Privacy Policy

1. We respect your privacy

Welcome to RipeGlobal. This privacy policy (Policy) sets out how we (RipeGlobal Group Pty Ltd ACN 640 122 425 and each of our associated entities) collect, store and use your personal information when you interact with us in relation to the online dental education content and training we provide (Services).

The terms of this Policy will apply whether you access our Services through our website located at <www.ripeglobal.com> (Website) (or any other website that we operate from time to time), or through a software application that we have made available to download to your mobile phone, smart television or other analogous device (App).

We respect your right to privacy, and we are committed to safeguarding the privacy of the personal information that you provide to us. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).

2. Contact        

1. General Contact Information

If you wish to contact us regarding any of the matters covered in this Policy, or otherwise in respect of your personal information, please contact us using the following details:

Online Support Form: https://www.ripeglobal.com/contact-us

Email: support@ripeglobal.com

Telephone: 1300 436 033

Post: Shop 8, 14 See St, Bargara, Queensland, 4670

Privacy Officer: Cam Harris - Executive Managing Director

Privacy Issues Email: privacy@ripeglobal.com

2. European Union

Mindaugas Kudelis has been appointed as our EU Representative for privacy related matters.

In addition to contacting us using our general contact information, if you are based in the European Union, you can also contact our EU Representative with any privacy enquiries. The best way to contact our EU Representative is via the following email address:

privacy@ripeglobal.com 

 

3. Anonymity

Due to the nature of the Services it is impractical for us to deal with you without knowing your name. When you request any of our Services or register an account to allow you to access our Services (Ripe Global Account) you will be required to identify yourself and use truthful and accurate information.

4. Basis for collection

We collect your personal information for numerous reasons when we interact with you.This includes collecting your personal information for the following reasons:

1. Delivery of Contractual Services

Where you are accessing our Services we will need to collect your personal information in order to:

1. allow you to create a Ripe Global Account;
2. enter into our services agreement, entitled ‘Terms of Use’ with you; and
3. perform our obligations under that agreement.

2. Legitimate Business Purposes

We may also collect and use your personal information where we consider:

4. you will not be detrimentally impacted by our collection and use of that information;
5. our collection and use is limited to what you would reasonably expect in view of the Services we provide; and
6. it is necessary to fulfil our legitimate business interests.

This may include, for example, use of your personal information to improve our Services or any App through which our Services are provided.

3. Legal compliance 

There are certain situations in which we may be required to deal with or disclose your personal information in order to comply with the law or regulations that have been imposed by a supervisory authority. For example, if we are subject to an order of the court.

4. Consent

In some circumstances we may request your explicit consent to certain uses of your personal information. For example, where you are based in the European Union, we request your explicit consent to transfer your personal information to our servers located outside of the European Union. Where we do so, we will provide an explanation of why we are requesting such consent. We will also provide you with information on how your consent can be withdrawn at any time.

You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

5. What personal information is collected

1. We may collect basic information such as your name, phone number, dental skills and experience, address, financial and billing information (including credit card details) and email address to enable us to transact and communicate with you and to provide you with our Services.
2. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys or promotions or communicate with our customer support.
3. Additionally, we may also collect any other information you provide while interacting with us.

6. How we collect your personal information

1. General

Whenever you (including non-member users) visit our Website, our servers automatically record information for statistical purposes about your usage such as:

1. type of browser used;
2. referring URL;
3. IP address;
4. number and type of pages/content viewed along with viewing duration;
5. date and time of visits; and
6. the exit URL.

We also collect similar usage information about you when you access our Services through our App. We do not collect information from your device regarding other activities that you undertake on that advice.

 

If you have not identified yourself by registering as a member or logging on as a member, we will not link a record of your usage of our Website or App to you personally, such data would be anonymous.

2. Cookies and other tracking technologies

To improve your experience, we may use cookies and other tracking technologies, such as pixel tags, web beacons, device IDs, or advertising IDs. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, please note that if you do this, you may not be able to use the full functionality of our Website or the Services.

Our Website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage.

You can customize or opt out of Google Analytics using the Ads Settings for your Google account.

Our Website uses cookies and other tracking technologies to support Google Analytics for:

4. Google Marketing Platform integrations;
5. Demographic and Interest Reporting;
6. Display Advertising including Remarketing and Google Display Network Impression Reporting to advertise our services online;
7. optimizing and personalizing ad services based on your past visits to our Website; and
8. reporting the use of ad services and interactions with ad impressions and how they are related to visits to our site.

Cookies and other tracking technologies may also be used to support analytics by other third parties.

7. Third party interactions

1. General

We may allow third parties, including authorized service providers, advertising companies, data management platforms, and ad networks to serve advertisements on our Website or through our App.

These companies may use tracking technologies (such as cookies, pixel tags, web beacons, device IDs, or advertising IDs) to collect information about users who view or interact with their advertisements. Any information that these third parties collect via cookies should be completely anonymous and is non-identifiable. You may refuse the use of third party data collection by selecting the appropriate settings on your browser or by switching off your profile.

You may also have the capability through our Services to access third party websites that do not operate under this Policy and that we do not control. Such websites may collect your personal information and we recommend that you consult the privacy statements of all third parties with which you interact.

2. Social media

Our Services may interface with social media sites such as Facebook, Twitter, YouTube, Instagram, Pinterest, Weibo and others. If you choose to "like" or "share" information through these services, you should review the privacy policy of the relevant service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to our Website with other Personal Information.

8. How we use your personal information

We will use personal information collected from you to provide you with information about our Services and to deliver our Services to you. This includes using your personal information to:

9. offer products and services to you during the usual course of our business activities;
10. administer our business activities;
11. manage, research and develop our Services;
12. provide you with information about our Services;
13. make you aware of new and additional products, services and opportunities available to you;
14. communicate with you by a variety of measures including, but not limited to, by phone, email, sms or mail;
15. our internal research and statistical purposes (including market segmentation and customer value analysis);
16. enabling us to forward to you other information or material which we believe may be of interest to you;
17. enabling a payment processor to process payments that you make to us; and
18. any other purpose specified in our Terms of Use.

If you withhold your personal information, it may not be possible for us to provide you with our Services, or for your to fully use our Website or Apps.

9. Disclosure of your personal information

1. General

1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.
2. If we do disclose your personal information to a third party, we will protect it in accordance with this Policy.
3. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law, our user databases, together with any personal information and non-personal information contained in those databases.

2. Unsolicited information

If we collect personal information which we have not sought or requested about you, and if we determine we are legally permitted to collect that information, we will deal with that information in accordance with the terms of this Privacy Policy. In all other circumstances, we will destroy or de-identify the relevant personal information as soon as practicable, where it is lawful and reasonable to do so.

10. Hosting and International Data Transfers

1. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to Australia and the USA. Where you are based in the European Union, our transfer of your personal information may include the transfer or personal information to a country that is not the subject of an adequacy ruling for the European Commission.
2. We and our associated entities have physical facilities, as well as hosting facilities, in Australia and the USA. We also use suppliers and contractors that may be situated in Australia and the USA. Transfers of personal information to each of these countries will be protected by appropriate safeguards, which may include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; or the use of binding corporate rules, a copy of which you can obtain from us upon request.
3. However, notwithstanding the above, by providing us with your personal information, you are explicitly consenting to the international transfer and processing of your personal information in accordance with this Policy, in full and informed knowledge of the risks associated with such transfers and processing in countries such as Australia and the USA, which may not have been subject to an adequacy decision by the European Commission.
4. You also acknowledge that personal information that you submit for publication through our Services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

11. Security of your personal information

1. 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.
2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
3. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us or receive from us.  Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Policy.

12. Access to your personal information

1. Access to Personal Data

We will provide you with access upon request to the personal information held by us in relation to you except to the extent that:

4. giving access would be unlawful; or
5. denying access is required or authorized by or under a relevant law, regulation or court order.

To request access to your personal data, please contact us using the details provided above.

Following your request, we will contact you within one (1) month from the date of receipt of your request and provide you with the personal information requested, unless we have determined that some reason or obligation exists requiring us to withhold access to that personal information.

2. Third party disclosure

We do not sell your personal information to any third parties. Unless specifically referred to in this Policy, we also do not disclose your personal information to any third parties for other business purposes. Notwithstanding this, you may at any time request that we provide confirmation that your personal information has not been sold to a third party, or to request details of any third party to which information has been sold or disclosed for business purposes.

3. Data portability

Insofar as it does not adversely affect the rights and freedoms of others and where you have communicated a request to us:

6. where we have employed an automated means to process your personal information, we will provide you with a copy of such personal information in a structured, commonly used and machine-readable format; and
7. after receiving your request, where technically feasible, we will transmit your personal information directly to another party.

4. Commercially sensitive information

If providing you access to your personal information would reveal commercially sensitive information, we are unable to give you access to that information. However, we will provide you with the reasoning behind our determination.

5. Use of intermediaries

Where we cannot directly provide you with access to your personal information we may, if it is reasonable, engage the services of a third party intermediary to do so.

6. Correction and erasure of Personal Data

It is your responsibility to ensure that the information you provide to us is accurate and to update your personal information as necessary. If for any reason you are unable to correct any personal information held by us yourself, please contact us using the details provided above.

If after receiving your request we choose not to correct your information, we will notify you within one (1) month of the reason of our refusal and the mechanisms available to you to object to our refusal.

If you wish to have your personal information erased, please communicate your request to us using the contact information provided above. The only circumstances in which we will not take steps to erase your personal information are where we need to keep it in accordance with another provision of this Policy, an applicable law or regulation or the order of a court or supervisory authority. However, our deleting of your personal information may result in the deletion of your Ripe Global Account which will mean you are unable to access our Services.

If we correct or erase personal information about you that we previously disclosed to a third party in accordance with our Policy, we will take reasonable steps to notify the third party of the correction or erasure and to request that they do the same.

7. Refusal to correct or erase

If at any time we refuse or deny you access to your personal information, or refuse to correct or erase your personal information, we will provide you with reasons why we are unable to comply with your request.

8. Restriction of processing

You may request that we limit or restrict the manner in which we deal with and process your personal information, in which case we will only process your personal information: with your consent; for the establishment, exercise or defence of legal claims against us; or for the protection of the rights of another person.

9. Costs

Access to, erasure and rectification of your personal information, including any communications related thereto, will generally be provided free of charge.

Where your requests are manifestly unfounded or excessive in nature (particularly due to repetitiveness) we may charge you a reasonable fee for providing the information or communication, or taking the action requested. Where your requests are manifestly unfounded or excessive in nature we may also refuse your request.

10. Specific objection rights

If it becomes necessary for us to deal with your personal information without your consent for reasons of:

8. performing a task in the public interest;
9. the exercise of an official authority that has been vested in us; or
10. where it is in our legitimate interests or the legitimate interests of a third party to do so;

you will have the right to object to such use.

If you object to our use of your personal information we will refrain from using your personal information unless compelling legitimate grounds exist for us to use that information, or for the establishment, exercise or defence of legal claims.

If we have collected your personal information in accordance with this Policy and elect to use it for the purposes of direct marketing (to which you consent), you have the right to object at any time to such use. Upon receiving an objection we will, as soon as is reasonably practical, cease using your personal information for the purposes of direct marketing.

11. Identification

Before taking any of the actions referred to above in regard to your personal information, we may ask you to verify your identity.

13. Destruction of Personal Data

We will keep your personal information only for as long as we need it for legitimate business purposes and as required by applicable law. We will take reasonable steps to erase any personal information that we hold about you where:

11. we no longer need the personal information for the purposes for which it was collected and we are not otherwise entitled to retain such data; and
12. we are not required or obligated by law, regulation or court order to retain the information.

If certain information has been provided to third parties in accordance with this Policy, retention of that information will be subject to the policies of the relevant third party.

14. Complaints about privacy

1. Making a complaint

If you believe that we have used or disclosed your personal information in a manner which is contrary to this Policy or that otherwise breaches an applicable law, then please contact us using the contact information provided above.

If you are based in the European Union and have a complaint or enquiry regarding your personal information, you may also contact our European Representative using the contact information contained detailed above.

You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. If you are unsure who your relevant supervisory authority may be, please contact us so that we may provide you with assistance.

2. Our response

Within 30 days of receipt of your complaint we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response.

15. Changes to Privacy Policy

Please be aware that we may change this Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our Website or through our App. Please check back from time to time to review our Policy.

Last updated 17.07.2020