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1. About this Privacy Policy

Welcome to Iogra. The website located at (‘Website’) is owned and operated by Acoustic and Computing Solutions Pty Ltd (ACN 085 477 550) trading as Iogra (‘Iogra’).
The Website is a platform that provides people with a safe and enjoyable place to write and publish autobiographies or biographies (our ‘Services’). The Website operates as a digital platform to document and share life stories that create a lasting legacy for future generations.
Iogra is committed to maintaining the security of personal information (‘Personal Information’) provided to us. When you share Personal Information with us, we treat it with care and take our responsibility to protect it seriously.
Our Privacy Policy is intended to clearly explain what Personal Information we collect about you, how we collect your Personal Information, how we share your Personal Information, how we store your Personal Information, how we transfer Personal Information and other information about how we manage your Personal Information.
We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), the Privacy Amendment (Notifiable Information Breaches) Act 2017 (NDB) and the EU General Information Protection Regulation (GDPR).
By using our Website, you consent to the collection, use and storage of your data through your use or purchase of our products and services as described in this Privacy Policy.
Any reference to “Iogra”, “we”, “our”, or “us” means Iogra . Any reference to “you, or “your” means you as a user (‘User’) of our Website.
If you do not agree with this Privacy Policy, please do not access or use our Website.
By using or accessing our Website or providing us with Personal Information, you consent to the collection, use, disclosure and management of your Personal Information in accordance with this Privacy Policy.
We may update this Privacy Policy from time to time to accurately reflect our own data collection and processing practices or any changes to the Privacy Laws. Amendments to this Privacy Policy will be effective upon posting to the Website as a condition of your continued use of our Website.

2. About the Iogra Website and Services

The Website is a platform that allows friends and family access to store and share their life stories and preserve a legacy for the decades to come. The platform allows its Users to add a timeline, build a family tree, record memories, create a gallery, share projects, and publish autobiographies, biographies and books (our ‘Services’).
Our Services are currently offered free of charge. Anyone can sign up, upload content and publish autobiographies or biographies with default templates that we provide.
When available on our Website, Members can subscribe to a premium service to access our online bookstore to sell their works. We will also provide Users with customised templates and more features made available through our paid premium services. Iogra reserves the right to add, modify, or remove any or all features from any Services that Iogra provides, at any time, with or without notice.

3. Acceptance

To obtain access to our Services, you must register for a member account through our Website (‘Member Account’).
By registering for a Member Account, you will be required to accept our Terms and Privacy Policy by clicking the “register” button in the user interface as a condition of joining as a subscriber. By clicking the “register” button you agree to our Terms, our Disclaimer and Privacy Policy listed on this Website which gives notice to you through our user interface as follows:
By Registering, you agree that you've read and accepted our Website Terms and Conditions, our Disclaimer and you consent to our Privacy Policy.
By accessing the platform and entering your details via ‘Contact Us’ page on our Website, or by subscribing to our mailing list, you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
Once you have signed up for a Member Account you can start writing your life story including the entering of additional personal data about yourself. This personal data may be in the form of postings, messages, text, files, images, photos, videos, sounds, or other materials or works you upload for your life story (‘Your Content’).

4. What Personal Information is collected

“Personal Information” is information or an opinion that can reasonably identify an individual (s 6(1) of the Privacy Act).
We receive and store Personal Information you provide to us through the supply of our Services, through your use of our Website, when we answer your queries or when you submit Personal Information to us online when you use our platform.
Personal Information about visitors to our Website is collected only when it is knowingly and voluntarily submitted with your consent. For example, we may need to collect this information to provide you with our Services or to answer any requests or enquiries.
We only collect Personal Information that is reasonably necessary for the purpose of our functions.
For any of our Services that require a login and password (‘Login Details’), it is your responsibility to keep your Login Details confidential and secure.
We ask you to provide Personal Information and obtain other information from you when you use our Website and Services.
This Personal Information may include:
a) name, mobile number, address, occupation, date of birth;
b) usernames, passwords, email addresses, or other registration details;
c) bank, credit or financial account information;
d) forms submitted and User preferences;
e) non-identifiable device information, IP addresses, location data, system logs, browser activity, operating system, length of visit, number of visits and referral sources, User preference settings, unique IDs generate for each Website sign in, product descriptions viewed, videos watched; and
f) any other information reasonably collected or required for the supply of our Services.
We may collect additional information from you at other times, including but not limited to, when you provide feedback, change your content or email preference, respond to surveys, or when you email us or communicate with our support team.
We also collect and use Personal Information to improve our Services through marketing communications.
You are solely responsible for:
g) the accuracy, quality, integrity, legality, reliability, and appropriateness of the Personal Information that you provide to us, and
h) accessing and updating that Personal Information if it is inaccurate or incomplete.
We do not knowingly collect any Personal Information from you that is considered sensitive or a “Special Category” under the GDPR such as Personal Information revealing physical or mental health, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
We do not knowingly collect or process Personal Information of persons 18 years or younger.

5. Your use of third-party personal data

Iogra recognises that you may wish to include references to individuals in your life story and publications that can be used to identify individuals. These references may constitute the use of personal data under applicable data protection legislation in the relevant jurisdictions.
It is your responsibility to ensure that you comply with all law, regulations, and standards to ensure your compliance with applicable data privacy laws.
You bear sole responsibility for how you transmit, use and publish personal data on or through the Website.

6. How we collect your Personal Information

Iogra collects Personal Information from you in a variety of ways, including when you interact with us electronically or in person, when you access our Website and when we provide our Services to you.
We may also receive Personal Information from third-parties in connection with the supply of our Services. If we do, we will protect your Personal Information in accordance with this Privacy Policy.
Iogra will use reasonable endeavours to only collect your Personal Information directly from you including through the use of online forms. If you are disclosing details of another person (for example, where you are signing up on their behalf), it is your sole responsibility to ensure that that person understands and consents to the collection, use and disclosure of their Personal Information in the manner set out in this Privacy Policy.

7. How we use your Personal Information

Iogra uses your Personal Information and you consent to us using your Personal Information to:
a) supply you with our Website and Services in accordance with our Terms;
b) provide you with information and updates about our Website and our Services;
c) communicate with you by a variety of measures including, but not limited to, by telephone, email, SMS or mail;
d) manage, research and develop our Website and Services including through data analytics;
e) administer our business activities and internal record keeping;
f) meet legal, regulatory and compliance obligations; and
g) investigate any complaints.
We also use your Personal Information to assist us in providing our Services to you, to verify your identity, contact you or respond to your queries, display, update and maintain the Website and its content, tailor your experience of the Website and our communications to you.
If you choose to withhold your Personal Information, it may not be possible for us to provide you with our Services or for you to access certain parts of our Website and for us to respond to your query.

8. Legal basis in the European Union (EU) for the collection and processing of your Personal Information

“Personal Information” refers to any information relating to an identifiable natural person who can be identified directly or indirectly (‘Information Subject’) (Article 4).
The GDPR applies to the data processing activities of businesses with an establishment in the EU or where the processing activities relate to offering goods or services to individuals in the EU or monitor the behaviour of individuals in the EU.
If you are an individual residing in the EU, we may collect and process Personal Information about you in accordance with the GDPR. A “Controller” says how and why Personal Information is processed and a “Processor” acts on behalf of the Controller by processing the data.
When you use our Services, we may process Personal Information on your behalf as a Processor where you are the Controller and otherwise to the extent that we are a Controller as defined in the GDPR.
“Processing” means any operation or set of operations that is performed upon Personal Information or sets of Personal Information whether automated or not including for collection, recording, organisation, structuring, storage, adaption, or alteration, retrieval, consultation, use, disclosure by transmission or for dissemination.
Where we are a Processor of Personal Information on your behalf as the Controller, we must provide you with the:
a) the legal basis for collecting Personal Information;
b) which items of Personal Information to collect;
c) the purposes the Personal Information is to be used for;
d) which individuals to collect Personal Information about;
e) whether to disclose the Personal Information and to whom;
f) whether Information Subject access and other rights apply; and
g) how long to retain the Personal Information and whether to make amendments to the Personal Information.
The legal basis for which we collect Personal Information from you depends on the Services you use and how you use them. Iogra will only collect and use your Personal Information on the following legal bases:
a) Contractual basis. This legal basis applies to the collection or processing of Personal Information in order to fulfil or perform a contract with you, or to which you are a party.
b) Consensual basis. This applies where you have provided your consent to the collection or processing of Personal Information for a specific purpose (for example, to provide you with marketing updates). You can withdraw your consent at any time by updating your email preferences, opting-out, or by contacting us directly.
c) Legitimate interests. This applies where we have a legitimate interest to collect or process your Personal Information. For example, it may be to respond to an enquiry about our Services.
d) Legal obligations. This applies where it is necessary to disclose your Personal Information to comply with a legal obligation.
We will only otherwise collect your Personal Information with your express consent for a specific purpose and any Personal Information collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
As a Processor, we process Personal Information in accordance with your documented instructions. We will make available to you all information necessary to show our compliance with the GDPR including that we have taken appropriate security measures to protect the Personal Information in accordance with the GDPR. We will delete or return the Personal Information to you at the end of our Services in accordance with your explicit instructions.
In the event of a Personal Information breach including any breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Information transmitted, stored or process, we will report the breach to you without undue delay after becoming aware of the breach, and not later than 72 hours after the breach giving you a description of the nature of the breach.
Unless otherwise required by contractual obligation or any other legal basis, we only store your Personal Information while it remains necessary, or if the purpose of the processing could not reasonably be fulfilled by other means.
If you are under the age of 18, we request that you obtain and provide parental consent before using our Website and Services as required by the GDPR.

9. Right of Access

Under the Privacy Laws, you have certain rights as to how your Personal Information is being controlled and used. We will provide you with reasonable access to your Personal Information in accordance with the relevant Privacy Laws.
We comply with your rights under the Privacy Laws and the GDPR (subject to the grounds set out in the GDPR) that permit you:
a) to be informed as to how your Personal Information is being used;
b) to access your Personal Information and to know specifically what information is held about you and how it is processed, where and for what purpose (we will provide you a copy of your Personal Information in electronic format free of charge if requested);
c) to rectify your Personal Information if it is inaccurate or incomplete;
d) to erase your Personal Information (also known as 'the right to be forgotten') if you wish to delete or remove your Personal Information;
e) to restrict processing of your Personal Information;
f) to retain and reuse your Personal Information for your own purposes (Personal Information portability);
g) to object to your Personal Information being used; and
h) to object against automated decision making and profiling.
You can contact us any time to exercise your rights under the GDPR including as to:
a) request access to Personal Information that we hold about you;
b) to correct any Personal Information that we hold about you;
c) delete Personal Information that we hold about you; or
d) opt out of emails, marketing, and any other push notifications that you receive from us.
We may ask you to verify your identity before acting on any of your requests.
If you have any questions about Iogra’s collection and storage of data, please contact us through the ‘Contact Us’ page on our Website.

10. Disclosure of your Personal Information and Third-Parties with Access to it

We will only share your Personal Information where you have given us your consent, and only for the purposes described in this Privacy Policy.
We may disclose your Personal Information to third-parties where:
a) the disclosure is directly related to the purpose for which the Personal Information was collected, and we have no reason to believe that you would object;
b) you are likely to be aware, or have been made aware, that Personal Information of that kind is usually disclosed;
c) where we believe on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to the life or health of you or another person; or
d) where that disclosure is authorised, otherwise permitted or required by law.
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 Privacy Policy. Personal Information is only supplied to a third-party when it is required for the delivery of our Services.
We may share your Personal Information with third-party service providers to help us provide our Services, and to provide you with a payment platform. Our third-party service providers may be located outside of Australia or outside of the EU.
When we disclose your data to third-party service providers we do so on the basis that your data is treated with confidence, and only used for the limited purpose of providing support to our Website and Services, and in manner consistent with this Privacy Policy.
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.

11. International Information Transfers

We may store, process and transfer your data, including your Personal Information and Your Content in countries other than the country you live in. Information transfer may occur in and between countries outside of Australia which may include but are not limited to the United States and Europe.
As part of our obligations under the GDPR, we only transfer the data of individuals residing in the EU to countries outside of the EU with adequate privacy data laws or to a third-party where we have approved transfer mechanisms in place to protect your Personal Information and Your Content, for example, by entering into the European Commission’s Standard Contractual Clauses for data protection for data that is transferred internationally or ensuring the entity is Privacy Shield Certified for data transfer to third-parties based in the United States
We only employ third-party data processors that are compliant with the GDPR requirements and that have sufficient security measures in place to protect and safeguard your data.
You may not have the same rights to protect your data in these countries as you do in Australia. Where your data has been transferred to a country abroad, it will be treated in accordance with the purposes described in this Privacy Policy.
For individuals in the European Economic Area (EEA), your data will be stored and processed in Australia which provides an adequate level of data protection. This mean that your Personal Information will be transferred from the EEA to Australia.
If your Personal Information is transferred from the EEA to a country or international organisation outside of Australia, we will ensure that we have approved transfer mechanisms in place to protect your Personal Information and Your Content adequately (for example, by entering the European Commission’s Standard Contractual Clauses for data protection for data that is transferred internationally or ensuring the entity is Privacy Shield certified for data transfer to third-parties based in the United States).

12. Information Ownership

You, as a User, own all rights, title and interest in the content and Personal Information and Your Content that you provide to us (‘User Information’).
You are solely responsible for the accuracy, quality, integrity, legality, reliability, and appropriateness of your User Information.
You grant to Iogra, or to any third-parties used by us to provide the Website or Services and any associated software, a non-exclusive, worldwide and royalty free licence to use, copy, display, perform, distribute, disseminate, transmit, translate, edit, cache and create derivative works of User Information.
Iogra or any related entities owns all right, title and interest in any data or information that we create, generate, compile, derive or produce in connection with any supply of our Website or Services, including data and information that is:
a) aggregate or raw or statistical relating to usage, analyses and results of the Website;
b) for the purpose of optimising delivery, commercialisation and performance of our Website; and
c) samples and prototypes, conclusions, techniques, know-how, methods, and undocumented findings generated in the usual course of our business.

13. Security of your Personal Information and Your Content

Iogra will take all reasonable steps to protect your Personal Information and Your Content from unauthorised access, use and disclosure. However, we cannot guarantee that our systems and stored data will be completely free from third-party interception or data corruption.
Certain parts of the Website (such as those parts that require you to provide us with your credit card number) provide the ability for you to transmit information to our platform in an encrypted form by using secure socket layer (SSL) technology. We cannot ensure or warrant, and do not warrant, the absolute security or privacy of your Personal Information and Your Content, including payment and account details. If you have any questions regarding security, you can contact us at through the ‘Contact Us’ page on our Website.
If you use our Website to link to another website, we encourage you to view their terms and conditions of use, privacy policies and security statements before disclosing any of your Personal Information and Your Content on those websites.
To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, such as encryption of Personal Information and Your Content, to safeguard and secure data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
These measures include where appropriate or required by law, computer safeguards and secured, Internet firewalls, intrusion detection, anti-virus protection, network monitoring and Transport Layer Security (“TLS”) or similarly encrypted browsers.
You agree that the transmission and exchange of information is carried out at your own risk. No method over the transmission or storage system is 100% private and secure. You understand that we do not guarantee or warrant the absolute privacy or security of any information we collect from or about you. If you have any questions about privacy or security, please contact us.

14. Access to and how you can control your Personal Information

It is your responsibility to advise us of any changes to your personal details to ensure we can keep our records accurate and up to date. If you wish to access some or all of the Personal Information that you have provided us, please submit a request to [insert].
We request that you keep your information as current as possible so that we may continue to improve our supply of Services to you.
If you believe that your Personal Information with us is incorrect, you may request for the amendment of such information. You may also request that we delete your Personal Information with us.
If you request Iogra not to use your Personal Information in a particular manner or at all, we will adopt reasonable measures to observe your request but we may, to the extent permitted by law, still use or disclose your Personal Information if you subsequently consent to the disclosure or if we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or is otherwise required or authorised by law. If you know that the information we hold about you is not accurate or complete, please notify us. We will respond to requests for access within thirty (30) days.
We will retain your Personal Information for as long as your Member Account is active or as needed to provide you our Services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

15. Third-party tools and cookies

Iogra may use Google Analytics Advertising products such as Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our Website traffic via Google Advertising cookies and anonymous identifiers. Information collected via these Google products is not linked with any personally identifiable information you submit while on our Website. If you wish to opt out of the Google Analytics data collection, you may do so on Google’s Website at
As is true of most platforms and mobile applications, we and, in some instances, our third-party tracking-utility partners automatically gather certain information and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
Iogra uses this information, which does not identify individual Users, to analyse trends, to administer the Website, to track Users’ movements around the Website and to gather demographic information about our User base as a whole.
Iogra and its marketing and development partners, affiliates, and analytics or third-party service providers or subcontractors, such as online customer support provider and email marketing system, use technologies such as cookies, beacons, tags and scripts. These technologies are used in analysing trends, administering the Website, tracking Users’ movements around the Website and gathering demographic information about our User base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as on an aggregated basis.
Iogra uses cookies for authentication purposes and for tailoring the Website according to User preferences. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our Website may be limited.

16. Marketing Material

Iogra may use your Personal Information to provide you with materials, promotions and communications from time to time about Services available to you or from other service providers in partnership with us, or to invite you to continue to use our Services. This information will only come from us. Iogra will not sell your Personal Information to other providers without your express consent.
You may opt out of receiving promotional materials from us at any time by contacting us through the ‘Contact Us’ page on our Website or by clicking the 'unsubscribe' link on the relevant promotional emails.
If we process your Personal Information for emails and short message communications (SMS), you can unsubscribe from our email database though the “unsubscribe link” that is contained in an email from us or texting ‘STOP’ if you receive SMS communications.

17. Advertisements and Links

We may publish advertisements from third-parties and our Website may from time to time have links to third-party websites. Links to third-party sites do not constitute sponsorship or endorsement or approval of these sites. Iogra is not responsible for the privacy practices and advertising content.

18. Notifiable Information Breach

The security of your data is important to us but remember no method of transmission over the internet is 100% private and secure. We do not guarantee or warrant the absolute privacy or security of any data we collect from or about you.
The internet is an insecure medium and Users should be aware that there are inherent risks transmitting information across the internet. Information submitted unencrypted via electronic mail or web forms may be at risk of being intercepted, read or modified.
A reportable “Information Breach” is a security incident where the integrity of Personal Information is compromised through being destroyed, lost, altered, corrupted, disclosed or accessed by an unauthorised person where it is likely to result in serious harm to any individual affected.
We have procedures and systems in place including a data breach incident response plan, specific data breach policies and procedures and personnel to deal with an actual or suspected “Information Breach” and will notify you and the applicable regulator in accordance with our obligations under the Privacy Laws and NDB.
Please report to Iogra any actual or suspected data breaches for investigation by using the ‘Contact Us’ page provided on our Website.

19. Complaints about privacy

If you have any concerns about on how we handle your Personal Information and Your Content or if you need further information, please contact our Privacy Officer at our contact details below. Also use this contact address if you no longer consent to receiving marketing material from us.
We may change this policy from time to time to reflect changes to our information practices. We encourage you to regularly review this statement to inform yourself of any amendments

20. Our contact details

You can contact us:
a) using the ‘Contact Us’ page provide on our Website located at ;
b) by email at:
c) by mail using the address provided above

Privacy Policy last updated on 7 May 2020.