Unmessy Privacy Policy

California Notice at Collection: See the California law privacy rights section below for important information about your rights under California privacy laws.

Introduction

This Privacy Policy describes how Unmessy and its corporate affiliates (collectively, “Unmessy,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”)).

Unmessy may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. Unmessy provides CRM data cleaning and enhancement services, including data formatting, standardization, deduplication, and email validation services designed to help business customers improve the quality and accuracy of their customer relationship management data.

Data Processor Relationship

For data processing activities where we act as a data processor on behalf of our business customers, this Privacy Policy does not apply to the personal information contained within the customer data we process. Our processing of personal information that we handle on behalf of our customers is governed by our agreements with those customers and their own privacy policies. If you have questions regarding your personal information that appears in data our customers have sent us for processing, please direct your inquiry to the relevant business customer, as they are the data controller for such information.

Our data cleaning services typically involve processing business contact information including:

• Names
• Email addresses
• Phone numbers
• Job titles
• Company information

Our websites, products and services are designed exclusively for business customers and their data management needs. We do not offer products or services for use by individuals for their personal, familial or household purposes. Accordingly, we treat all personal information we encounter in customer data as business contact information pertaining to individuals in their professional capacities.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe” or “European” and should be understood accordingly) below.

Table of Contents

1. Personal information we collect
2. How we use your personal information
3. How we share your personal information
4. Your choices
5. Other sites and services
6. Security
7. International data transfers
8. Children
9. Changes to this Privacy Policy
10. How to contact us
11. California privacy rights notice
12. Notice to European users

Personal Information We Collect

We may collect personal information from or about you from a variety of sources. Below, we describe the various manners in which we may collect such personal information. We may combine your personal information that we obtain from various sources.

Information You Provide to Us or That We Generate About You

Personal information you may provide to us through the Service or otherwise or that we may generate about you, includes:

• Contact data: Your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number
• Account data: Username, password, account preferences, subscription information, and any other information that you add to your account profile
• Demographic data: Your city, state, country of residence, and postal code
• Communications data: Based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise
• Transactional data: Information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history
• User-generated content data: Reviews, comments, questions, messages and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data
• Financial data: Your financial account numbers or payment card information, including corporate payment card information
• Other data: Not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection

Third-Party Sources

We may obtain personal information about you from other sources, such as:

• Public sources: Government agencies, public records, social media platforms, and other publicly available sources
• Private sources: Data providers (including licensors) and social media platforms (such as Meta)
• Customers
• Service Providers: That provide services on our behalf or help us operate the Service or our business
• Marketing partners: Such as joint marketing partners
• Parties to corporate transactions: We may receive personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution or at transfer, divestiture or sale of all or a portion of business or assets

Automatic Data Collection

We, our service providers, and our business partners may automatically log information about you, your device, and your interaction over time with the Service, our communications and other online services. The information collected automatically may be combined or associated with information collected from other sources. The information collected automatically may include:

• Device data: Your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area
• Online activity data: Pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them
• Communication interaction data: Your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails

Cookies

Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How We Use Your Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service Delivery and Operations

We may use your personal information to:

• Provide and operate the Service and our business
• Establish and maintain your user account on the Service
• Enable security features of the Service, such as by sending you security codes via email or SMS
• Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages
• Provide support for the Service, and respond to your requests, questions and feedback

Service Personalization

We may use your personal information to:

• Understand your needs and interests
• Remember the devices from which you have previously logged in
• Personalize your experience with the Service and our Service-related communications
• Remember your selections and preferences as you navigate our digital properties

Research and Development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We compile, derive, and otherwise process de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.

Marketing and Advertising

We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct Marketing

We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Interest-Based Advertising

Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

Service Improvement and Analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Compliance and Protection

We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims)
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies
• Enforce the terms and conditions that govern the Service
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft

Data Sharing in the Context of Corporate Events

We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

With Your Consent

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as:

• The amount, nature, and sensitivity of the personal information
• The potential risk of harm from unauthorized use or disclosure of your personal information
• The purposes for which we process your personal information and whether we can achieve those purposes through other means
• The applicable legal requirements

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates

Our corporate parent, subsidiaries, and affiliates.

Service Providers

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics).

Payment Processors

Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Advertising Partners

Third-party advertising companies for the interest-based advertising purposes described above.

Subscribers

We may share personal information with our subscribers (business customers who subscribe to our CRM data cleaning services) as part of providing our data cleaning and enhancement services. When subscribers send us their CRM data for processing through integrations or bulk uploads, we clean, format, standardize, deduplicate, and validate this data (including email bounce checking where applicable) and return the enhanced data back to the subscriber. In some cases, we may supplement the original data with additional information to improve data quality. We do not control how our subscribers use the personal information we process on their behalf, as they remain the data controllers for such information.

Third Parties Designated by You

We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional Advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and Others

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business Transferees

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Unmessy, financing of Unmessy, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Unmessy as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located in California, and Europe can find additional information about their rights below.

Access or Update Your Information

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-Out of Communications

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and Other Tracking Technologies

For information about cookies and other tracking technologies employed by the Service and how to control them, see our Cookie Notice.

Blocking Images/Clear GIFs

Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to Provide Information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfer

We are headquartered in Australia and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to Contact Us

Email: [email protected]

California Privacy Rights Notice

This section applies only to residents of California. This section describes how we collect, use, and share Personal Information of California residents and the rights California residents may have with respect to their Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the in the California Consumer Privacy Act (“CCPA”) and does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

For purposes of this section, the term “Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms in the applicable State Privacy Laws and does not include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.

Your California Privacy Rights

As a California resident, you have the rights listed below. However, these rights are not absolute, and we may decline your request in certain cases as permitted by law. If you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to your request, we may not be able to process your request.

Information

You can request the following information about how we have collected and used your Personal Information during the past 12 months:

• The categories of Personal Information that we have collected
• The categories of sources from which we collected Personal Information
• The business or commercial purpose for collecting and/or selling Personal Information
• The categories of third parties with which we share Personal Information
• The categories of Personal Information that we sold or disclosed for a business purpose
• The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose

Access

You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Correction

You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion

You can ask us to delete the Personal Information that we have collected from you.

Opt-Out

You can opt-out of the sharing of your Personal Information for interest-based advertising purposes and/or from the sale of your Personal Information (as applicable). We have no actual knowledge that we have sold or shared the Personal Information of California residents under 16 years of age.

Limit Processing of Sensitive Personal Information

We do not knowingly use sensitive personal information (as that term is defined under the CCPA) for purposes that California residents have a right to limit under the CCPA.

Nondiscrimination

You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising Your Rights

Information/Know, Access, Appeal, Correction, and Deletion

You may submit requests to exercise your right to information/know, access, correction, or deletion via email to [email protected].

Opt-Out of “Sale” or “Sharing” of Personal Information

You can submit requests to opt-out of tracking for targeted advertising purposes via email to [email protected] or by broadcasting the global privacy control signal. If our website detects that your browser is transmitting an opt-out preference signal, such as the GPC signal, we will opt that browser out of cookies on our website that result in a “sale” or “sharing” of your personal information. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use to visit our websites.

Verification of Identity; Authorized Agents

We may need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law. Under the CCPA, you may enable an authorized agent to make a request on your behalf upon. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your CCPA rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Deidentification

We may deidentify your Personal Information and disclose this deidentified information to others as permitted by applicable law. Where we deidentify information or use deidentified information, we use the data in a deidentified form and will not attempt to reidentify that information.

Personal Information Categories We Collect, Use and Disclose

We have summarized the Personal Information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal information we collect” section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of Personal Information not described below.

Contact Data

• CCPA statutory category: Identifiers; Commercial information; California customer records
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers

Demographic Data

• CCPA statutory category: Identifiers; Commercial information; California customer records
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers

Account Data

• CCPA statutory category: Identifiers; Commercial information; California customer records
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising)

Communications Data

• CCPA statutory category: Identifiers; Commercial information; California customer records; Internet or network information
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: None

Transactional Data

• CCPA statutory category: Identifiers; Commercial information; California customer records; Financial information
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: None

Marketing Data

• CCPA statutory category: Identifiers; Commercial information; California customer records
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: None

User-Generated Content Data

• CCPA statutory category: Identifiers; Commercial information; California customer records
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers

Financial Data

• CCPA statutory category: Identifiers; Commercial information; California customer records; Financial information
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: None

Other Data

• CCPA statutory category: Identifiers; Commercial information; California customer records; Inferences; Protected classifications
• Sources: You; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Payment processors; Advertising partners; Subscribers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers

Data Collected via Cookies and Similar Technologies

• CCPA statutory category: Identifiers; Internet or Network Information; Inferences
• Sources: You; Your devices; Third-party sources
• Business/Commercial Purposes: Service delivery and operations; Research & development; Marketing & advertising; Service improvement and analytics; Compliance & protection
• Third parties to whom we disclose: Affiliates; Service providers; Advertising partners; Subscribers; Third parties designated by you; Professional advisors; Authorities and others; and Business transferees
• Third parties to whom we “sell” or “share” Personal Information: Advertising partners (to facilitate interest-based advertising); Subscribers

Shine the Light Law

Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Notice to European Users

General

Where This Notice to European Users Applies

The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal Information

References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller

Unmessy is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Our Legal Bases for Processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Notice to European Users are listed below:

• Contractual Necessity: Where we need to perform a contract, we are about to enter into or have entered into with you
• Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out below)
• Compliance with Law: Where we need to comply with a legal or regulatory obligation
• Consent: Where we have your specific consent to carry out the processing for the Purpose in question

We have set out below, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Purpose: Service Delivery and Operations

• Categories of personal information involved: Contact data, Account data, Communications data, User-generated content data, Device data, Financial data, Transactional data
• Legal Basis: Contractual Necessity

Purpose: Research and Development

• Categories of personal information involved: Any and all data types relevant in the circumstances
• Legal Basis: Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Service and how we use Personal Information is as un-privacy intrusive as possible.

Purpose: Service Improvement and Analytics

• Categories of personal information involved: Contact data, Account data, Device data, Online activity data, Communication interaction data
• Legal Basis:
  • Legitimate Interests. We have a legitimate interest in providing you with a good service, which is personalized to you and that remembers your selections and preferences.
  • Consent, in respect of any optional cookies used for this purpose.

Purpose: Direct Marketing

• Categories of personal information involved: Contact data, Account data, Communications data, Marketing data, Communication interaction data
• Legal Basis:
  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.
  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Purpose: Interest-Based Advertising

• Categories of personal information involved: Device data, Online activity data
• Legal basis: Consent

Purpose: Compliance and Protection

• Categories of personal information involved: Any and all data types relevant in the circumstances
• Legal basis:
  • Compliance with Law
  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Purpose: Further Uses

• Categories of personal information involved: Any and all data types relevant in the circumstances
• Legal basis:
  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected
  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes. To determine the appropriate retention period for personal information, we consider:

• The amount, nature, and sensitivity of the personal information
• The potential risk of harm from unauthorized use or disclosure of your personal information
• The purposes for which we process your personal information and whether we can achieve those purposes through other means
• The applicable legal requirements

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other Information

No Sensitive Personal Information

We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling

As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your Rights

General

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access: Provide you with information about our processing of your personal information and give you access to your personal information
• Correct: Update or correct inaccuracies in your personal information
• Delete: Delete your personal information where there is no good reason for us continuing to process it – you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
• Transfer: Transfer a machine-readable copy of your personal information to you or a third party of your choice
• Restrict: Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it
• Object: Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes
• Withdraw Consent: When we use your personal information based on your consent, you have the right to withdraw that consent at any time

Exercising These Rights

You may submit these requests by email to [email protected].

We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with Your Supervisory Authority

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

• For users in the European Economic Area: The contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
• For users in the UK: The contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing Outside Europe

We are an Australian-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe. It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to Territories with an Adequacy Decision

We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).

Transfers to Territories Without an Adequacy Decision

We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases:

• We may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorize for this purpose; or
• In limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.