Privacy Policy

Vudoo Pty Ltd
(ACN 618 786 959)

Privacy Policy (Policy)

1 Key terms
Australian Privacy Principles means the Australian Privacy Principles contained in the Privacy Act.

Claim means any claim in law or equity, or under statute, for a remedy of any nature whatsoever, whether contingent, prospective, actual or otherwise and including any and all claims, actions, sums of money, arbitrations, suits, counterclaims, demands, causes of action, debts due, verdicts, judgments, Losses, account reckonings, proceedings and charges. 

Data Breach has the meaning given in clause 12.4.

GDPR means the General Data Protection Regulation (EU) 2016/679.

Law means any law or legal requirement, including at common law, in equity, under any statute, regulation or by-law and any decision, directive, guidance, order, decree, guideline or requirements of any authority.

Loss means any damage, loss, expense and cost whatsoever including any cost or expense regarding any Claim and any legal costs and expenses of any nature.

OAIC means the Office of the Australian Information Commissioner. 

Personal Information has the meaning given in clause 3.2.

Privacy Act means the Privacy Act 1988 (Cth).

Related Bodies Corporate has the meaning given to that term in the Corporations Act 2001 (Cth).

Statistical Information has the meaning given in clause 3.3.

Site means any website operated by Vudoo or any of its Related Bodies Corporate. 

Services means the services provided by Vudoo from time to time.

2 General

2.1 In this Policy, User, you or your means any person who accesses and uses Site or Services.

2.2 This Policy has been prepared in accordance with:

(a) applicable Australian privacy and data protection laws, including the Privacy Act and the Australian Privacy Principles contained therein; and

(b) the GDPR, 

as applicable.

2.3 This Policy applies to Vudoo’s collection and disclosure of your Personal Information (as defined in clause 3.2) when you use the Site or Services.

2.4 This Policy is intended to describe what information Vudoo collects and/or processes; how Vudoo uses it; and under what circumstances, if any, Vudoo discloses any Personal Information. Please read this Policy before using the Site or Services or submitting any Personal Information. By using the Site or Services, you are accepting the practices described in this Policy.

2.5 Vudoo may in its absolute discretion elect to amend or replace this Policy by uploading a revised Policy on the Site from time to time. A copy of the most up to date version of this Policy will be made available to view on the Site. Any changes made to this Policy will apply immediately from the date Vudoo uploads the revised Policy onto the Site. In addition, Vudoo may, but is not obliged to, notify you by email of any updates to this Policy. Vudoo strongly encourages you to refer to this Policy on an ongoing basis to understand your rights under the Policy. Unless otherwise stated, the most current Policy will apply to all information Vudoo has about you. If you do not agree with the practices outlined in this Policy, you must immediately stop using the Services and accessing the Site. 

3 Types of Information Collected

3.1 When you use the Services or access the Site, Vudoo may collect your Personal Information and Statistical Information – both of which are defined in clauses 3.2 and 3.3 below, respectively. Vudoo will not collect any Sensitive Information from you (being any information (or an opinion) about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices or criminal record, or information about your health, genetic information or biometric information).

3.2 Personal Information includes information which identifies a natural person, or by which the person’s identity may be reasonably determined. It may (potentially) include a person’s full name, mailing or residential address, date of birth, bank account details, credit card details, PayPal account details, phone number and email address, as well as potentially “personal data” for the purposes of the GDPR. For the purpose of this Policy, the term Personal Information also includes personal information obtained from a third party which, under and in accordance with the Privacy Act, may lawfully be exchanged.

3.3 Statistical Information includes the internet protocol (IP) address of your device used to connect to the Site or use the Services, time zone setting, language preferences, location data, information about your browser, phone, hardware and software (including your hardware model, operating system version, device memory, advertising or unique application or device identifiers and (potentially) information about your applications installed, battery level, as well as other information which does not identify you personally, but which tracks your usage of the Site or Services.

3.4 Vudoo also collects information automatically (through the use of cookies and web beacons) on the Site, as discussed in this Policy further below.

4 Personal Information about third parties

4.1 If at any time you supply Vudoo with Personal Information about another person, you should ensure that you have written consent from that person to do so, and you must agree to inform that person about Vudoo and the fact that Vudoo may use and disclose their Personal Information in accordance with and for the purposes outlined in this Policy.

5 How Vudoo Collects Personal Information

5.1 Vudoo will not ordinarily collect any Personal Information about you except where you provide it to Vudoo, or where it is provided to Vudoo with your authority.

5.2 Vudoo collects Personal Information when you:

(a) sign up for and use the Services; and

(b) provide Vudoo with feedback or make a complaint.

5.3 In the event Vudoo receives unsolicited information about you, it will only be collected where: 

(a) such collection is reasonably necessary for one or more of Vudoo’s functions or activities; and

(b) Vudoo either:

(i) obtains your consent; or

(ii) is authorised or required to do so by Law.

5.4 Where clause 5.3 does not apply, Vudoo will (within a reasonably practicable timeframe) destroy any unsolicited Personal Information that Vudoo receives.

6 How Vudoo uses Personal Information

6.1 Vudoo will collect Personal Information for the purposes set out in clauses 6.2 to 6.4 inclusive. Vudoo will make every effort to advise you of the purposes for which Vudoo is required to collect your Personal Information before that Personal Information is to be collected.

6.2 To provide, develop and improve the Services

You authorise Vudoo to use your Personal Information to:

(a) contact you in relation to your use of the Services, including (without limitation) to notify you of any modifications to this Policy;

(b) notify you about any promotions or other communications;

(c) make improvements to the Services and/or the Site. For example, Vudoo may track any troubleshooting issues and compatibility issues with various operating platforms and devices to ensure you have proper and stable access to the Site and the Services, and to implement updates where necessary; and

(d) measure the performance of the Services and to understand how the Services are used.

6.3 To ensure compliance

Additionally, the purposes for which Vudoo will generally collect and use your Personal Information will include collection for the following reasons:

(a) to comply with all Laws (including but not limited to verifying your identity to prevent fraud or other unauthorised or illegal activity);

(b) to co-operate with authorities in relation to any investigation into any User of the Site;

(c) to perform Vudoo’s administrative operations, including accounting, risk management, payment processing, record keeping, archiving, and development and testing; and

(d) to manage Vudoo’s rights and obligations under this Policy;

6.4 Marketing Communications

If you are a User, Vudoo may send you email marketing communications to:

(a) provide you with information about Vudoo’s Services and the Site; and/or

(b) communicate with you for other marketing purposes.

In doing so, Vudoo will always provide you with the option to unsubscribe from Vudoo’s marketing communications. If you do not want to receive marketing communications from Vudoo, please contact Vudoo at

7 Disclosure of Personal Information

7.1 By accessing the Site or using the Services, you consent to the disclosure of your Personal Information in accordance with this Policy.

7.2 Vudoo takes the protection of your Personal Information very seriously. Vudoo will only disclose your Personal Information to its employees, officers, insurers, professional advisers, agents or contractors (including potentially where these parties are based overseas) and insofar as such disclosure is necessary to enable Vudoo to perform its obligations and to act in accordance with this Policy. Such Personal Information will not be disclosed or used other than as specified in this Policy without your express consent, which will be stored in Vudoo’s records.

7.3 Vudoo will not use or disclose your Personal Information for any purpose other than as disclosed in this Policy unless:

(a) Vudoo has obtained your consent to its use or disclosure; or

(b) the purpose is related to the purposes disclosed in this Policy and an individual would reasonably expect Vudoo to use or disclose that Personal Information in that manner.

7.4 Vudoo may also disclose your Personal Information to other third parties from time to time. Subject to what is permitted by Law, the types of third parties to whom Vudoo may disclose your Personal Information may include:

(a) Vudoo’s agents, contractors and external advisors (such as legal and financial advisors) whom Vudoo engages from time to time to carry out, or advise on, Vudoo’s functions and activities;

(b) business partners (eg advertisers);

(c) other Users (eg your username or profile name, the information you have consented to us sharing, and any Content you create on the Site which contains Personal Information); and

(d) regulatory bodies, government agencies, law enforcement agencies and

7.5 Unless otherwise specified in this Policy or as required by Law, you authorise Vudoo to disclose your Personal Information and Statistical Information to third parties:

(a) where Vudoo assigns, transfers, sells or otherwise licenses its rights under any relevant User contractual arrangement to a third party;

(b) where Vudoo reasonably believes (acting in good faith) that such disclosure is necessary in order to investigate, prevent or take action regarding illegal activities (including without limitation suspected fraud), situations involving potential threats to the physical safety of any person, violations of this Policy, or as otherwise required by Law;

(c) in a business transaction including (but not limited to) a merger with or acquisition by another company, or the sale of all or a substantial portion of Vudoo’s assets, of which your Personal Information and Statistical Information may be among the assets transferred. Where this occurs, Vudoo will notify you using the Personal Information provided by you; and/or

(d) where such disclosure is required by Law, or where Vudoo reasonably believes in good faith that such disclosure is necessary to protect Vudoo’s rights.

7.6 You consent to Vudoo disclosing Statistical Information to third parties including, without limitation, to analytics companies and Vudoo’s business partners, to help Vudoo understand usage patterns, to assist in product development and for advertising purposes.

7.7 Vudoo may from time to time disclose your Personal Information to overseas entities who may not be bound by Australian Law. Where Vudoo discloses your Personal Information to overseas recipients, Vudoo will make every reasonable effort in the circumstances to ensure that the overseas recipients comply with this Policy and any applicable Australian Law concerning the protection of Personal Information, unless:

(a) Vudoo believes on reasonable grounds that the overseas recipient is bound by Laws that are substantially similar to the Privacy Act which can be enforced against the overseas recipient; or

(b) you give Vudoo an informed consent to the disclosure of your Personal Information to an overseas recipient who may not be bound by Australian Law; or

(c) the disclosure to an overseas recipient is authorised or required by Australian Law (including the Privacy Act).

8 How Vudoo Uses Cookies and Web beacons

8.1 If you continue to access the Site or use the Services, you agree to Vudoo’s use of tracking technologies, referred to as cookies or web beacons, to track and record your usage. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. Web beacons (also known as Clear GIFs) are small pieces of code placed on a website to monitor visitor behaviour and collect data about the visitor’s viewing of the website.

8.2 When you access or use the Services, Vudoo will automatically use cookies and/or web beacons to collect technical information including:

(a) Statistical Information; and

(b) information about your interaction with the Services, including your clickstream to, through and from the Site, the times you access the Site, activity on third party websites which are linked to the Site.

8.3 You may control the technical information Vudoo collects, including through your browser or device settings. In doing so, you:

(a) acknowledge some of Vudoo’s Services may not function properly if you choose to disable cookies; and

(b) release Vudoo and any of its Related Bodies Corporate from any and all Claims, liability and Losses which may arise out of, result from, or relate in any way to your decision to disable cookies (including any limitation on your ability to use the Services).


9.1 Vudoo will comply with the principles of data protection (including as set out in the GDPR) for the purpose of fairness, transparency and lawful data collection and use.

9.2 Vudoo will process Personal Information as a processor and/or, to the extent relevant, as a controller (as those terms are defined in the GDPR).

9.3 Vudoo must have a legal basis to process Personal Information which it collects. Vudoo relies on several legal bases to process Personal Information in accordance with this Policy, including:

(a) where the person has consented to the processing of Personal Information by Vudoo (which consent may be withdrawn at any time);

(b) for Vudoo’s legitimate interests to operate, provide or improve the Site and/or Services;

(c) where necessary to provide access to, and use of, the Site and/or Services; and/or

(d) where Vudoo is authorised or required by Law to do so.

9.4 Where a person has (directly or indirectly) provided consent to Vudoo processing their Personal Information, the consent may be withdrawn at any time with future effect – i.e. the withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal. If consent is withdrawn, Vudoo will only continue processing the person’s Personal Information where Vudoo is permitted or obliged to do so by Law (including under the GDPR).

10 Your Rights Under this Policy

10.1 This clause 10 sets out the rights you have in relation to how your Personal Information is obtained and used.

10.2 Except as otherwise provided by Law, you have the following rights in connection with your Personal Information we have collected:

(a) the right to be informed how your Personal Information is being used;

(b) the right to access your Personal Information (and Vudoo will provide you with a free copy of it);

(c) the right to correct your Personal Information if it is inaccurate or incomplete;

(d) the right to delete your Personal Information (which is also known as “the right to be forgotten”);

(e) the right to restrict processing of your Personal Information;

(f) the right to retain and reuse your Personal Information for your own purposes;

(g) the right to object to your Personal Information being used; and

(h) the right to object against automated decision making and profiling.

10.3 You are encouraged to contact Vudoo at any time if you wish to exercise your rights in relation to this Policy. Vudoo reserves the right to request you verify your identity before Vudoo acts on any request made by you.

10.4 Alternately, please contact us on

11 Storage of Personal Information
11.1 Vudoo implements a variety of security measures to maintain the safety of your Personal Information. Your Personal Information is held on our servers in a controlled, secure environment where it is protected from unauthorised access, use or disclosure.

11.2 Vudoo's servers may at times be located overseas in countries which are not bound by the Privacy Act, including, without limitation, the United States of America, and you hereby expressly consent to the disclosure of your Personal Information to overseas recipients. In doing so, you agree that Vudoo is not obliged to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information.

12 Security of Personal Information

12.1 Vudoo will use all reasonable efforts to keep secure your Personal Information, Statistical Information and all other information that you transmit to Vudoo through your use of the Site and Services or otherwise. Vudoo will take all reasonable care to protect and prevent unauthorised access to, or modification and disclosure of, your Personal Information.

12.2 Notwithstanding clause 12.1 above, you acknowledge the internet is inherently insecure and no data transmission online can be guaranteed as fully secure. Accordingly, Vudoo cannot guarantee or warrant the security of any information (including Personal Information) you provide through the use of the Site. You understand that any Personal Information you provide to us is done so at your own risk.

12.3 If Vudoo becomes aware of a breach of security in relation to your Personal Information, Vudoo will immediately use its best endeavours to take action to remedy the security breach, in order to limit the risk caused by unauthorised access to, or unauthorised disclosure of, your Personal Information before any serious harm is suffered as a result of the breach.

12.4 If Vudoo becomes aware of a breach of security, and a third party has, without authorisation:

(a) accessed your Personal Information; or

(b) disclosed your Personal Information to another third party, (Data Breach), and a reasonable person would conclude that such unauthorised access or disclosure is likely to result in serious harm to the individuals to whom the information relates, Vudoo will (as required by Law) notify you and the OAIC with details of the Data Breach, including details of how Vudoo believes the Data Breach has occurred and to what Personal Information such Data Breach relates, and the steps that you can take in response to the Data Breach.

12.5 If Vudoo becomes aware of a Data Breach in which your Personal Information is lost, and Vudoo has reasonable grounds to believe that:

(a) unauthorised access to, or unauthorised disclosure of, your Personal Information is likely to occur; and

(b) if unauthorised access to, or unauthorised disclosure of, your Personal Information occurs, a reasonable person would conclude that such unauthorised access or disclosure is likely to result in serious harm to the individuals to whom the information relates, Vudoo will notify you and the appropriate local authority with the details of the Data Breach, including details of how Vudoo believes the Data Breach has occurred and to what Personal Information such Data Breach relates, and the steps that you can take in response to the Data Breach.

12.6 You acknowledge and understand that if you access the Site or the Services from outside Australia, other entities including, potentially, foreign governments, may collect, use and disclose your Personal Information in ways which differ from this Policy and the Laws of Australia, and that we will in such circumstances have no control over such collection of your Personal Information (and are not liable in relation to such collection).

13 How long your Personal Information is stored

13.1 You consent to Vudoo retaining your Personal Information for as long as necessary to fulfil the purposes for which Vudoo has collected it, including in order to satisfy any Law.

13.2 To determine the appropriate retention period for Personal Information, Vudoo will consider the amount, nature and sensitivity of the Personal Information collected from you, the potential risk of unauthorised use or disclosure of your Personal Information, the purposes for which Vudoo processes the Personal Information and whether Vudoo can achieve those purposes through other means. Vudoo will also at all times have regard to the applicable legal requirements under the GDPR and/or the Privacy Act (as applicable).

14 Third parties

14.1 Where Vudoo provides your Personal Information to third parties in accordance with this Policy, you acknowledge and agree that:

(a) the use of your Personal Information by third parties is not in Vudoo’s reasonable control;

(b) third party websites may place their own cookies or other files on your computer or telephone, solicit Personal Information from you and may or may not use your Personal Information in accordance with their own privacy policies which may differ from this Policy; and

(c) it is your responsibility to familiarise yourself with the privacy policy of any third party website you visit which collects Personal Information about you and to use your discretion when providing such information.

14.2 If Vudoo discloses personal information to a third party, Vudoo will always act to protect it in accordance with this Policy. However, you agree that Vudoo will not be liable for any Loss or liability which may be incurred as a result of, or in connection with, or in relation to any use of your Personal Information by a third party to whom Vudoo validly disclosed the Personal Information (and you agree to make no claim against Vudoo in that regard).

15 How to Contact Vudoo

15.1 If you believe that the privacy of your Personal Information has been compromised or has not been used in accordance with this Policy, you should contact Vudoo as soon as possible using the means provided on the Site or at:


16 How to Contact the Office of the Australian Information Commissioner

If you do not receive a satisfactory response from Vudoo, or you believe that Vudoo has not handled your complaint satisfactorily, you may wish to refer your complaint to the OAIC at:

Address: GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992