PRIVACY POLICY

LOGOJI PRIVACY POLICY

Introduction

Our website (www.logoji.com) (Site) and our mobile application (the Logoji App) are created, operated and controlled by Logoji Pty Ltd (ACN 671 335 934) (Logoji, our, us or we).

Logoji are committed to ensuring your Personal Information is protected. Logoji manages your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

By visiting or using our Site or downloading, accessing and using the Logoji App, you agree to this Privacy Policy.

This Privacy Policy outlines how Logoji collects, stores, processes, shares, uses and discloses your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

The information Logoji collects about you

Personal Information

Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.

Logoji collects and uses Personal Information and/or Non-Personal Information from visitors to our Site, from users of the Logoji App, and any other individual who interacts with us.

Logoji will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver our Site, make the Logoji App available to you, or as otherwise permitted by law.

The type of Personal Information and Non-Personal Information that Logoji collects and uses depends on the type of dealings that you have with Logoji.

Users

We collect and hold Non-Personal and/or Personal Information about users of the Logoji App. For example, the type of Non-Personal Information and/or Personal Information that we collect includes:

Apple ID;

marketing data and information relating to your dealings, or enquiries you have made, with us, including information about: (i) the Logoji App; (ii) Emoji Stickers you have used and the frequency of use of such Emoji Stickers; and (iii) the third party products and services you may have used or enquired about;

device information which is automatically collected from you when you visit and navigate through the Logoji App and/or Site. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Logoji App and/or Site, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Logoji App and/or Site and other usage statistics; and

other information that you provide to us or that we may collect in the course of our relationship with you.

Enterprises

We collect and hold Non-Personal and/or Personal Information about advertising partners or customers (Enterprises) that submit or publish their logos or trade marks (in emoji sticker form) (Emoji Stickers) on, or via, the Logoji App for users to access and use when messaging other persons on their mobile devices. For example, the type of Personal Information and Non-Personal Information that we collect includes:

an Enterprise’s details (for example, business name, ABN, ACN or other business/company identifiers and email address);

the contact details of the Enterprise’s authorised representatives (such as, full name, job title, business phone number and business email address );

an Enterprise’s trade mark or logo ownership and registration documents or licence agreement;

copies of an Enterprise’s trade mark or logos;

payment or billing details (for example, credit card and debit card);

information relating to your dealings, or enquiries you have made, with us in relation to our Site or the Logoji App; and

other information that you provide to us or that we may collect in the course of our relationship with you.

Other information

Logoji may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, Logoji may collect anonymous answers to surveys or aggregated information about how users or Enterprises use our Site or the Logoji App.

If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.

Sensitive Information

We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.

If you have accidentally sent us Sensitive Information, please contact us using the details

How Logoji collects Personal Information

Direct collection from you

We will collect Personal Information and/or Non-Personal Information about you in a number of different ways. We may collect Personal Information and/or Non-Personal Information directly from you or in the course of our dealings with you. For example:

in the case of users, when you download, access, and use the Logoji App (including when you use Emoji Stickers);

in the case of Enterprises, when you:

access and use our Site (including when you open an enterprise account or create or update your enterprise account on, or, via, our Site);

publish or submit your logo or trade mark through our Site for use on the Logoji App as an emoji sticker;

contact or correspond with us via email or telephone or when you submit a query in relation to your logo or trade mark (or Emoji Stickers) or the Logoji App;

when you visit our Site or submit information through our Site (including on, or via, our related social media accounts), contact us, or complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires;

when you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint about another user or Enterprise; and

when otherwise legally authorised or required to do so.

When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.

By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

Collection from third parties
- We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:
  - when you provide your Personal Information to third parties (including to our related bodies corporate, business partners, service providers and third party contractors);
  - if you use our social media sites or applications or other third party products and services that interact with, or connect with, the Logoji App and our Site;
  - if third party payment processors are used by us to process payments made by you.
- When Logoji collects your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
- If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
  - inform them that you are providing their Personal Information to us; and
  - advise them that they can contact us for further information.
- You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.

How Logoji uses your Personal Information

Purposes of use and disclosure

Logoji only uses, processes and discloses your Personal Information for the purposes for which it is collected.

In particular, Logoji uses, processes and discloses your Personal Information and Non-Personal Information to:
- provide or deliver the Logoji App or our Site to you, including, without limitation, to:
  - providing Enterprises with an opportunity to advertise or promote their businesses to users on, or via, the Logoji App by converting the Enterprise’s logos and trade marks into Emoji Stickers and permitting users to use the Emoji Stickers; and
  - providing users with access to, and use of, the Logoji App (including permitting users to access and use the Emoji Stickers when sending messages through the user’s mobile device);
- confirm an Enterprise’s identity and/or the Enterprise’s ownership rights in relation to a trade mark or logo;
- assist with, or respond to, your queries or respond to, or investigate, complaints raised about an Enterprise or user of the Logoji App. For example, an Enterprise may complain that another Enterprise has infringed their intellectual property rights in the logo or trade mark contained within a Emoji Stickers;
- inform you about the Logoji App, our Site, or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Logoji App, our Site, Enterprises, or other matters which we believe are of interest to you (such as recruitment or job opportunities);
- manage, administer, improve, test, develop and upgrade the Logoji App and our Site (including customising the content and Emoji Stickers on the Logoji App and our Site),
- inform you about scheduled maintenance or outages;
- manage our relationship with you;
- share with our Authorised Affiliates;
- to perform research and analysis about the Logoji App and our Site and for data analytics purposes, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is made anonymous by removing data that can identify you;
- charge and bill Enterprise to use our Site and advertise on the Logoji App;
- for direct marketing purposes (see section 6 below);
- to comply with regulatory or other legal requirements,
- for any purpose to which you have consented; and
- for any other purpose notified to you at the time of collection.
In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.

Disclosure to third parties

With your consent, we may provide your Personal Information and Non-Personal Information to the following recipients:
- our employees, related entities, business partners, third party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering the Logoji App, our Site, our products and services (including customer support services);
- third party service providers who process or use your Personal Information and Non-Personal Information for the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, such as cloud-based accounting software platform; marketing and analysis organisations, financial and credit card institutions to process payments or third party payment processors, cloud-base hosting companies, web developers, internet service providers, customer service providers, customer support specialists, fulfilment companies and research and data analysis firms, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us (for example, previous employers and referees); and
- external business advisors, such as auditors, lawyers, insurers and financiers,

(collectively, Authorised Affiliates).

When we disclose your Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
Our Authorised Affiliates may also provide us with Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliate, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.
Logoji may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.

Overseas disclosure
- In the course of providing you with access to, and use of, the Logoji App and our Site, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to our mobile application developers who are located in Australia and the Philippines and Shopify who are located in Canada.
- The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, Logoji will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
- By accessing or using the Logoji App and/or Site, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Authorised Affiliates. If you do not wish to receive information from any of our Authorised Affiliates, please let us know using the details below. However, if you do not provide your Personal Information to us or our Authorised Affiliates, we may not be able to provide you with access to, and use of, the Logoji App or our Site.

Disclaimer
- Logoji will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless:
  - we are otherwise required by the relevant Privacy Laws;
  - we are permitted to under this Privacy Policy; or
  - such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the Logoji App and/or Site.
- This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

Notifiable Data Breaches

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, Logoji will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach provisions of the Privacy Act.

Marketing communications

Direct marketing
- Logoji may use and disclose your Personal Information to send you information about the Logoji App and/or Site and any other products or services we may offer from time to time, as well as other information that may be of interest to you.
- These communications may continue, even after you stop using the Logoji App and our Site.
Communication channels
- Logoji may send this information to you via the communication channels specified at the time you provide your consent.
- These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices or advertising on the Logoji App and/or Site.
Opting-out

You can opt out of receiving these communications by:

contacting us using the details below; or
using the unsubscribe function in the email or SMS.

Storage and security

Protecting your Personal Information
- We take reasonable steps in the circumstances to keep your Personal Information and Non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information. Some of the safeguards that we use include firewalls and data encryption, cloud services via AWS, SSL (Secure Socket Layer) encryption when transmitting payment information, and information access authorisation controls.
- Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
- Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and Non-Personal Information take reasonable steps to:
  - protect and maintain the security of your Personal Information and Non-Personal Information; and
  - comply with the Australian Privacy Principles when accessing and using your Personal Information.
- No guarantee
  - The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the Logoji App or Site.
  - You provide your Personal Information and Non-Personal Information to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and Non-Personal Information.

Destruction of Personal Information

We will destroy or de-identify Personal Information where it is no longer required, unless we are required or authorised by law to retain the information. However, Logoji may retain Personal Information (including basic registration information) in accordance with documentation retention and destruction laws.

Accessing and correcting your Personal Information
- Logoji shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act.
- You can access, or request that we correct, your Personal Information by writing to us using the details below. Logoji may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.
- We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
- We will endeavour to respond to your request for access or correction within 30 days from your request.

Cookies and other tracking technologies
- Logoji and our Authorised Affiliates may collect information by automated means when you access and use the Logoji App or Site by utilising features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.
- The type of information we and our Authorised Affiliates collect may include statistical and device information, including, but not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Logoji App and Site, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Logoji App and Site and other usage statistics.
- We may use cookies and similar technologies to:
  - enable us to identify you as a return user, make it easier for you to login to the Logoji App and personalise and enhance your experience and use of the Logoji App or Site; and
  - help us improve our services to you when you access the Logoji App or Site and to ensure that the Logoji App and our Site remain easy to use and navigate.
- Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies.
- If you reject our cookies or similar technologies, you may still use the Logoji App or our Site but may only have limited functionality of the Logoji App or our Site.
- We may also use your IP address to analyse trends, administer the Logoji App, our Site and other websites we operate, track traffic patterns and gather demographic information.
- Services that our Site and Logoji App may use from time to time include analytics. These enable us to collect information about how users engaged with us, and user trends and behaviour on our Site and on the Logoji App, for example we may collect information about how you engaged with our Site and the Logoji App. We use this information to better understand the user experience and improve your experience on our Site and on the Logoji App. The analytic tools we use do not identify individual users or associate your IP address with any other data held by us or our Authorised Affiliates. The Authorised Affiliates that provide analytics, cookies and tracking technologies include:
  - Google: policies.google.com/privacy
  - Firebase: www.firebase.google.com/support/privacy

Privacy complaints

If you have any issues about this Privacy Policy or the way Logoji handles your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or your commercial arrangements with us.
Our Privacy Officer will endeavour to:
- respond to you within 30 business days; and
- investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.
If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner.

How to contact us

Logoji can be contacted by email at customercare@logoji.com.

Changes to this Privacy Policy

From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the Logoji App and/or our Site.
We encourage you to check the Logoji App and/or our Site from time to time to ensure you are familiar with our latest Privacy Policy.

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PRIVACY POLICY