PRIVACY POLICY

Mirabella International Pty Ltd (“we”, “us” or “our”) is a registered company located in Melbourne, Australia. We are committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we collect, store, use and disclose your personal information.

We are bound to comply with the Australian Privacy Principles (“APP’s”) contained in the Privacy Act (Cth) 1988. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au.

The APP’s and this Privacy Policy govern the way in which we collect, store, use and disclose your personal information.

What personal information do we collect?

Personal information is information or an opinion about an individual, which can be used to identify that individual.

We do not need to know any sensitive information about you (e.g. ethnic origin, political opinions etc.) when you activate an account to use the Mirabella Genio App and will never ask you for this information. Sensitive information includes information about your health, racial or ethnic origin, political opinions, religious beliefs, political associations, sexual orientation, or biometric information.

Personal Information collected in connection with the Mirabella Genio App and Account

The Mirabella Genio App has been developed so that you can use your mobile telephone, tablet or other compatible device to control smart devices which you have purchased from us. The Mirabella Genio App is free (other than any cost associated with the download of the Mirabella Genio App which may be charged to you by your telecommunications service provider). To use the Mirabella Genio App, you must create and activate an account with us when you want to download the Mirabella Genio App.

When you create a Mirabella Genio Account, we may ask you to provide personal information such as your name, postal address, email address and telephone number. This information is to help us to activate, manage and provide ongoing service for the Mirabella Genio App.

You may be able to set up the account using a nickname or pseudonym but if you do not provide all the required personal information, we may not be able to provide you with our products or services.

Your profile picture (if you provide one), country, time zone and location settings will be collected and will be connected to your account.

If you do not want to provide us with your personal information, we might not be able to provide you with our products and services, including but not limited to, alerting you to known software or malware or other issues, or be able to respond to your enquiries.

Picture/video

If you wish to use the Mirabella Genio App to control security cameras purchased from Mirabella, then any pictures or video acquired captured by the security cameras and displayed on the camera on your mobile telephone or other device may also be collected and used to provide mobile monitoring and/or alarm services to you.

User scenario

While you use functions like scenario, automation and so on, we will collect the information you have set which is used to support intelligent scenario service to you.

How do we use your personal information?

We use your personal information for the purpose for which it is collected, and related purposes, which we consider come within your reasonable expectations, or as permitted by law.

The personal information you supply helps us to provide you with customer service. In particular, the personal information that we collect is used to:

· Respond to your questions or suggestions;

· Invite you to participate in surveys relating to your use of Mirabella Genio Smart devices.

· Improve the quality of our products or services (including but not limited to, monitoring our software licenses);

· Provide you with information, promotional materials or marketing about current or new products and services, or products and services which are about to be launched in the future; or

· As notified to you at the time the information is collected.

Your personal information may be used for direct marketing because you agree that you would reasonably expect us to use or disclose such information (other than sensitive information) for that purpose.

Although we do not require any of your sensitive information, if you do volunteer any sensitive information we may use it for direct marketing only if you consent to the use or disclosure for that purpose.

You can unsubscribe from our mailing or marketing lists at any time by contacting us in writing.

Who do we share your information with?

Sending your personal information overseas

Some of your personal information may be processed or stored overseas in one or more foreign countries.

Before that happens, we are required to take reasonable steps to ensure that there are arrangements in place to protect your personal information.

In any event, by downloading the Mirabella Genio App and creating your Mirabella Genio Account you are giving your consent for us to use your personal information in this manner.

Other than as described above, we will never send your personal information to recipients outside of Australia without:

a) Obtaining your consent (in some cases this consent is implied); or

b) Otherwise complying with the APP’s.

We will not trade, rent or sell your personal information to/with any person or organisation.

Security of personal information

We will take reasonable steps to protect all the personal information that we receive from you. Information collected is desensitized and de-identified and stored as encrypted data in major storage areas in China, USA or Europe.

When your personal information is no longer needed for permitted purposes under the Australian Privacy Principles, we will take reasonable steps to destroy or suppress your personal information.

Disclosure to Third Party Service Providers

Your personal data may be disclosed to other companies related to Mirabella International Pty Ltd (e.g. in communications, social media, technology or the cloud business), or third party service providers such as our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, and customer service providers, agents (“Third Party Service Providers”) who will use your personal information for one or more of the permitted purposes disclosed in this Policy.

Personal Information is shared by us to provide or improve our products and services.

Mirabella rely upon and use the services of Google Home, Amazon Alexa and AWS related server services, which may in turn request personal information from you to use those services.

Before you disclose your personal information to any other service provider, we recommend that you first examine the privacy policy of that service provider.

Other Information we may collect from you

We use statistical data that does not specifically identify you (non-personal data) to help in our operations and improve our products and services and provide a better user experience for you. Some examples of the use of your non-personal data which we may collect, include:

a) When you create a Mirabella Genio Account, download our software, register in our e-commerce website, participate in online surveys or interact with us in other ways, we may collect your language preferences, postal code, area code number and time zone in which you use our products and services.

b) When you opt-in to participate in our User Experience Improvement Program, we may gather statistics relating to your use of our products functions, on an anonymous basis. This may include information relating to your use of our official website, products and services. If there is an abnormal shutdown or breakdown, we may collect information relating to your mobile device to diagnose the problem.

c) When you use our services or functions that are based on location information (e.g. carry out a location search, use weather functions, access information based on maps) we may collect your geographical information.

d) When you use our online services, interactive applications, email messages and advertising, we may use cookies and other technical elements (e.g. pixel labels) to collect and store non-personal data. These enable us to provide you with a better experience and improve our overall service quality, e.g. in saving your preferred language settings, sending emails in a readable format, to determine whether the emails have been opened or not.

e) When you use our online services, we may collect log information, e.g. IP address, browser type, language, reference source, operating system, date and time marking and click rate data.

f) When you first use and activate your Mirabella Genio Smart device, the device’s unique identification code and approximate geographical information may be collected.

Cookies are small text files placed on your mobile device or computer by us to automatically collect information about you without you providing that information to us directly. We use cookies to enhance your experience of our online and other services. Most browsers are set by default to accept cookies. However, if you do not wish to receive any cookies you may set your browser to either prompt you whether you wish to accept cookies on a site or by default to reject cookies. If you reject cookies, we may not be able to provide you with all our services.

How you can check and update your personal details and preferences

You have the right to access and correct your personal information and privacy preferences.

You can check and update your details by logging onto your Mirabella Genio Account and selecting:

“Profile - Personal Centre” and select whether you want to terminate the account or amend any of your details.

Alternatively, if you would like us to update or amend your personal details, please contact us at customerservice@mirabella.com.au

We will respond to you within a reasonable period after you make any request to amend or update your personal information.

We will give you access to your personal information or amend it if you cannot amend it on your account online if it is reasonable and practicable to do so.

Privacy Policy Concerns or Enquiries

We are always here to receive your feedback, suggestions or questions so that any problems or concerns are resolved the first time.

If you have any queries or concerns about our Privacy Policy or want to access or amend your personal information, please contact us at customerservice@mirabella.com.au

We will respond to your request within a reasonable time.

Changes to this Privacy Policy

We reserve the right to modify or amend this Policy from time to time by posting the revised Policy on our website or notify you on your account. It is your responsibility to review the Policy from time to time, which we will keep on our website: www.mirabella.com.au

This statement was last updated in October 2018