Privacy Policy
some.place Privacy Policy - November 2021
This Privacy Policy was last updated on 11 November 2021.
1. About this Privacy Policy
1.1 IRL Space Pty Ltd ACN 640 276 768 and its related entities (collectively “some.place”, “we”, “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes the types of information we may collect from you or that you may provide to us, including when you visit the website https://some.place/ (including its subdomains and any other website we operate from time to time) (“Website”) and the some.place application (“App”) (collectively, “Services”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. If you wish to make any inquiries regarding this Privacy Policy, you should contact us in any of the ways specified in paragraph 17.
1.2 Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use our Services and do not provide your information to us. By using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see paragraph 16). Your continued use of the Services after we make changes is deemed to be acceptance of the changes, so please check this Privacy Policy periodically for updates.
2. Children Under the Age of 13
2.1 Our Services are not intended for children. No one under the age of 13 may provide any information to or on the Services. We do not knowingly collect Personal Information from anyone under 13. If you are under 13, do no use or provide any information on the Services or on or through any of the features. If we learn we have collected or received Personal Information from someone under 13 without verification of parental consent, we will delete that information. If you believe we might have any information form or about a child, please contact us at: legal@some.place.
3. Personal Information
3.1 Personal Information is information that may be used to directly or indirectly identify you and includes information such as: (a) names, aliases, postal addresses, unique personal identifiers, online identifiers, Internet Protocol (IP) address, email address, telephone number, account names or similar identifiers; (b) financial information; (c) commercial information, including records of products or Services purchased, obtained or considered, or other purchasing or consuming histories or tendencies; or (d) Internet or other electronic network activity information, including anything that may be defined as "personal information" (or equivalent) under any applicable privacy or data protection laws. It does not include information where the identity has been removed (anonymous data) such that the individual is no longer identifiable.
4. What Personal Information do we collect and hold?
4.1 The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following
(a) username or alias/nickname;
(b) name;
(c) age and/or date of birth;
(d) contact details including telephone numbers (landline and/or mobile);
(e) email address;
(f) address (including postal address);
(g) gender;
(h) in respect of job applicants:
(i) occupation and employment details including employment status and any previous work experience; and
(ii) information from or in connection with your resume or job application if you apply for a position with us;
(i) Australian Business Number (ABN) or similar identifiable business credentials;
(j) information from social media accounts and profiles.
4.2 We may collect and record Personal Information about individuals such as:
(a) our users/customers, potential users/customers and their representatives;
(b) our investors and shareholders;
(c) our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;
(d) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us; and
(e)our employees past and present, including applicants.
(b) our investors and shareholders;
(c) our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;
(d) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us; and
(e)our employees past and present, including applicants.
5. How and when do we collect Personal Information?
5.1 We collect your Personal Information to allow us to conduct our business functions, to provide, market, and sell our products and services, and for the specified purposes set out in paragraph 7.
5.2 We may collect your Personal Information in the course of providing you with goods or services, or:
(a) when you register, sign up for, access or use some.place's platform (“Platform”), including through its Website or through the App;
(b) when you otherwise use or buy our products or services;
(c) when you provide us, or you offer or apply to supply us, with goods or services;
(d) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
(e) when you request information about us, our products or our services;
(f) when you provide feedback to us;
(g) when you visit or fill in a form on our Website (see paragraph 6);
(h) when you visit premises from which we operate;
(i) from third parties, for example, our business partners;
(j) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations;
(k) when you submit a job application to us;
(l) when you otherwise contact us by telephone, fax, email, social media, post or in person; or
(m) where we are otherwise required or authorised by law to do so.
(b) when you otherwise use or buy our products or services;
(c) when you provide us, or you offer or apply to supply us, with goods or services;
(d) when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
(e) when you request information about us, our products or our services;
(f) when you provide feedback to us;
(g) when you visit or fill in a form on our Website (see paragraph 6);
(h) when you visit premises from which we operate;
(i) from third parties, for example, our business partners;
(j) when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations;
(k) when you submit a job application to us;
(l) when you otherwise contact us by telephone, fax, email, social media, post or in person; or
(m) where we are otherwise required or authorised by law to do so.
5.3 Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we seek to collect Personal Information directly from the relevant individual where reasonable and practicable.
5.4 However, we may also collect Personal Information about you from third parties and other sources such as:
(a) our share registry service provider;
(b) our business partners;
(c) publicly available sources of information; or
(d) related entities, companies and businesses of some.place,
(b) our business partners;
(c) publicly available sources of information; or
(d) related entities, companies and businesses of some.place,
but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.
5.5 If the Personal Information we collect includes sensitive information we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.
5.6 Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.
5.7 If you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, you will not be able to use the Services or access the Platform, and we may not be able to otherwise provide you with requested information, products or services, or to effectively conduct our relationship with you.
5.8 In certain situations or as we develop new features for the Services, you also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
6. Information collected via our Services
6.1 Personal Information may be collected by us and by our third party service providers who assist us in operating our Services.
6.2 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Services, including, but not limited to, the methods set out in this paragraph 6.
Google Analytics
6.3 We may use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website.
6.4 If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
Click Stream Data and app usage data
6.5 When you read, browse, or download information from our Services, we or our internet service provider may also collect information such as the date, time, and duration of a visit on the Website or time spent in the App, the pages accessed, the IP address of your computer, any information downloaded, and other App usage data. This information may be used for purposes including product development and support, statistical, reporting, and website administration, maintenance, and improvement purposes.
Cookies
6.6 Our Website may use “cookies” from time to time. Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns. Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. We use this information to enhance the content and services offered on our Website.
6.7 Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access our Website or click-through to our Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.
6.8 Cookies may also be used for other purposes on our Website.
6.9 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.
6.10 If you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.
Advertising networks
6.11 We use network advertisers to serve advertisements on unaffiliated websites or other media (e.g. social networking platforms). This enables us and network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors, and/or traffic measurement services may use pixels, cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These pixels, cookies and other technologies are governed by each entity’s specific privacy policy, not this Privacy Policy. We may provide these advertisers with information, including Personal Information, about you.
6.12 In accordance with applicable law, we may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audiences click here or to opt-out, go to the Facebook ad preferences page) - so that we can better target ads and content to you and others with similar interests on other websites or media (Custom Audiences). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other ad networks display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.
6.13 You may be able to opt out of many ad networks. For example, you may go to the Digital Advertising Alliance (DAA) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (NAI) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
6.14 Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e. contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on a consumer choice website, your opt-out may not be effective.
6.15 We may also use LiveRamp's Authenticated Traffic Solution (ATS) which operates as a cookieless targeting solution. ATS uses a piece of JavaScript on our Website and application, which collects your Personal Information that is then shared with LiveRamp to create an identity link for users instantaneously. This identity link is then used to enable direct advertising across various sites. If you would like to opt out of the ATS add-on, please visit the LiveRamp site at https://liveramp.com.au/privacy/web-privacy-policy/.
Third party content (e.g., social media links)
6.16 Some of the content on our Services may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Services through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.
7. How do we use your Personal Information?
7.1 We use the Personal Information we collect about you for our business functions and activities, in order to operate our business efficiently, and to market our products and services for the benefit of our users/customers.
7.2 We may collect, hold and use your personal information:
(a) to provide and allow you to access the Platform, including using the services and functionality made available through the Platform;
(b) to provide you with information, products, or services that you request from us;
(c) to allow you to view and interact with any content, information, communications, advice, text or other material displayed on the Platform;
(d) to allow you to use, own, buy and sell unique virtual assets such as virtual clothing, accessories, art, tools and collectibles (Non-Fungible Tokens or NFT's) which are available on the Platform or included by you for use on the Platform;
(e) to identify and communicate with you;
(f) to enable us to provide you with requested information, products or services;
(g) to otherwise assist users/customers by providing them with information and support;
(h) to collect and process payments (or facilitate the collection and processing of payments by our third party payment processor service providers);
(i) to help us to manage and enhance products or services we provide to you;
(j) to help us to manage and enhance goods and services we procure from our suppliers and subcontractors;
(k) to personalise and customise your experiences on our Services;
(l) to manage and administer any account you may hold with us;
(m) to promote and market our products and services to you;
(n) to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners;
(o) to conduct research for the purposes of improving existing products or services or creating new products or services;
(p) to allow you to participate in interactive features on the Platform;
(q) to help us research the needs of our customers to enable us to market our products and services with a better understanding of your needs and the needs of customers generally;
(r) to protect you and us from fraud;
(s) to provide for the safety and security of workers and onsite visitors;
(t) to help us manage our business operations;
(u) for business support purposes including maintenance, backup and audit;
(v) to process any job application submitted by you;
(w) to respond to any queries or complaints you may have;
(x) to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information; or
(y) to comply with our statutory and legal obligations.
7.3 We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.
7.4 We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or our applications or to retain the content of any user session.
7.5 You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy.
7.6 We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:
(a) in accordance with this Privacy Policy or any agreement you enter into with us, or
(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth) and the California Consumer Privacy Act.
(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth) and the California Consumer Privacy Act.
8. When do we disclose your Personal Information?
8.1 some.place may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 7. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).
8.2 We may also disclose your Personal Information to:
(a) any of some.place's internal divisions, business units or departments;
(b) your nominated representatives;
(c) other organisations or individuals who assist us in providing products and services to you;
(d) professional service providers and advisors who perform functions on our behalf, such as lawyers;
(e) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development);
(f) banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers; and
(g) government, regulatory authorities and other organisations as required or authorised by law.
(b) your nominated representatives;
(c) other organisations or individuals who assist us in providing products and services to you;
(d) professional service providers and advisors who perform functions on our behalf, such as lawyers;
(e) representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development);
(f) banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers; and
(g) government, regulatory authorities and other organisations as required or authorised by law.
8.3 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website or applications experience a technical problem or to ensure that they operate in an effective and secure manner.
8.4 As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.
9. Interstate and Overseas disclosures
9.1 Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas (outside of the country in which you are located) by us, or by third party service providers. This may happen if:
(a) our offices or related entities are overseas;
(b) we outsource certain activities overseas;
(c) transactions, information, services or products have an overseas connection; or
(d) our computer systems including IT servers are located overseas.
9.2 You consent to the collection, use, storage, and processing of your Personal Information outside of Australia (or otherwise outside of the country in which you are located) as set out in this Privacy Policy.
9.3 In particular, your Personal Information may be disclosed to third parties in Australia and the United States of America, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in countries outside of Australia, without us being responsible under the Privacy Act 1988 (Cth) for such use (or for any breach). Where such parties are located overseas, you may have rights to enforce such parties' compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.
10. Other uses and disclosures
10.1 Where permitted by applicable laws, we may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we may, in our discretion, take reasonable steps to make it known to you at the time we collect or use your Personal Information, but this may not always be possible or appropriate.
11. Marketing
11.1 Except where applicable law requires an express opt-in or other processes to be followed in order for consent to be obtained, by providing your Personal Information to us you consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. Such consent includes consent to us sending you such information by means of direct mail, email, SMS and MMS messages.
11.2 If we are permitted to send marketing information to you and you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:
(a) by clicking on the “Unsubscribe” or subscription preferences link in a direct marketing email that you have received from us; or
(b) contacting us using the contact details specified in paragraph 17.
(b) contacting us using the contact details specified in paragraph 17.
12. Storage and Data Security
12.1 We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, including, but not limited to, using secured servers to store the information you provide to us.
12.2 We aim to keep your Personal Information that we hold secure. We have measures in place designed to protect Personal Information that is collected via our Services.
12.3 If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.
12.4 The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.
12.5 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
13. Accessing and Correcting Your Information
13.1 You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, some.place may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.
13.2 You can access some of your Personal Information through the Services by logging into your account and viewing your profile at any time. A request for access can also be made by contacting us in any of the ways specified in paragraph 17.
13.3 We take reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.
13.4 Please contact us in any of the ways specified in paragraph 17 if you believe that the Personal Information is inaccurate, incomplete or out of date, and we will use all reasonable efforts to correct the information.
13.5 It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.
14. How do we deal with complaints about privacy?
14.1 If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact us in any of the ways specified in paragraph 17 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.
14.2 It would assist us to respond to your complaint promptly if it is made in writing. Please include all relevant information to your complaint. You will receive confirmation of your request within ten (10) business days. We will notify you of the outcome of our investigation within forty-five (45) days.
15. Your California Privacy Rights
15.1 If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the Privacy Policy for California Residents.
15.2 California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us in any of the ways specified in paragraph 16.
16. Updates to this Privacy Policy
16.1 We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website at: https://some.place/pages/privacy-policy. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.
17. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy
17.1 If you:
(a) have a query or concern about this Privacy Policy or our Personal Information handling processes;
(b) wish to make a complaint in relation to a breach of your privacy;
(c) would like to access your Personal Information held by us;
(d) would like to update or correct your Personal Information held by us; or
(e) would like to opt out of direct marketing,
please contact us in any of the following ways:
Email Address: legal@some.place; or
Mailing Address: 34 Glenayr Avenue, North Bondi, NSW 2026, Australia.
Mailing Address: 34 Glenayr Avenue, North Bondi, NSW 2026, Australia.