Privacy Policy

This Data Privacy & Protection Policy applies to Invincible Software Holdings Ltd “ISH” collectively, prospect, partner and associate interactions, customer service inquiries & user conferences you may have with the business.

This Data Privacy & Protection Policy does not apply to any third-party applications or any other third-party products, services or businesses.

Information we collect and receive

ISH may collect and receive Customer, Partner & Associate Data and other information and data (“Other Information”) in a variety of ways:

Customer, Partner or Associates Data: Customers, Partners & Associates or individuals granted access to the ISH Group businesses.

Cookie Information: The ISH website uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services.

Third-Party Data: ISH may receive data about organisations, industries, Website visitors, marketing campaigns and other matters related to our business from within the ISH group, its affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful.

This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed. Additional Information Provided to ISH. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with ISH.

Generally, no one is under a statutory or contractual obligation to provide any Customer, Partner or Associate Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as basic user profile level information (e.g. name, email address), is not provided, we may be unable to provide our services.

How do we use the information?

Customer, Partner & Associates Data will be used by ISH in accordance with given instructions, including any applicable terms in relevant agreements or Customer’s, Partner’s & Associate’s use of our services, and as required by applicable law.

ISH uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically;

To provide, update, maintain and protect our services, websites and business.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
To send emails and other communications. We may send you other administrative emails, messages and other types of communications.
To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, ISH may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Data Privacy & Protection Policy as “Personal Data.”

Data retention

ISH will retain Customer, Partner & Associate Data in accordance with instructions as required by applicable law.

ISH may retain Other Information pertaining to you for as long as necessary for the purposes described in this Data & Protection Privacy Policy. This may include keeping your Other Information to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How do we share and disclose information?

This section describes how ISH may share and disclose Information. Customers, Partners & Associates determine their own policies and practices for the sharing and disclosure of Information, and ISH does not control how they or any other third parties choose to share or disclose Information.

Customer’s, Partners & Associates Instructions: ISH will solely share and disclose relevant Data in accordance with given instructions, including any applicable terms in service agreement and in compliance with applicable law and legal process.
Access: Owners, administrators, Authorised Users and other representatives and personnel may be able to access, modify or restrict access to Other Information.
Third-Party Service Providers and Partners: We may engage third-party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support the delivery of our Services is set forth within the section “Subprocessors”.
During a Change to ISH’s Business: If ISH engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of ISH’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or De-identified Data: We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, or as part of new offerings or services or to provide anonymised benchmark metrics for comparative performance analysis.
To Comply with Laws: If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may include the Notifiable Data Breaches (NDB) scheme contained within the Australian Privacy Act, notifiable privacy breach provisions within the New Zealand Privacy Act, and data breach notification provisions contained within the United Kingdom and/or European Economic Area General Data Protection Regulation (GDPR). For example, where Personal or Sensitive Information is lost or subject to unauthorised access or disclosure and will likely result in serious harm to an individual/risk to the rights and freedoms of natural persons, ISH will take appropriate response action in accordance with applicable law.
To enforce our rights, prevent fraud, and for safety: To protect and defend the rights, property or safety of ISH or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
With Consent: ISH may share Other Information with third parties when we have consent to do so.

Security

ISH takes the security of data very seriously. We take all reasonable steps to ensure that all Customer, Partner & Associate Data and Other Information is secure and protected from misuse, loss and unauthorised access and modification.

Changes to this policy

ISH may change this Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this policy on the ISH website and encourage you to review our Data Privacy & Protection Policy to stay informed. If we make changes that materially alter your privacy rights, ISH will provide additional notice, such as via email or through the Services.

Data protection officer

To communicate with our Data Protection Officer, please email data.protection@invsholdings.com

Your rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.

To the extent that ISH’s processing of your Personal Data is subject to the General Data Protection Regulation, ISH relies on its legitimate interests, described above, to process your data. ISH may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to ISH’s use of your Personal Data for this purpose at any time.

Subprocessors

ISH uses certain subprocessors to assist in providing its Services. It works with service providers that have or may have access to or process ISH’s customer, partner or associate data.

Before engaging any sub-processors, ISH performs strict due diligence to ensure our customer data remain secure and protected, including ensuring our subprocessors satisfy equivalent contractual obligations as those required.