This Privacy Policy explains how Nooriam Group (which includes Nooriam Pty Ltd (ACN 654 246 509) and its affiliates, including Nooriam Sarjana Pty Ltd (ACN 666 673 623) and Nooriam Alfareria Pty Ltd (ACN 666 513 515)) (“Nooriam“, also “we” and “us“) collect, use, disclose and manage the privacy of information within the Nooriam ecosystem, including this website, the MemoryBinder application and any other services we provide.
We review this Privacy Policy regularly and may revise it from time to time to keep up to date with developments in our platform, products, services the law or technology practices. You may contact us in writing at info@nooriam.com for further information about this Privacy Policy.
By using this website, our platform or any of our products or services, completing forms or communicating with us, you acknowledge and agree to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.
What Personal Information is Collected
We may collect the personal information you provide to us including:
your name and name prefix or title;
your contact details (such as your postal address, email address and phone numbers);
your location, nationality, gender, organisation, business interests, passport, drivers’ licence, employment, positions held, occupation, date of birth, personal interests and other information. This information may include special categories of data (such as race and ethnicity, biometrical data, information about health, political opinions or religious beliefs);
personal information from communications you have with us such as enquiries, support requests or feedback;
billing and financial information (such as billing address, bank account, credit card details and payment information);
unique Nooriam identifiers such as your Nooriam username and password;
information for your Nooriam user profile, such as your profile picture or bio;
personal information you upload to the Nooriam platform. This information may include special categories of data (such as race and ethnicity, biometrical data, information about health, political opinions or religious beliefs);
additional personal information that you provide to us by submitting forms or questionnaires or through your use of our platform, products and services, associated applications and any associated social media platforms.
You are not obligated to provide personal information. However, failure to do so may result in Nooriam being unable to facilitate or provide you with certain products or services.
We may collect personal information about you from our systems including:
electronic information about or from your browser or mobile device about your activity on our website or your interactions with our platform such as dates/times when you visit, inferred location information, details of visits made to our online services, logs (including, the IP address and location of your device and other identifiers about the device and the nature of the visit), resources accessed and your connections and interactions with other Nooriam customers; and
your Nooriam account number.
We may collect personal information about you from third parties including:
regulatory authorities;
identity verification service providers;
your employer, including where your employer is a customer or a counterparty or otherwise transmits information to Nooriam;
government agencies;
credit reporting agencies;
information or service providers;
publicly available records;
social media account providers;
bank, credit or debit card provider or our third party payment processor such as bank account numbers, expiration date, and cardholder or account holder name or other payment details;
other Nooriam customers;
recruitment agencies;
other organisations with whom you have dealings;
other third parties as set out or implied in this Privacy Policy.
We will work to retain your personal information only so long as reasonably necessary. Personal information provided in connection with the provision of our services will be retained in accordance with the Nooriam’s policies unless we agree otherwise with you, in writing. If you wish to know more, please contact us.
If you provide any personal information about another person, you acknowledge that you have obtained their consent to do so.
We may also obtain personal information about you from legitimate third party sources including, referral agents, our customers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.
Use of Your Information
We may use your personal information as follows:
to perform our contract with you or to perform our contract with an entity through whom you access our platform, products or services such as your employer or a contractual counterparty;
to provide the information, products, data and services that you have requested, respond to your enquiries, create and maintain your Nooriam account;
to verify your identity and conduct searches on you in connection with our business processes;
to process transactions, send receipts, and update you about changes to your subscriptions or use of our platform, services and products;
to maintain and develop our relationship with you and our customers and their counterparties;
to personalise and customise the services, experience, advertising and content that you view and engage with on the Nooriam website and Nooriam platform;
to provide, improve and develop and train our platform, products and services;
to keep you informed about Nooriam products and services and identify products or services you may be interested in;
to enable your registration and attendance at one of our events such as an information webinar or Nooriam training event;
to send publications and other informational, educational, or marketing emails to you when you are entered onto our mailing lists;
to obtain opinions or comments about products and/or services and to conduct other research and development;
to improve our services and products including auditing and monitoring the use of those services and products;
to administer, monitor and analyse our own business or facilitate our business operations;
to compile statistical data for marketing analysis and to conduct market research;
where applicable, to undertake recruitment for Nooriam and to manage your employment or contractual engagement with Nooriam;
to pursue a legitimate interest of Nooriam which is not overridden by your rights;
to fulfil our legal, regulatory, accounting, reporting, risk management or professional obligations;
to protect, establish, exercise or defend legal rights;
otherwise required or authorised by law (for example, for a fraud detection purpose); and
with your consent.
Information Disclosure
We may share your information with:
Nooriam affiliates, Nooriam promotional partners, Nooriam customers and other trusted third parties (and their directors, personnel and agents) either in Australia or overseas;
your lawyers, agents, contractors and service providers;
third party service providers for the purpose of enabling them to provide their services to us, including (without limitation) vendors who help us with fraud prevention, identify verification and fee collection services, payment networks, financial instituations, professional advisors, data storage, web-hosting and server providers, maintenance providers, marketing providers and advertising providers;
third parties involved in the provision of products or services to our customers;
our professional advisers, auditors and insurers;
third party service providers to whom we outsource services, for example archival, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), IT support, mailing house, delivery, website, social media, research, banking, payment, client contact, data processing, insurance, forensic, litigation support, data room, marketing and security services;
third party technology organisations, including cloud service providers, such as data storage platforms;
third parties with whom we have co-promotional arrangements (such as jointly sponsored events);
third parties who carry out research and analyses of our services and products on our behalf;
third parties Nooriam is considering entering into transactions with such as a merger, acquisition, sale of equity or similar transaction; and
regulatory authorities, courts, tribunals, government agencies, law enforcement agencies and other third parties.
We may also share de-identified or aggregated data with researchers, potential customers, investors and to entities Nooriam is considering entering into transactions with such as a merger, acquisition, sale of equity of similar transaction.
Some of your personal information may be stored with and managed by a cloud service provider located outside of Australia. Your personal information may be accessed by third parties whose laws provide various levels of protection for personal data which may be higher or lower than the level of protection stipulated in Australia. Where we transfer your information internationally, we will take reasonable steps to ensure that your information is treated securely and that the means of transfer provides adequate safeguards. If you have any questions in relation to the transfer of your personal information, please contact the Privacy Officer at info@nooriam.com
Security
We take reasonable steps to hold information securely and to prevent unauthorised access, modification or disclosure. We require our third party data storage providers to comply with appropriate industry standards. All personnel and third party providers with access to personal information are subject to confidentiality obligations.
The transmission of information via the Internet is never completely secure. We cannot guarantee the security of your data transmitted to our online services. By using our website, platform, products or services, you accept the inherent risks of transmission.
We cannot guarantee or accept liability for data theft or unauthorised access to your data. By visiting our website, using our platform, products or services or otherwise communicating with us you acknowledge that you understand and accept this exclusion of liability.
Cookies
Cookies are small text files that are stored on your device by the websites you visit. They are used in order to make websites work and to improve their efficiency, as well as to provide website usage information to the website owner.
This website may use “cookies”, where we do so, Nooriam enables and respects “Do Not Track” requests and will limit the cookies we use to the following:
Strictly necessary cookies to protect the Website against DDoS attacks.
Strictly necessary cookies to facilitate user logins and protect the Website against attempts to inject malicious code into registration forms.
Performance cookies to provide us with analytical information about the use of the website with your consent.
You can remove cookies from your browser and prevent new cookies from being placed on your device by going to the privacy settings of your browser. You can choose to block all cookies or only cookies from specific websites. Please note that blocking cookies will not automatically remove cookies that are already stored on your device.
Please be aware that by blocking and/or deleting cookies, this website (and possibly other websites) might not function properly. With every new session, new cookies will be placed unless you have blocked the use of cookies. If you choose to block cookies, but also want this website to function properly, please go to the privacy settings of your browser and ensure that it allows cookies from this website.
Our website may contain links to other sites controlled by third parties, which may also use cookies over which we have no control. We recommend that you check the relevant third party’s privacy policies for information about any cookies which may be used. Although we provide the links for informational or convenience purposes, we do not accept responsibility for their use of information about you.
Users Based in EU
If you are an individual residing in the EU, you may have additional rights under the General Data Protection Regulation, Regulation 2016/679 (GDPR) in relation to the handling of your Personal Data (as defined in Article 4 of the GDPR).
In providing our services to you, we may monitor your activity on our website using automated processes, including for the purposes of counting usage of our website and creating audience profiles. We do this to provide you with more tailored and relevant services.
In addition to other rights set out in this Privacy Policy, in certain circumstances you may:
request access to the Personal Data that we hold about you;
request a copy of the Personal Data that you have provided to us, in a structured electronic format;
request that we update your Personal Data if it is inaccurate or incomplete;
subject to any legal obligation we have, request that we delete your Personal Data (also known as ‘the right to be forgotten’);
object to the processing of your Personal Data;
retain and reuse your Personal Data for your own purposes;
object to your Personal Data being used; and
object to automated decision making and profiling.
Please contact us at any time to exercise your rights under the GDPR.
We may ask you to verify your identity before acting on any of your requests.
Where your Personal Data is transferred outside of the EEA, it will only be transferred to countries that have been identified as providing adequate protection for Personal Data, or to a third party where we have approved transfer mechanisms in place to protect your Personal Data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
Your Rights
The privacy laws of some jurisdictions may give you the right to access, amend or erase your personal information or, in some circumstances, to restrict or object to the processing of your personal information.
If you would like to request a copy of your data, or would like to take steps to exercise any of your rights please contact us by email at info@nooriam.com.
Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
Information we hold about you should be up-to-date and accurate. Please advise us in writing of any changes to your information.
Where relevant, you can withdraw your consent for us to send marketing, informational, and educational materials to you by contacting us at info@nooriam.com.
Contact and Further Information
It is important to us that you understand how your personal information is collected, stored, used, and disclosed. If you have any questions about this Privacy Policy, or want to submit a suggestion or complaint to us about how we handle your personal information, please contact us.
Please allow 30 days for any requests relating to this Privacy Policy to be processed. If you do not receive a satisfactory response from Nooriam to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page
