1
PURPOSE AND SCOPE
1.1
The AIME app (App) and the services provided through it (Services) are owned and operated by Aura Labs Pty Ltd (ABN 50 147 895 99) (Aura/We/Us).
1.2
Aura is committed to maintaining the privacy and security of your personal information and complying with the obligations under the Privacy Act 1988 (Cth) and the applicable Australian Privacy Principles. This policy can be viewed on our website www.aime.app/privacy
1.3
By accessing our website, using the App and using the Services, you consent to the terms of this policy.
1.4
In relation to this policy:
(a)
“User/Users” refers to all individuals who have been given authorised access to or use of the Services and the Shopify store in respect of which the App is being used (Store), including Merchant Users, Store Users and Customers. The use of the terms “You” or “Your” refers to all users of the App and and customers of our website and our products and services;
(b)
“Merchant Users” are owners of Shopify stores who create an account to access the App, use the Services through their Store, and authorise Store Users to access the Services on their or their Store’s behalf; and
(c)
“Store Users” are individuals authorised by a Merchant User to access or use the Store and the Services, including employees, affiliates, or contractors of the Merchant User.
(d)
“Customers” are individuals accessing the Merchant User’s storefront and providing their personal information which Aura collects as part of the Services.
2
AURA COLLECTS YOUR PERSONAL INFORMATION
2.1
Aura provides the App, which is a plug-in service offered to Merchant User’s operating a Shopify store front, and where authorised by the Merchant User, is used by Store Users.
2.2
The Services involve collection and storage of information about how Customers interact with Stores, including features they use, pages they visit, and actions they take.
2.3
“Personal information” is information about an identifiable individual, and may include but is not limited to information such as the individual’s name, email address, phone number, age, bank account details, and accounts and financial information.
3
WHAT PERSONAL INFORMATION WE COLLECT AND HOLD
We will only collect personal information from you if it is reasonably necessary to provide the Services to you.
3.1
Information and content You provide us
(a)
By accessing and using our Services, or by providing personal data directly to us, we may collect personal information necessary to offer and provide the Services you request. When using the App, our website or Services, the information collected may include, for example:
(i)
online identifiers such as IP addresses and User ID;
(ii)
location information, and usage or interaction data within the App or website; and
(iii)
content you provide us including feedback, observations, and content contained therein.
3.2
Sensitive Information
(a)
Some personal information we may collect is considered Sensitive Information under the Privacy Act. Sensitive information that we may collect includes a person’s sexual orientation or preferences. We use this data in integration with the Services, including the ability to tailor the Services to you. Where we collect such data from you we will only do so if it is considered reasonably necessary for us to collect such data for us to perform our functions or activities and you consent, or collection is required by law or another exception under the relevant laws applies.
(b)
We may also collect information that is necessary for a service to be provided, when you fill in a form on our website or when you ask to be included in an email list.
3.3
Information we collect from others
(a)
We may collect information from third parties, such as from Merchant Users, Store Users and other users of the Services, including your name, contact details and transaction details. We may also collect information and communications about you that other people provide when they use our services.
(b)
Our clients may use our services in their workplace or business. This means we may collect personal information that the client may send to us either manually or automatically through our services. In most situations we collect personal information about an individual from the client where the Customer has accessed the Store or the Merchant User’s website.
3.4
Information we collect from use of our online services
(a)
We may collect a variety of information from your interaction with the Store, website or the Services, including your IP Address, the date, time and duration of your visit, the number of pages you have downloaded, and the type of browser you use.
4
HOW WE COLLECT YOUR PERSONAL INFORMATION
4.1
We will generally collect personal information directly from you when:
(a)
as a user of the App, you:
(i)
interact with product items within the App UI components; or
(ii)
Interact with items outside of the App UI components in order to measure affinity scores associated with a product and the App’s performance; and
(b)
as a Merchant User you initiate specific actions within your Store, including enabling or disabling the App;
4.2
We may also be required to collect personal information about you from a third party. These parties may include Merchant Users, our clients, your representatives, brokers or other publicly available sources. We also collect your information from our analytics providers.
4.3
Through your use of the Services, Aura may also collect information from you about someone else. If you provide Aura with personal information about someone else, you must ensure that you are authorised to disclose that information to Aura and that, without Aura taking any further steps required by applicable data protection or privacy laws, Aura may collect, use and disclose such information for the purposes described in this policy.
4.4
This means that you must take reasonable steps to ensure the individual concerned is aware of and/or consents to the various matters detailed in this policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to obtain access to that information and Aura’s identity.
4.5
Where requested to do so by Aura, you must also assist Aura with any requests by the individual to access or update the personal information you have collected from them and entered into the App.
5
THE PURPOSES FOR WHICH AURA COLLECTS, HOLDS, AND USES YOUR PERSONAL INFORMATION
5.1
Aura collects and uses your personal information so that we can provide you with the Services and any related services you may request. Aura collects and uses different types of personal information for different purposes.
5.2
The App collects, holds and uses your personal information both locally and remotely as follows:
(a)
locally stored personal information is retained on App users’ devices and is not passed to Aura’s remote services. This personal information includes product affinity scores, and excludes any personally identified information of the individual.
(b)
Remotely stored personal information includes anonymised affinity scores associated with product interactions and product specific information including available, description, interactions, and mathematical representations of the associated imagery and display text.
5.3
Aura may also use the personal information we have collected from you for purposes related to the Services including to:
(a)
verify your identity;
(b)
administer the Services;
(c)
notify you of new or changed services offered in relation to the Services;
(d)
carry out marketing or training relating to the Services;
(e)
assist in the understanding of client and user needs to create development priorities;
(f)
assist in the internal testing of products and services;
(g)
gather and aggregate information for statistical and research purposes;
(h)
maintain your account and your details;
(i)
take measures to detect fraud;
(j)
perform our internal administration and operations (including distributing payments to our clients, accounting, reporting, risk management, record-keeping, archiving, systems development and testing and staff training);
(k)
comply with laws and regulations in applicable jurisdictions; and
(l)
communicate with you.
5.4
By using the Services, you consent to your personal information being collected, held and used in this way and for any other use you authorise. Aura will only use your personal information for the purposes described in this policy or otherwise with your express permission.
5.5
We agree to not use or disclose your personal information for a secondary purpose unless you consent to us doing so, or under the circumstances involved we believe you would reasonably expect us to use or disclose the information for a secondary purpose and that that secondary purpose is related to the primary purpose of collection.
5.6
If you are the Merchant User or Store User, it is your responsibility to keep your password to the Services safe and should notify us as soon as possible if you become aware of any misuse of the password, and immediately change the password within the App.
6
AURA CAN AGGREGATE YOUR NON-PERSONALLY IDENTIFIABLE DATA
6.1
By using the Services, you agree that Aura can access, aggregate and use non-personally identifiable data Aura has collected from you. This data will in no way identify you or any other individual. Aura may use this aggregated non-personally identifiable data to:
(a)
assist us to better understand how other merchants, users and customers are using the Services,
(b)
provide other merchants and users with further information regarding the uses and benefits of the Services,
(c)
enhance business productivity, including by creating useful business insights from that aggregated data, and
(d)
otherwise to improve the Services.
7
ANONYMITY AND PSEUDONYMITY
7.1
We will generally need to know who you are in order to provide you with our products and services. Where it is reasonable and practicable we may allow you to transact with us anonymously or by using a pseudonym, such as where you make a general enquiry.
7.2
However, this is not possible if we are required or authorised by law or other instrument to deal with people who have been appropriately identified, or where it is impracticable for us to deal with individuals who have not identified themselves or who would prefer to use a pseudonym.
8
STORAGE AND SECURITY YOUR PERSONAL INFORMATION
8.1
Aura is committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your personal information is stored within secure systems that are protected in controlled facilities. Our employees and authorised agents are obliged to respect confidentiality of any personal information held by us.
8.2
The internet is not in itself a secure environment and we cannot give an absolute assurance that your information will be secure at all times. Transmission of personal information over the Internet is at your own risk and you should only enter, or instruct the entering of, personal information to the Services within a secure environment.
8.3
We will only keep your personal information for as long as we require it for the purposes of providing you with the Services. However, we may also be required to keep some of your personal information for specified periods of time, for example under certain laws relating to businesses and financial reporting legislation.
8.4
Where personal information is no longer needed for any purpose, we will ensure that it is effectively and securely destroyed or de-identified.
9
THE PURPOSES FOR WHICH AURA COLLECTS, HOLDS, AND USES YOUR PERSONAL INFORMATION
9.1
We may disclose your personal information to third parties for the purposes contained in this Privacy Policy, including to:
our related companies/entities, in which
(a)
our related companies/entities, in which case we require our related companies/entities to honour this Privacy Policy. In the event we are involved in a merger, acquisition or sale of assets we may disclose personal information collected by us to such entities that we propose to merge with or be acquired by, and will assume the rights and obligations regarding your personal information as described in this Privacy Policy;
(b)
service providers, whom we use to provide you with services that we offer including those that verify your identity, assist in processing transactions, information technology service providers, mailing houses and market research organisations, and organisations that provide us with professional advice such as lawyers, accountants and business advisers, and business partners;
(c)
third parties where we reasonably believe there has been an infringement of your rights or those of a third party and disclosure of your information may remedy or assist in the remedy of the infringement;
(d)
other parties to transactions when you use the Services, such as other users, merchants and their service providers. We may share information with the other participants in your transactions to facilitate the transaction and to help resolve disputes and detect and prevent fraud;
(e)
the client in respect of whose product or service the information was collected and other organisations that are contracted to our client to provide services in relation to the information collected;
(f)
our clients where they are contracted to provide you with our products or services in relation to the information collected; and
(g)
third parties where we believe in good faith we are required to do so by law, or an exception applies under the Privacy Act or with your consent.
9.2
Notwithstanding the above, we may disclose aggregate information and other information that does not personally identify you to such third parties as we may see fit.
10
CROSS-BORDER DISCLOSURE
10.1
We will not disclose your personal information to third-party service provider(s) located overseas.
10.2
Australian Privacy Principle 8 provides in subclause 8.1 that, if we chose to disclose personal information about an individual to a person overseas, we must first take such steps as are reasonable in the circumstances to ensure that the person overseas does not breach the Australian Privacy Principles (other than Australian Privacy Principle 1) in relation to the information.
10.3
However, if you consent to our disclosure of Your personal information to overseas recipients, that subclause 8.1 will not apply to that disclosure and we will not be accountable for disclosure of your personal information under the Privacy Act.
10.4
If we are required to share your information with organisations overseas we ensure to take reasonable steps to ensure that the recipient complies with the Australian Privacy Principles or is subject to law or binding scheme that has the effect of protecting the information in a way that is substantially similar to the Australian Privacy Principles in relation to the collection, use, disclosure, storage and destruction or de-identification of personal information.
11
IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION
10.1
If you do not provide us with the personal information we have requested, we may not be able to provide you with the Services.
12
NOTIFIABLE DATA BREACH
12.1
In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in the Privacy Act 1988 (Cth), we will take all reasonable steps to contain the suspected or known breach where possible and follow the following process set out in this clause.
12.2
We will take immediate steps to limit any further access or distribution where possible. If we have reasonable grounds to suspect that the data breach is likely to result in serious harm to any individuals involved, then we will take all reasonable steps to ensure an assessment is completed within 30 days of the breach or sooner if possible. We will follow the guide published by the Office of the Australian Information Commissioner (if any) in making this assessment.
12.3
If we reasonably determine that the data breach is not likely to result in serious harm to any individuals involved or any remedial action we take is successful in making serious harm no longer likely, then no notification or statement will be made.
12.4
Where, following an assessment and undertaking remedial action (if any), we still have reasonable grounds to believe serious harm is likely, as soon as practicable, we will provide a statement to each of the individuals whose data was breached or who are at risk. The statement will contain details of the breach and recommendations of the steps each individual should take. We will also provide a copy of the statement to the Office of the Australian Information Commissioner.
12.5
We will then review the incident and take action to prevent future breaches.
13
YOU MAY REQUEST ACCESS TO YOUR PERSONAL INFORMATION
13.1
You may request access to the information we hold about you, or request that we update or correct any personal information we hold about you, by setting out your request in writing and sending it to us at privacy@thisisaura.com.
13.2
Aura will process your request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why.
14
CORRECTION OF PERSONAL INFORMATION
14.1
If you require access in order to correct your personal information, you will need to establish why the correction is necessary. We will then take reasonable steps to correct your information within a reasonable period of time, so that it is accurate, up-to-date, complete, relevant and not misleading. We may also correct your personal information if we determine that it is inaccurate, out of date, incomplete, irrelevant or misleading.
14.2
In certain circumstances we may refuse to update or correct the information held, if we do, we will provide you with a reason why.
15
AURA USES COOKIES
14.1
In providing the Service, Aura utilises “cookies”. A cookie is a small text file that is stored on your computer for record-keeping purposes. A cookie does not identify you personally or contain any other information about you but it does identify Your computer.
16
YOU CAN OPT-OUT OF ANY EMAIL COMMUNICATIONS
16.1
From time to time we may also use your personal information to let you know about other products and services from us that you might be interested in, but we will not if you tell us not to.
16.2
If you are a Merchant User, Aura may send billing information and product information to you via email and if you are a User, Aura may send marketing announcements, service updates and service notifications to you via email. Our emails will contain clear and obvious instructions describing how you can choose to be removed from any mailing list not essential to the Service. Aura will remove you at your request.
17
AURA HAS A PRIVACY COMPLAINTS PROCESS
17.1
If you wish to complain about how we have handled your personal information, please provide our Privacy Officer with full details of your complaint and any supporting documentation by email at privacy@thisisaura.com.
17.2
Our Privacy Officer will endeavour to:
(a)
provide an initial response to your query or complaint within 10 business days, and
(b)
investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
17.3
If you are still not satisfied, you can contact the Office of the Australian Information Commissioner:
Office of the Australian information Commissioner
Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address: GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
www.oaic.gov.au
18
THIS POLICY MAY BE UPDATED FROM TIME TO TIME
14.1
Aura reserves the right to change this policy at any time, and any amended policy is effective upon posting to the App or our website. Your continued use of the Services will be deemed acceptance of any amended policy. From time to time we will review our policy to keep pace with changes in our Services and any data protection laws. This document is our most recently updated Privacy Policy.
14.1
Last updated: 29 August 2025
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