Privacy Policy

This privacy policy ("Policy") describes how Brontech's bronID ("bronID" "Company", "we", "our", "us") collects, uses, shares, and stores personal information of users of this website, https://www.bron.tech/bronID/ (the "Site") and the Services (as defined below). This Policy applies to the Site, applications, mobile apps, products and services (collectively, "Services") on or in which it is posted, linked, or referenced.

By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy.  If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects for our legal bases for processing and transfer of your data.

1       Collection of personal information

We get information about you in a range of ways.

We collect information when You use the Website or the App.

For example:

a.  we collect Personal Information such as Your name and address from You when You use the bronID Service;

b.    we may collect information from an ID Document which You use to authenticate Your identity;

c.   when You use the bronID Service to verify Your identity for an Organisation, we collect information about this process;

d.    blockchain public address (unique identifier);

e.  private key signature associated with your Digital Identity Profile (as defined in the Terms of Use) for transactions you engage in with the Services;

f.      information about the Device;

g.    physical location, operating system, settings and security protocols;

h.   feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support or otherwise correspond with us;

i.   transaction information, such as metadata with respect to on-chain transaction history,  details about purchases you make through the Service and billing details;

j.    anonymized usage information, such as information about how you use the Service and interact with us; and

k.   marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;

 

Information We Get From Others.

We may get information about you from other third party sources and we may add this to the information we get from your use of the Services:

a.  Where You have consented to have Your identity checked for an Organisation, we provide to the Organisation some Personal Information that has been checked, which may include Your name, address and date of birth, and whether a match has been confirmed by government ID Verifiers. We do not provide to the Organisation copies of ID Documents, identification numbers used on ID Documents, or details of the authentication sources used to check Your identity, unless we have Your express consent. If we reasonably believe that any information provided to an Organisation was or has become incorrect, misleading or out-of-date, we may inform the Organisation and provide corrections or details of our concerns. You should check the privacy policy for each Organisation before You agree for us to provide the Organisation with information about Your identity.

 

Information Automatically Collected. We may automatically record certain information about how you use our Site (we refer to this information as "Log Data"). Log Data may include information such as a user's Internet Protocol (IP) address, hash of IPFS address, device and browser type, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked on or used, referral url, and other statistics. We use this information to administer the Service and we analyse (and may engage third parties to analyse) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users' needs and preferences.

We may use cookies or similar technologies to analyse trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

We also use data analytics services such as Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics' use of your personal data here: https://www.google.com/analytics/terms/us.html.

2       Storage of personal information

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, biometrics, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

a.  we may store some information, including Your name, date of birth and address, and ID Document numbers, in an encrypted form and will only use or share them with Your express consent in connection with Your future use of bronID Services;

b.  we may also store other Personal Information, information about the types of ID Document You have checked with bronID, and information collected from ID Verifiers for Your future use of the bronID Services;

c.    we may disclose information we have collected about You in connection with the bronID Services (including Personal Information) to the App Provider for the purposes of the bronID Services it provides;

d.    the App Provider may collect and disclose to us information (including Personal Information) about You in order to facilitate the bronID Service;

e.   some information may be stored on Your Device, Your personal cloud or our servers (for example, Your name and photo are stored so these can be displayed in the App to personalise Your experience).

3       Use of personal information

We will use your personal information in the following ways:

a.    To enable you to access and use the Services

b.    To provide and deliver products and services that you may request.

c.   To send information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.

d.    To comply with law

e.   We use your personal information as we believe necessary or appropriate to comply with applicable laws,  lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. 

f.    We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

g.    In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.

h.    We may use or share your personal information with your consent, such as when you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

i.      We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

4       Sharing of personal information

We disclose personal information to third parties under the following circumstances:

a.  We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

b.    We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

c.     We may share personal information for legal, protection, and safety purposes.

d.   We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, auditors, and insurers.

e.   We will disclose Your information to some other third party ID Verifiers to assist in the administration of the bronID Service and in order to verify Your details, and may collect some Personal Information from them.

f.   Your information will be shared to check Your identity for an Organisation only with Your specific consent. You may give the consent to us through the bronID Service via the Website or the App, or directly to the Organisation. If You do not use the bronID Service to check Your identity to any Organisation for an extended period, the information stored in Your Profile may be deleted.

5       Overseas use and disclosure

We may transfer personal information to countries outside Australia (for example when we need to verify your identity attributes with an overseas data registry or you are using the bronID service to onboard overseas partner services). We will only do so in compliance with all applicable Australian data protection and privacy laws and only with your explicit consent for the purposes of providing you the Services. We will take reasonable steps to protect personal information no matter what country it is transferred to.

For the purposes of providing the Services we may transfer your personal information in other countries as follows:

European Union, New Zealand, United States, Canada, Singapore, South Korea and Japan.

6       Cookies

We use "cookies" on our Site, that you can accept if you choose to use our Site. We use "cookies" in many ways. "Cookies" help us to improve the offered services and make use of our services more convenient. We collect data on how users interact with our website and / or application. In addition, we collect information from your computer or device, such as the IP address, browser you are using, and language settings. Information about how the user uses our web pages and applications is used for statistical purposes to improve our web pages and applications, and to display custom content for the customer. If you prefer that your personal data will not be processed on our website, you can activate the private browsing feature of Your web browser. This is your choice.

7       Your rights

You may ask us to take the following actions in relation to your personal information that we hold:

You can submit these requests by email to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected].
Any complaints will be reviewed and we endeavour to resolve your complaints within 30 days of the date on which you notify us. You may take unresolved complaints to the Office of the Australian Information Commissioner (www.oaic.gov.au) by filling in this form or contacting the OAIC at [email protected].

8       International Users

By using the Services, bronID will transfer data to Australia. By choosing to visit or utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of New South Wales and the adjudication of any disputes arising in connection with bronID or the Services will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Australia. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.

9       Changes to the Privacy Policy

We may change this privacy policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the the Site or Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

10       Contact Us

If you have any questions about this Privacy Policy, the practices of the service, this site, or your dealings with this site, please contact us at: [email protected]. If you have a complaint in relation to personal information held by us, then please send an email to: [email protected]. Any complaints will be reviewed and we endeavour to resolve your complaint within 30 days of the date on which you notify us. Unresolved complaints may be taken to the Office of the Australian Information Commissioner (www.oaic.gov.au).

11       Complaints and further information on privacy

You can obtain further general information about your privacy rights and Commonwealth privacy law or submit a complaint by contacting the Office of the Australian Information Commissioner by: