PRIVACY POLICY
UseVerb is an internet SaaS company that provides an online platform as a service where individuals (Members) can present, advertise themselves, connect, network and communicate with other Members on UseVerb platform (Platform).
To provide these services we need some basic info to set you up as a Member. It is important that you understand how we collect, use and disclose personal information about you that you provide to us.
We are committed to protecting your information and your right to privacy. If you have any questions or concerns about our Privacy Policy (Policy), or our practices with regards to your personal information, please contact us via your Member Settings (settings).
When you use our services, you trust us with your information, and we take our obligations regarding your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.
We recommend that you read this Policy carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue your use of the Services and do not install our App (or delete it if you already installed it).
In this Policy words have the meaning as defined in the Policy, in the UseVerb Member
Agreement, or elsewhere in the documents published on the Platform, and finally as may
reasonably be inferred from the context in which they are used.
Our Platform is operated by Verb Pty Ltd ABN 81 145 485 034 trading as UseVerb (we, our or us). It is available at https://useverb.com/ and via other channels or addresses including our mobile application available on both the Apple App Store and the Google Play Store. Our head office is located at: L3, 218 St Georges Terrace, Perth, Western Australia, Australia.
This Policy relates to your personal information in connection with your use of and access to the UseVerb website (https://useverb.com/), UseVerb-branded applications, UseVerb payment services, and UseVerb tools, including access via mobile devices and apps (collectively, the Services).
Throughout this Policy the terms “you” and “Member” refers to the member wishing to access and/or use the Services, and may include visitors to your UseVerb account/profile acting on your behalf.
You can find out more about us on our website. If you have any questions about this Policy or your personal data, please refer to our Member Settings or contact our data protection manager at [email protected].
By continuing to access or use our Services you acknowledge that you have read and understand the terms of this Policy and agree to its terms.
Importantly, if you do not agree to the terms in the Policy, we ask that you do not make use of our Services or visit our website.
We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. In the event we make any material changes to this Policy we will inform you of such changes in advance through our Services, or by other means, and you will have the opportunity to review the changes before they become effective. By continuing use after a notice of changes is sent, the Member has acknowledged the changes to the Policy and that use of their personal data is subject to the updated Policy, as of its effective date. If you do not agree to any changes to this Policy then you must immediately stop using the Services.
It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).
This Policy applies to the personal information we collect as a controller from:
This Policy also acts as a privacy notice in as far as we provide you with notice on how we collect personal information, the purpose we use it for and the categories of people with whom we will share the information.
This Policy applies to the processing of personal information by us as a controller of the personal information. This means that we are in a position to control the purpose and how the personal information will be processed.
If you provide us with personal information about another person if you are (as example) a recruiter (defined as a Company in the Member Agreement), you may be acting as a controller and provide the person with a copy of this Policy and let them know the ways in which that person’s personal information will be used as set out in this Policy.
In Short: We collect personal information that you provide to us upon registering an account including information such as your name, date of birth, address, contact information, job title, social media handles/URLs.
We collect personal information that you voluntarily provide to us when registering to use and actually using the Services, including our App, or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and the features you use. When you use the Services and/or when you otherwise deal with us, we may collect the following information about you (the Information):
In Short: Some Information – such as IP addresses and/or browser and device characteristics – is collected automatically when you use the Services.
We automatically collect certain Information when you visit our website/app, use or navigate the Services. This Information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage Information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, Information about how and when you use the Services and other technical Information. This Information is primarily needed to maintain the security and operation of the Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect Information through cookies and similar
technologies. You can find out more about this in our Cookie
Policy. When you first access the Platform, or when there
are material changes to it, you will be required to accept our Cookie Policy that appears as a cookie pop-up
banner on the Platform.
In Short: We process your Information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use your Information collected via the Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.
How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your Member Settings. We use the data that we have about you to provide and personalize our Services so that our Services (including ads) can be more relevant and useful to you and others.
We may process your Information for the following purposes:
In Short: We only share Information for Contractual Reasons, to fulfill our Business Purposes, with your Consent or as required by applicable laws.
We only share and disclose your Information in the following situations:
When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
In a group, posts are visible to others in the group. Your membership in groups is private within the group.
Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
When you follow a person or organization, you are visible to others and that “page owner” as a follower.
We let senders know when you act on their message, subject to your settings where applicable.
Subject to your Settings, we let a Member know when you view their profile.
When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).
In Short: We may transfer, store, and process your Information in countries other than your own, but will take all reasonable steps to ensure it is protected.
As we operate internationally, we may transfer your Information across national boundaries. This could include transferring your Information to other companies within our corporate group or to third parties for data storage purposes. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.
If we do transfer your Information across an international border, we will take measures to protect your information in accordance with this Policy and applicable laws. UseVerb relies on European Commission-approved Standard Contractual Clauses as a legal mechanism and protection for data transfers from the EU. These clauses are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of the data. Please see our Data Processing Addendum if it applies to you.
If you have any questions about this, please refer to your Member Settings or contact our Data Protection Manager at [email protected].
We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Services. In such circumstances we will not disclose any Information which can identify you personally.
If you are based in Australia, by providing us with Information, you consent to the disclosure of your Information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy law. You acknowledge that some overseas third parties may not be regulated by the Australian Privacy Act and the Australian Privacy Principles in the Privacy Act and if any third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.
In Short: We are not responsible for the safety of any Information that you share with third party providers who feature or advertise, but are not affiliated with, the Services.
Our website/app may feature links to third party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from our website/app. You should review the policies of such third parties and contact them directly if you have any related questions.
In Short: We keep your Information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is permitted or required by law.
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by general law (such as contract, tax law, accounting requirements or other legal or regulatory requirements). For example, we generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form. Personal data is no longer visible (to other members or to anyone) after the information is no longer kept.
If you choose to close your UseVerb account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below. Information you have shared with others (e.g., through messages, updates or group posts) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services.
When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
In Short: We aim to protect your Information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any
Information we process. However, please also remember that we cannot guarantee that the Internet itself is
100% secure. Although we will use our reasonable endeavors to protect your Information, transmission of personal Information to and from our website/app
is at your own risk. You should only access our services within a secure environment.
In Short: We take steps to ensure that the Services are only used by those over 15 years* of age and we do not knowingly collect data from or market to children under 15 years of age.
We do not knowingly solicit data from or market to children under 15 years of age. By using the Services, you represent that you are at least 15 years of age. If we learn that Information from members less than
15 years of age has been collected, we will deactivate the
relevant account and take reasonable measures to promptly delete such data from our records. If you become
aware of any data we have collected from children under 15 years of age, please contact us immediately via your Member Settings.
(*or the legal age applicable in your jurisdiction)
Summary: If you choose to register or log into our website using a social media account, we may have access to certain Information about you.
We may offer you the ability to register and log-in to our Services using your third-party social media account details (e.g. Facebook, LinkedIn, Twitter etc). Where you choose to do this, we will receive certain Information from your social media provider. The Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture and other Information that you choose to make public. If you log-in using Facebook, we may also request access to other information related to your account, such as friends, check-ins and likes, and you may choose to grant or deny us access to each individual permission.
The Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by other users of those networks and we have no control over that viewing and use and cannot prevent further use of that Information by third parties.
If you choose to link your UseVerb profile to a social media account, Information that you provide to us in the process may be included on your UseVerb profile. Additionally, your contacts on the social media platform(s) (Friends) may be able to see your activity on our website/app. A link to your public profile on the social media site may be added to your UseVerb profile and other members and users of the Services may be able to see any Friends or links (e.g. friends of Friends) via the social network(s) that you have in common with them.
When you interact with us through social media networks, you acknowledge that we may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any Information posted via social media through your use of the Services, or via any third party which you allow to access your content, is posted entirely at your own risk and that by posting to a public platform you make that Information visible to third parties who can use that Information at their discretion.
Please note that we do not control, and are not responsible for, other uses of your Information by your third-party social media provider(s). We recommend that you review their privacy policies to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.
You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Services.
If you have previously given your Consent you may freely withdraw such Consent at any time. You can notify us at [email protected]
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Services and you object or do not provide Consent to us processing your Information, you accept that the Services will no longer be available to you.
If you have given Consent to marketing we may contact you about our services, promotions and special offers. If you no longer wish to receive such Information, you can withdraw your Consent at any time by changing your preferences in your Member Settings or unsubscribing from the communications.
If you have given Consent, we may share your Information with carefully selected third party organizations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a service or your involvement in other related transactions.
We implement security safeguards designed to protect your data, such as HTTPS, TLS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
You may at any time review or change the Information in your account by logging into your UseVerb account.
If you wish to terminate your UseVerb account, please update your account through your Member Settings and we can arrange this for you. Some Information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms of service and/or comply with legal requirements.
In Short: You have certain rights in respect of your Information.
You have certain rights in relation to the Information that we hold about you. Your rights will vary, depending on the country that you live in. Details of some of the rights which might apply to you and how to exercise them are set out below. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further Information in relation to your request to speed up our response. To exercise or discuss any of your rights, please visit your Member Settings.
You may also have the right to restrict our use of your Information, for example during a period in which we are verifying the accuracy of your Information in circumstances where you have challenged the accuracy of that Information.
In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organization on your behalf.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal Information of others without their consent.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.
This section provides supplemental information that applies to residents of California (United States) if we collect their personal data (aka personal identifiable information).
We collect the following categories (CCPA Categories) of personal information from you:
Identifiers: name, address, email address, phone number, IP address, online identifier, account name, or other similar identifiers.
Characteristics of protected classifications under California or Federal law known as “Characteristics of Protected Classifications” such as age, gender and demographical data.
Commercial information from the product used, services rendered or purchases made.
Online usage information from your use of the internet such as browsing history, search history and information regarding your interaction with our Services.
Geolocation data.
Personal information described in California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Inferences drawn from other personal information: Profile reflecting preferences, characteristics, behavior.
Professional/employment related information, audio, electronic, visual or similar information.
Sensitive personal information which may include data generated or shared when you communicate on our Platform (i.e. messages to other Members), the data used to secure your account (login, proof of ID if you are unable to verify your account), data you may add to your settings/profile that may include information about your race or ethnicity.
We collect information and data directly from you when, as an example, you create an account, make a purchase, browse our Platform or otherwise use our Services or interact with other Members. We may also collect information indirectly from activity on the Platform or by use of our Services. We may also collect personal information and data from service providers that provide services on our behalf to you to process payments, verify your information, monitor the Platform, provide and perform analytics on data, maintain databases, conduct marketing, administration and communications services, and provide any supplementary services linked to our Services to you.
We do not sell your personal information, and to be succinct, we also do not sell personal information of individuals under 16 years of age. We do not provide services to children. We do not knowingly collect personal information from children. If you believe we inadvertently collected personal information from a child, please contact us and we will take steps to remove that information.
The CCPA considers ‘sharing’ as disclosing personal information for the purpose of cross-context behavioral advertising, and this includes instances where companies target advertising based on personal information obtained from customers' activities across distinctly branded websites or services. While we share your information, we do not believe that any ‘sharing’ of your information would qualify as a sale of your personal information under the CCPA. We do not share sensitive information.
The CCPA requires us to describe the ‘business purpose’ for which we may disclose your personal information. Our Privacy Policy describes the manner in which we may disclose your personal information in order to provide the Services to you. We can also disclose your personal information as directed by you, such as when you choose to communicate with other Members through our Platform and share your personal information with them. We may disclose your personal information for any of the following ‘business purpose’:
Service providers: such as marketing and advertising service providers, affiliate sites, auditors who verify the performance of our advert placements, cyber, technology and data security service providers, and any service providers contracted with UseVerb as we deem necessary to allow us to provide the Services.
Group companies: entities owned/controlled by us or the entity that acquires us, or that we acquire.
Government authorities and agencies: those agencies with proper authority over us or you.
We do not share your personal information with third parties to allow them to direct market any products to you except as specifically consented by you and as required under the California Civil Code Section 1798.83 (“Shine the Light law”). If you want to opt-out of any sharing for this purpose please send an email requesting opt out in terms of the Shine the Light law to [email protected].
You have the following rights under the CCPA:
If you wish to exercise any of these rights please contact us by email to [email protected].
We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please let us know through your Member Settings or by emailing us at [email protected].
[UK: You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance].
Verb Pty Ltd ABN 81 145 485 034
Last update: 8 June 2023