Privacy · Sphere

ABOUT SPHERE

Sphere (For Good) Holdings Pty Ltd (comprising SPV Fintech Innovations Pty Ltd, Sphere (For Good) Australia Pty Ltd and its associated and related entities) (“Sphere”) directly owns and / or is licensed to use a complex suite of technologies and systems that combine with know-how, corporate structuring and commercialisation strategies to deliver Sphere (For Good) Holdings Pty Ltd corporate and client outcomes.

YOUR USE OF THE WEBSITE

You expressly understand and agree that this Privacy Policy does not apply to any third party websites or information that is listed and/or linked to/from the Sphere Website located at the primary domain www.sphereforgood.com along with other Sphere domains (“Sphere Website”).

Sphere understands and appreciates that visitors to the Sphere Website and subscribers to its online features and services (“Features”) and in the case of a subscription feature, a subscriber’s identification or login (“Subscriber ID”) secured logon, are concerned about their privacy and about the confidentiality and security of information (including without limitation) name, email address, age, gender and details of personal interests as collected by Sphere (“Personal Data”). We are committed to protecting your Personal Data in so far as is practical. Sphere recommends closing your browser when you have finished your user session. This is to ensure that others cannot access your Personal Data and correspondence if you share a computer with someone else or are using a computer in a public place such as library, Internet café, university or standalone IP terminal where public internet access is available. You expressly understand and agree that you as an individual are responsible for the security of and access to a computer to which you have access to.

COLLECTION AND DISCLOSURE

Sphere may collect your Personal Data to enable it to accurately identify and verify who is using the Feature or gaining access to a subscription feature by login using the Subscriber ID, including what may be information and materials confidential to Sphere, its Offering, Technology and IP, along with information concerning its clients, suppliers and affiliates. Some of the Personal Data collected is essential to meet legal requirements and for control, protection and security purposes and as such is mandatory.

In accordance with the requirements of the The Privacy Act 1988 Australia (“Privacy Act”) or similar legislation in other jurisdictions where such information is generated or held, we may share your Personal Data with (i) our associated and related entities and licensed subsidiary operations and offices around the world; and (ii) our licensees, licensors, clients, service providers, employees, contractors and third parties to whom Sphere is bound or where they are bound to Sphere by terms of confidentiality or who are contracted to us for the provision of products and/or services. Countries in the European Economic Area (“EEA”) and The Association of Southeast Asian Nations (“ASEAN”) in most, if not all cases, have a similar standard of protection of personal data to that under the Privacy Act. This is not always the case in countries outside of the EEA and ASEAN, and so we will therefore use reasonable endeavours to see that our licensed subsidiary operations, offices and third party service providers (be they within or outside of the EEA and ASEAN, handle your Personal Data in accordance with the reciprocal legislative requirements of the Privacy Act.

The time period for which we keep your Personal Data and information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep your Personal Data or information, we will retain it for no longer than is necessary for the purposes for which the Personal Data was collected or for which it is to be further processed.

We may disclose your Personal Data, in response to properly made requests, for the purposes of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In either case we do so in accordance with the Privacy Act.

SECURITY

We are serious about guarding the security of your Personal Data. We take appropriate organisational and technical security measures to protect your Personal Data against unauthorised disclosure or processing. We use a secure server to store the information you give us when you register for a subscription, order or take up an Offering (including where applicable your credit/debit card details and your password).

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. We may also disclose your Personal Data when required to do so by law, for example under a court order, or in response to properly made demands, under powers contained in legislation.

While Sphere strives to protect your Personal Data, it cannot ensure or warrant the security or integrity and freedom from harmful code or viruses in respect of any information you transmit to us or receive from your use of our online services. These activities are conducted at your own risk.

CORRECTING PERSONAL DATA / ACCESSING

If the Personal Data we hold about you is inaccurate, please let us know and we will make the necessary amendments and confirm that these have been made.

AUTHORISED USE

You agree and consent to the use by Sphere and release to others of the Personal Data in any manner or for any purpose directly or indirectly associated with Sphere and/or (i) the Features, the Offerings, Technology or IP in which you have expressed interest, seek to partake of or participate in and may render this Personal Data available to and accessible by third parties where such is for the same or similar purpose ; or (ii) where it aids Sphere to best accommodate your registered or otherwise expressed interest.

If you want specific information on your Personal Data, please tell us and give us any relevant information to enable us to locate the information about you because this will speed up our reply. No fee will be charged for an access request made by you, though you may be charged the reasonable expenses incurred in Sphere providing you any information on your Personal Data (such as retrieval, photocopying and reproduction costs).

To access information on your Personal Data held by Sphere, or to obtain more information about your rights or our Privacy Policy, please contact Sphere at: