Privacy Policy.

This Policy applies to Gaia App, operated by LnP Digital Pty Ltd (ABN 57 602 579 147) and its related entities from time to time, together (Us, we, our)

  1. Introduction
  2. We are bound by the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles (APPs), and any registered privacy codes that apply to it. This Policy sets out:

    • What kind of information we collect
    • How we collect it
    • How we use it
    • How we disclose it
    • Opting in and out of marketing activities
    • Management and security
    • How to seek access to and update your personal information
    • How to contact us or make a complaint

    By visiting or using our websites that link to this Policy or otherwise providing information to us, you consent to collecting, processing, using, and disclosing information about you as set out in this Policy, including transfers to third parties and other countries. Your use of our services and the websites, and any dispute over privacy, is subject to this Policy and our Terms of Use, including applicable limitations on damages and the resolution of disputes.

    From time to time, we may review and update this Policy, including to take account of new or amended laws, new technology, and/or changes to our operations. We will post changes to this Policy on our websites along with the effective date of the changed policy. We recommend that you review this Policy periodically. If we make a material change to this Policy, you will be provided with appropriate notice.

    All personal information held by us will be governed by the most recently updated Policy. This Policy was updated in April 2024 and is effective from 8 April, 2024.

  3. The information we collect
  4. Personal Information

    Personal Information is any information or opinion about an identified individual or an individual who is reasonablyidentifiable, whether the information or opinion is true or not, and whether the information or opinion is stored in a material form.

    We only collect personal information directly related to, or reasonably necessary for, our functions and activities.

    In general, the personal information we collect about you includes (but is not limited to):

    • Personal information for your account: your legal name, date of birth, residential address, contact details (including phone numbers and physical and electronic addresses) and in some circumstances, financial information (including your bank account details so we can make payments via Electronic Funds Transfers).
    • Information about third parties: we may collect information from you regarding other individuals related to your account. By disclosing information about authorised signatories, dependents, relatives, potential beneficiaries, employees, agents, or other representatives, you warrant that you have the consent of those parties to such collection, use, and disclosure of their information as described in this Policy.
    • Information from communications with us: If you communicate with us by telephone, email, online chat, or text message, we may keep a record of that communication. In accordance with applicable law, we also may record and monitor telephone calls for training, quality assurance, security, and customer service purposes.
    • Information contained in surveys: We may ask you to complete surveys for research and/or client service-related purposes. You are not required to respond to those surveys, and any information collected by us that you provide in response to those surveys is at your discretion.
  5. Other information
  6. We collect information about you automatically on our websites and through emails that we send to you, including whether you click on or select links in our emails. We may also collect data relating to your activity on our websites (including IP addresses) via tracking technologies such as cookies, or we may collect information from you in response to a survey. We generally use this information to help us understand how our websites are used and how you interact with information we send you, report statistics, analyse trends, administer our services, diagnose problems, and target and improve the quality of our products and services.

    To the extent this information does not constitute personal information, the APPs do not apply, and we may use this information in ways not covered by this Policy.

    We generally advise that you do not publish or communicate personal information, or at least limit the personal information that you publish or communicate, to the public via our services, such as in our forums or blogs (Non-Confidential Information). You acknowledge that we cannot control any third-party collection or use of your Non-Confidential Information. You agree that we may use and disclose Non-Confidential Information for any purpose and by any means.

  7. How we collect personal information and other information
  8. We collect personal information directly from you whenever practical, and for example, may collect your personal information when you request or acquire a product or service from us, register or subscribe with us as a member, provide a product or service to us, complete a survey or questionnaire, enter a competition or event, contribute in a fundraising event, participate in our services (including our radio programs, blogs and forums) or when you communicate with us by email, telephone or in writing (for example, if you contact customer service to make a complaint or provide feedback). We may also collect your personal information from a variety of third-party sources, such as advertisers, mailing lists, recruitment agencies, contractors, and business partners.

    If, at any time, you provide personal or other information about someone other than yourself, you warrant that you have that person’s consent to provide such information for the purpose specified.

  9. Cookies
    1. We may collect your personal information through cookies and other tracking devices. When you access our websites, we may send your device a “cookie” (a small summary file containing a unique ID number). This enables us to recognise your device each time you visit our websites, without requesting you to register or log-in. It also helps us keep track of products or services you view, so we can send you news about them.
    2. We use cookies to measure traffic patterns, determine which areas of our websites have been visited, and measure aggregate transaction patterns. We use this to research our users’ habits so that we can improve our online products and services. If you do not wish to receive cookies, you can set your browser, so your device does not accept them. We may also log IP addresses to analyse trends, administer the website, track user movements, and gather broad demographic information.
    3. We may also collect anonymous data (not personal information) relating to your activity on our websites (including IP addresses) via cookies or collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems, and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply, and we may use this information for any purpose and by any means whatsoever.
    4. We may combine the information that we have collected about you. If you have registered for secure access to our websites or accessed an email, we have sent you that includes a web beacon or sets a cookie, we are able to combine the information we collect about your usage of our websites with other information we know about you, such as any searches you conduct or information you request during your web session. We can also identify your computer or device on each visit to our websites, even if you do not log on, and determine whether you came to our websites by clicking on an email link. This enables us to link information about your website’s visits, as well as about our ads that you may have viewed on other websites to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our websites and the effectiveness of our email communications and online advertising, as well as to identify our products and services that may be of interest to you. For more information about how we and our service providers use information for analytics and advertising purposes, please see the “Website Analytics and Interest-Based Advertising.”
  10. Why we collect personal information and other information
    1. The primary purpose for which we collect personal information about you is to provide you with the products and services you have requested. We also collect information about you for the purposes outlined below. We may state a more specific purpose at the point we collect your information. If you do not provide us with the information we request, we may not be able to provide you with our products or services. For example, if you do not register as a website member, you cannot access features or services reserved for members only.
  11. How we use personal information and other information
  12. We may use the personal information and other information we collect, and you consent to us using your personal information and other information for the purposes for which it was provided to us, as required by law, and for our business purposes, including:

    • to provide you with news and information about our products and services;
    • to send marketing and promotional material that we believe you may be interested in. This material may relate to any business conducted by us or a third party business that we believe may be of interest to you;
    • for purposes necessary or incidental to the provision of goods and services to you;
    • to personalise and customise your experiences. We may tailor the content, information, and advertising that we may send or display to you, including as discussed in the section below titled “Website Analytics and Interest-Based Advertising,” to offer location customisation and personalised help and instructions, and to otherwise personalise your experiences while using the websites. Please see the section below titled “Website Analytics and Interest-Based Advertising” for information about how to opt out of tracking through third-party analytics;
    • to manage and enhance our products and services;
    • to communicate with you, including by email, mail or telephone;
    • to verify your identity;
    • to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
    • for research and analytical purposes, including counting and recognise visitors to the websites and various website features and better understand how users access and use our websites and our products and services;
    • to fulfil our legal obligations and to carry out our internal business functions; and/or
    • as required or permitted by any law (including the Privacy Act)

    In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance, where you would reasonably expect us to, and the purpose is related to the purpose of collection).

  13. Website Analytics and Interest-Based Advertising
  14. We partner with third parties to collect the information discussed in this Policy to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other devices and may use web beacons to collect information about your activity on our websites. In particular, our websites use Adobe Analytics and Google Analytics to help collect and analyse certain information for the purposes discussed in this Policy. The information generated about your use of the websites may be transmitted to and stored by Adobe Analytics and Google Analytics on servers outside your country of residence. You may opt out of the use of cookies by Adobe Analytics here. You may opt out of the use of cookies by Google Analytics here.

    We also partner with third parties to provide targeted advertising services through digital channels and social media that are customised based on your online activities over time and across unaffiliated websites (“Interest-Based Advertising”). These third parties may use cookies and web beacons (and other storage technologies) to collect or receive information about your activity on our websites, and they may combine it with information about your activity on other unaffiliated websites. In addition, our third-party advertising providers might use information about your use of our websites to help target interest-based advertisements based on your online activity in general. This means that you may see our banners and ads when you are on other websites and apps, such as social media.

    For more information about Interest-Based Advertising and how to opt-out, please visit the Australian Digital Advertising Alliance (ADAA) opt-out page, available at http://www.youronlinechoices.com.au/opt-out/.

    Although our websites do not respond to “do not track” browser headers, you can limit tracking by taking the above mentioned steps. The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies and not this Policy.

  15. How we disclose personal information
  16. We will disclose your personal information, and you consent to us disclosing your personal information to Queste Pty Ltd and any of its related entities (in which case, your personal information will be collected, used, disclosed, managed, and stored per this Policy). We may also disclose personal information, and you consent to us disclosing your personal information to third parties:

    • engaged by us to perform functions or provide products and services on our behalf, such as processing credit card information, mailouts, financial recovery, marketing, research, and advertising;
    • that are our agents, business partners, or joint venture entities or partners;
    • that sponsor or promote any competition that we conduct or promote via our services;
    • authorised by you to receive information held by us;
    • as part of any investigation into you or your activity, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary to the Police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator;
    • as part of a sale (or proposed sale) of all or part of our business; and/or
    • as required or permitted by any law (including the Privacy Act).

    We store your personal information in Australia, though some multinational service suppliers may store this information overseas. We are unable to determine in which countries this information may be held. We are unlikely to disclose your personal information overseas.

    As mandated by the Office of the Australian Information Commissioner (Commissioner), if an eligible data breach occurs that causes serious harm to an individual, LnP Digital Pty Ltd will have to notify the Commissioner of such a breach. This requirement is the Notifiable Data Breaches Scheme, effective 22 February, 2018. Your personal details may be provided to the Commissioner, and the individual themselves will be notified of the matter, should such an occurrence arise.

  17. Managing our communication to you
  18. You may “opt-out” from receiving communications from us or from third parties that send communications to you in accordance with this Policy. For example, you may unsubscribe from e-newsletters and other marketing, or promotional material sent by us. You may “opt-out” from receiving these communications by clicking on the unsubscribe link at the end of an email, or by updating your personal details on our websites, or by contacting us through any of the channels disclosed in the Contacting Us, complaints, and feedback section below.

    Please be aware that there is certain information we are required by law to provide to you, and you cannot opt out of receiving this information from us.

    If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this Policy or in breach of any law, please contact us through any of the channels disclosed in the Contacting Us, complaints, and feedback section below.

  19. Data management and security
  20. We have appointed a Privacy Officer to oversee the management of personal information in accordance with this Policy and the Privacy Act. Other than in relation to Non-Confidential Information, we will take all reasonable steps to protect the personal information that we hold from misuse, loss, interference, or unauthorised access, including by means of appropriate physical measures and appropriate electronic measures such as firewalls, password access, secure servers and encryption of credit card transactions.

    However, you acknowledge that the security of online transactions and communications sent by electronic means or post cannot be guaranteed. You provide information to us via the Internet or by post at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control. You acknowledge that we are not responsible for any third party's privacy or security practices (including third parties to whom we are permitted to disclose your personal information in accordance with this policy or any applicable laws). The collection and use of your information by such third party/ies may be subject to separate privacy and security policies. If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately through any channels disclosed in the Contacting Us, Complaints, and Feedback section below.

  21. Accessing and correcting your information
  22. We take reasonable steps to ensure that only required data is held and that all personal information is complete and accurate. We request that you keep your information as current as possible so we may continue improving our service.

    Subject to some exceptions in the Privacy Act, you have the right to seek access to the personal information we hold about you. If you make an access request, we will ask you to verify your identity. We may charge a fee to cover the costs of meeting your request, for example cancelling and re-issuing a cheque payment sent to an out-dated address. If we refuse your request for access, we will give you written reasons within a reasonable time (unless it would be unreasonable to provide those reasons).

    If you are registered with us as a member, you are able to change and update your profile at any time. Should you require assistance updating your data or removing your details, contact us through any channels disclosed in the Contacting Us, Complaints, and Feedback section below. You may also unsubscribe from our services at any time by contacting us through any of those channels.

    If the personal information you have provided us has changed or your circumstances change, or you believe that the data we hold is not accurate, please contact us through any of the channels disclosed in the Contacting Us, Complaints, and Feedback section below, and we will consider your request to correct the information. We will usually correct your information within a reasonable time. If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.

  23. Contacting Us, Complaints, and Feedback
  24. If you would like to seek access to the personal information we hold about you, or if you have any questions or complaints about how we collect, use, disclose, manage, or store your personal information, you can contact us via the below channels:

    • Postal Address:
      LnP Digital Pty Ltd
      5A Whiteside Street
      North Ryde, NSW 2009
      Australia
    • Email: agamlamba2@gmail.com

    If you make a complaint, we will take reasonable steps to investigate the complaint and respond to you within a reasonable time. If you are not happy with our response, you may complain directly to the Office of the Australian Information Commissioner at www.oaic.gov.au.

    For more information about privacy in general, or if you are dissatisfied with our response to your complaint, you can contact the Office of the Australian Information Commissioner at www.oaic.gov.au.