this purpose.
      7. You have the right to object to our processing of your Personal Information for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

    3. Information processing as per General Data Protection Rights Regulation

    4. To the extent that the legal basis for our processing of your Personal Information is:consent; or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your Personal Information from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
      1. If you consider that our processing of your Personal Information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
      2. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
      3. You may exercise any of your rights in relation to your Personal Information by written notice to us.
  9. Children's Privacy

    1. Our Services do not address anyone under the age of 16 ("children"). If you are younger than 16, you may not register with or use our Services.
    2. We do not knowingly collect personally identifiable information from children under 16. If you are a parent or guardian and you are aware that your children has provided us with Personal Information, please contact us. If we discover that anyone under the age of 16 has provided us with Personal Information, we will delete such information from our servers in accordance with our Data Retention immediately.
  10. Contact Us

    1. For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, you can contact Andrew Hine CEO using the details set out below:
      Postal Address:

Effective: 2021-05-13