Privacy Policy

TrueVaultPty Ltd ACN675 835 966(‘TrueVault’,‘we’,‘us’or‘our’)is committed to protecting the privacy of your personal information. Personalinformation is information that identifies you or information bywhich your identity can reasonably be ascertained and may include anopinion about you (Personal Information).  Wecollect, use, store, manage and disclose all Personal Information inaccordance with this Privacy Policy and otherwise with the AustralianPrivacy Principles set out in the Privacy Act 1988 (Cth)(Privacy Act).  

About this Privacy Policy

This Privacy Policy explains how we collect, use, manage and disclose Personal Information and how you can contact us if you have queries about our management of your Personal Information.
This Privacy Policy applies to all Personal Information submitted to or collected by us through the use of our services including our website (at www.truevault.com.au), TrueVault application or social media sites, or where you otherwise contact or interact with us through other forms of communication.
By submitting personal information to us (including via our website, the TrueVault application or social media sites or using our services), you accept the terms of this Privacy Policy, and consent to our use, collection, disclosure and retention of Personal Information as described in this Privacy Policy.  
If you do not agree to any provisions in this Privacy Policy, you should not disclose any Personal information to us.
You are view this Privacy Policy at any time at www.truevault.com.au.
Please note that this Privacy Policy may be updated or revised from time to time without notice and changes will apply immediately. Changes to this Privacy Policy will be published by posting an updated Privacy Policy on our website. Therefore, you should review our Privacy Policy regularly to ensure you are familiar with any changes.  
If you do not agree with the changes to our Privacy Policy, please notify us immediately in writing. Unless we hear from you, or if you continue to use our services, website or social media sites, you are taken to have accepted the changes to our Privacy Policy.This Privacy Policy was last updated on 28 April 2025.

What kind of Personal Information do we collect and hold?

General

As part of offering our services to you, we are required to collect Personal Information about you. In addition, you will need to create a user account as a registered user to use our services. The Personal Information we collect may include:

• your first and last names
• your phone number
• addresses, present and past
• email address
• copies of your identity documents including driver’s licence, passport, change of name documentation, proof of age card, police officer identity card, government cards and marriage certificate or divorce papers
• government or bank correspondence
• any other Personal Information you may provide to us from time to time

In addition, we will collect demographic information such as:

• your gender
• your age
• your marital status
• your date of birth

We may also collect sensitive information, including biometric and health information, such as:

• your signature
• an electronic copy of your face (to verify your identity)
• any photos or biometric information that is captured as a result of using our services
• professional or political or religious affiliations or memberships in respect of any correspondence provided
• sexual orientation in relation to any marriage certificate provided
• your organ donor status insofar as it is included on your identification documents

We will also collect other information, some of which may be personal information, including information about your order or service history with TrueVault, which areas of the site you visit (see the section “cookies”, below) and records of your communications and interactions with us.

In all cases, the personal information that we collect will depend on the nature of your interaction with us and will only be information necessary for one of our functions and activities. Our functions include:

• providing credentialing or verification services to you, or your business or customers
• Biometric verification
• details of the services you have purchased, considered or enquired about, together with any additional information necessary to deliver those services and respond to your queries
• payment information such as name, account number and payment card details for payments processed by us or third party payment gateway
• any additional information relating to you that you provide to us directly or indirectly through our representatives or our website or social media sites, including via customer surveys or user feedback

Sensitive Information

We collect “sensitive information” as defined by the Privacy Act (such as information about health information, ethnic origin, and biometric information) from you.
By voluntarily submitting sensitive information to us, you consent to our collection of such sensitive information which we will only use or disclose such information:

• for the primary purpose for which it was provided, or another directly related purpose;
• you consent to the disclosure; or
• as allowed by law.

How do we collect Personal Information?

Personal Information

We may collect Personal Information through different avenues, including when you:

• for the primary purpose for create a user account with us as a registered user on our website or through the TrueVault application; it was provided, or another directly related purpose;
• telephone, email or online communicate with one of our representatives; or
• access or use our website, application or social media sites.

We may also collect Personal Information about you from a third party (e.g. third party business customer and social media platforms).

Choosing not to Disclose Personal Information

You have the option of not disclosing Personal Information to us or to use a pseudonym when dealing with us in relation to a particular matter. If you choose to withhold any Personal Information, we may not be able to provide you with part of, or all of our services, or resolve a particular matter raised by you. Given that the TrueVault services and product is largely reliant on the disclosure of your Personal Information to us, we will not be able to provide you with credentials if you do not provide your Personal Information including sensitive information in the form of biometric face recognition for the primary purpose of our service.

When you Browse our Website

When you only browse our website, we do not collect your Personal Information until you have created a user account with us as a registered user. Our internet service provider or we may make a record of your visit and record your email address (if provided) and other non-personal information such as your server address; your internet protocol address; the pages you accessed and documents downloaded; the previous site you visited; and the type of browser being used. The non-personal information assists us to analyse web traffic and improve your site navigation experience.
We do not identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant or other such power to inspect the internet service provider's logs.

Cookies

We may also obtain anonymous information from our website using a technology called “cookies”. Cookies are small text files that are placed on your computer, tablet, or mobile device when you visit a website. They are widely used to enhance your browsing experience, remember your preferences, and collect information about how you interact with websites.  
We use the following cookies:

• Necessary Cookies: These cookies are essential for the proper functioning of our website. They enable you to navigate our site and use its features, such as accessing secure areas.
• Analytical Cookies: We use analytical cookies to gather information about how visitors use our website. This data helps us improve our website's performance and user experience. These cookies do not collect personally identifiable information.
• Third-Party Cookies: Some of our pages may display content from third-party websites, such as social media sharing buttons. These third-party sites may use their own cookies, and we do not have control over their cookie policies or how their cookies operate.

If you wish, you can disable your web browser from accepting cookies.

Other Social Platforms

There may also be occasions when we collect Personal Information (to the extent it is available) from social media platforms such as Facebook, Twitter, Instagram and LinkedIn. If you engage or contact us on one of our social media platforms or otherwise direct us to communicate or engage with you via social media, you agree to allow us to receive information (which may include Personal Information) from our social media platforms.  You also allow us to receive information about your visits and interaction with the sites and services of any of our third party partners that include our cookies and similar technologies unless you opt out.  

In addition to cookies, we use the Facebook Pixel, a tracking tool provided by Facebook, Inc. When you visit our website, the Facebook Pixel may collect data that allows us to track the effectiveness of our Facebook advertising campaigns. This data may include information such as the pages you visit on our website and your interaction with our content.

How we use your Personal Information

General

We may use the Personal Information you provide to us for the purposes for which it was initially collected or purposes related to such initial purpose (if such purpose would be within your reasonable expectations). We may use the Personal Information you provide to us to:

• provide you with services you have requested from us;
• for proof of identity, and credentialing purposes;
• to allow third parties you have agreed to have access to the information for the purposes of verifying the contents;
• to allow third parties you have agreed to have access to the information for the purposes of verifying the contents;
• to check and verify that the information you have provided, and the personal information located from other sources is correct;
• respond to your queries and requests, to resolve complaints and to respond to social media;
• keep a record of our dealings with you and enable us to contact you when necessary;
• promote relevant services which may be of interest to you via direct marketing or tailored advertising;
• to improve our internal processes;
• to improve our systems; and
• for any purpose that is reasonably necessary or directly related to these purposes, and that would reasonably be expected by you.

We may also use your Personal Information for purposes authorised by laws or regulations, such as to prevent or investigate alleged crime or fraud.

Text message updates

By supplying us with your Personal Information, you give us permission to use your Personal Information to contact you to provide you with updates regarding the services you have requested from us and other update relevant to TrueVault website or application operations. You can choose to opt out of such updates in the future by contacting us using the contact information provided in this Privacy Policy.

Direct Marketing

By supplying us with your Personal Information, you give us permission to use your Personal Information to contact you to inform you about services we think would be of particular interest to you, including from other businesses operated by or related to us. This may include contacting you through direct marketing, or social media. This permission is not limited in time unless you choose to opt out by contacting us using the contact information provided in this Privacy Policy, or by utilising an ‘unsubscribe’ facility on a communication we send to you, in which case we will take steps to ensure you do not receive any such direct marketing information in future.

How your Personal Information may be Disclosed

Third-parties

We may disclose your Personal Information to organisations that carry out functions on our behalf, or assist us to deliver our services, such as our business associates, contractors, agents or service providers.  These third parties may change from time to time.  Some examples include:

• the services of an Australian payment processor may be engaged for the purpose of collecting the payments for our services. In order to process your payment, we need to disclose some of your personal details like your name, surname, email and IP address to the processor
• the services of a hosting cloud provider to store your data securely in a data centre located in Australia
• disclosure of your personal information to our document verification service providers, on a strict ‘need to know’ basis, in order to verify your identity. We use a document verification service provider to match the information you provided to us against several sources such as government databases and document issuers for the purpose of confirming your identity and verifying the authenticity of the documents provided to us
• the services of an Australian third-party document verification service provider to determine to determine the authenticity of your identity documents in order to ensure that your proof of identity requirements are met as efficiently as possible.
• technology service providers, such as internet service providers, database management services, data storage providers, website hosting companies, website developers and digital mail providers who send communications on our behalf
• sponsors or organisations that partner with us
• our professional advisers, accountants, lawyers and auditors
• You agree that third parties which receive Personal Information from us may use and disclose the Personal Information subject to their respective privacy policies. We endeavour to take reasonable steps to enter into agreements with third parties that collect, store, disclose and retain Personal Information in accordance with the Australian Privacy Principles, except as otherwise required by law.

Statistical Data

From time to time, we may provide third parties with information in the form of statistical representations about our users collectively and for the purpose of statistical analysis. Where we provide such information to third parties for this limited statistical purpose, we will not provide Personal Information in such a way that your identity may be obtained.

Permitted Disclosures by Law

We may also release your Personal Information under the following circumstances:

• when required to do so by a court or under applicable laws or regulation (for example, a subpoena) or where requested by a government agency;
• where we consider a company or an individual may be engaged in fraudulent activity or other deceptive practices that a governmental agency should be made aware of; or
• to appropriate persons, where your communication suggests possible harm to others.

International Disclosures

We do not generally transfer Personal Information outside of Australia. No personal data gathered for the purpose of the service will be stored outside Australia.

We consider confidentiality of Personal Information collected from you to be of utmost importance. All information stored electronically is either password protected and/or encrypted.

To prevent unauthorised access to, disclosure, misuse or loss of, or interference with, your Personal Information, we have implemented a number of procedures to safeguard the security and confidentiality of your information including:

• instructing our staff and advisers who handle personal information to respect the confidentiality of user information and the privacy of individuals
• encrypting data packets, implementing secure authentication and authorisation procedures (including passwords and controls) and installing equipment to safeguard your information
• implementing procedures and installing equipment to safeguard your information
• continually reviewing privacy procedures and arrangements to ensure we are doing all that we can reasonably and technically feasible at the time
• dedicated privacy, information security, and ICT roles across our team members
• physical (hard copy, media and soft copy) security by preventing unauthorised access to our premises
• computer network security including password security to prevent unauthorised access
• incident prevention and management reporting structures
• strong password policies, including use of two-factor authentication and password managers to adopt best practices
• communication security
• capturing IP addresses
• capturing payment information
• verification of ID, linking the ID with your photo that may incrementally capture an image of you via the camera on a smartphone, tablet or web cam used to compare it against your photo ID
• signatures

Unfortunately, since no system is 100% secure or error-free, we cannot guarantee that your Personal Information is totally protected, for example, from hackers or misuse.  Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your Personal Information due to unauthorised third party access, errors in transmission or other causes beyond our control.  

If you enter or upload Personal Information on our website or application, you should exercise due care to safeguard any passwords and usernames created by you.

We will take reasonable steps to destroy or permanently de-identify any Personal Information from our records and systems which is no longer required by us. We may retain your Personal Information even after you have completed your transactions with us if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud or abuse or enforce this Privacy Policy and our terms and conditions. We may retain Personal Information for a limited period of time, if requested by law.

How to access and amend Personal Information you provide

We strive to keep your Personal Information accurate, up to date and complete.  Our policy enables you to find out what information we hold about you and correct that information if it is wrong.

If you become aware that any Personal Information we hold about you is incorrect or out of date, you may correct the Personal Information by logging into your customer account.  Otherwise, please let us know immediately. We will be happy to accept updated Personal Information in writing from the owner of that information at any time.  In order to protect your privacy and security, we will take reasonable steps to verify your identity before granting you access or enabling you to make corrections of your Personal Information.  Except where the Privacy Act provides otherwise, we reserve the right to recover any reasonable costs involved in providing extensive access to Personal Information, for example the cost of supplying information held in archives.

Our objective is to respond to any request to access personal information within a reasonable timeframe and no later than 30 days.  We will endeavour to inform you if this timeframe is not achievable.

In some circumstances, we may not be in a position to grant access to your Personal Information, such circumstances include where:

• providing access is likely to pose a serious threat to the safety of an individual or the public
• providing access is likely to unreasonably impact on the privacy of others
• the request for access is frivolous or vexatious
• providing access would reveal information which relates to existing or anticipated legal proceedings or otherwise impact on any negotiations
• providing access is unlawful (including being unlawful as directed by a court or tribunal order) or is likely to impact on actions being taken in relation to alleged unlawful activities relating to our functions and activities
• granting access would impact on a commercially sensitive decision-making process

Contact Us

If you have any questions about our Privacy Policy, or have a problem or complaint, please let us know. We will make all efforts possible to investigate your complaint within [20] days and advise you of the outcome as soon as possible within [40] days of you making the complaint.  When this is not possible, we will endeavour to contact you within that time to let you know how long it will take to resolve the complaint.

Our contact details are:

Privacy Officer

TrueVault Pty Ltd ACN 675 835 966
E-mail: SUPPORT@TRUEVAULT.COM.AU

If you believe we have not adequately dealt with your complaint, you may complain to the Privacy Commissioner, whose contact details are found on their website http://www.oaic.gov.au/.