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Privacy Policy

This Privacy Policy was published on 07/04/2023 and last updated on 10/04/2023.

By using Our Site and Service, You acknowledge and agree to the terms and conditions of this Privacy Policy. By using Our Site and Service, it shall constitute or be deemed to constitute Your express prior written consent to the terms and conditions of this Privacy Policy. We encourage You to carefully read, review, and understand Our Privacy Policy in its entirety to gain a full understanding of Our commitment to protecting Your Personal Data and Information, Your Sensitive Personal Data and Information, and the specific ways in which We may collect, process, use, disclose, store, retain, share, transfer, delete, and protect Your Personal Data and Information and may collect, use, and disclose Your Sensitive Personal Data and Information. When We do so, We may be subject to various laws in the Australia (“AU”) and We comply with the same.

If You have any questions or concerns regarding Our Privacy Policy or data practices and standards, please do not hesitate to contact Us using the contact information provided in this Privacy Policy. We are always available to address Your concerns and provide further clarification on Our commitment to safeguarding Your privacy.

1. Definitions

1.1 “Applicable Law and Regulations” refers to all federal, state, and local laws, statutes, regulations, directives, guidelines, and other legal requirements, and any applicable judicial or administrative interpretations, decisions, or rulings that govern, regulate, or pertain to the collection, processing, use, disclosure, storage, retention, sharing, transferring, deletion, and protection of Your Personal Data and Information and collection, usage, and disclosure of Your Sensitive Personal Data and Information. This includes, but is not limited to, data protection and privacy laws, consumer protection laws, and any other relevant laws or regulations that may apply to Our business operations, Site, and the Service, in the jurisdictions in which We operate or provide the Site and the Service.

1.2 “Partners” mean any person, individual, or entity that may be engaged in a professional relationship with Us in connection with the provision of various products, services, support, and/or collaboration on Our Site to Our Users. The Service of the Partners may be listed and displayed on Our Site.

1.3 “Personal Data and Information” means data and information that may identify, relate to, describe, may be reasonably capable of being associated with, or may reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include publicly available data and information or lawfully obtained, truthful data and information that is a matter of public concern, and de-identified data and information. For purposes of this paragraph, “publicly available” means data and information that is lawfully made available from federal, state, or local government records, or data and information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media; or data and information made available by a person to whom the consumer has disclosed the data and information if the consumer has not restricted the data and information to a specific audience. “Publicly available” does not mean biometric data and information collected by a business about a consumer without the consumer’s knowledge.

1.4 “Personnel” means any individual who may be employed or otherwise engaged by Us, Our Partners, or any third-party service providers, persons, or entities, as the case may be and as the context shall indicate, including, but not limited to, full-time and part-time employees, consultants, agents, advisors, officers, directors, or representatives. Personnel are responsible for performing tasks and services on behalf of Us, Our Partners, or any third-party service providers, persons, or entities, as the case may be and as the context shall indicate, in accordance with their respective roles, duties, and responsibilities, and are subject to Our, Our Partners’, or the third-party service providers’, persons’, or entities’ internal policies, procedures, and guidelines, and the Applicable Law and Regulations, as the case may be and as the context shall indicate, relating to the collection, processing, use, disclosure, storage, retention, sharing, and transfer of Your Personal Data and Information and the collection, usage, and disclosure of Your Sensitive Personal Data and Information.

1.5 “Sensitive Personal Data and Information” means Personal Data and Information that may reveal the following of a consumer: their social security, driver’s license, state identification card, or passport number, account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, or union membership. Sensitive Personal Data and Information does not include publicly available data and information.

1.6 “Service” refers to a wide range of products, services, tools, features, functionalities, resources, and content that may be provided by Us and that may be made available to the Users through the Site.

1.7 “Site” refers to the website hosted, operated, and maintained by Us, including all pages, subdomains, and related online platforms accessible through the Site’s domain, and any associated mobile applications or other digital interfaces that may be provided by Us for the purpose of offering information, resources, tools, or Service to its Users.

1.8 “User” or “Users” mean persons/customers who may purchase, access, and use Our Site and the Service, prospective customers (includes persons We think may be interested in Our Service and persons who have expressed interest in obtaining or learning more about Our Service), current customers (includes persons who purchase Our Service from Us), past customers (includes persons who have purchased Our Service from Us but do not currently hold any active accounts with Us).

1.9 “We” or “Us” or “Our” or “Ours” means Family.Estate, any of Family.Estate’s related Bodies Corporate, any of Family.Estate’s associated affiliates, Family.Estate’s group entities, other companies in the Family.Estate group, and their respective Personnel.

1.10 “Your” or “Yours” or “You” means Our Users.

2. About Us

2.1 Overview. We are a lead generation business in the Australia. We match Our Users with Our Partners, i.e., businesses, as per Our Users’ choices, needs, requirements, and preferences. We do not provide any legal advice or services, including, but not limited to, legal representation, drafting of legal documents, or consultation on legal matters. We understand the importance of data privacy and protection and are committed to protecting the privacy, security, and integrity of Your Personal Data and Information and Sensitive Personal Data and Information. This Privacy Policy outlines Our Personal Data and Information collection, processing, use, disclosure, storage, retaining, sharing, transferring, deletion, and protection practices and standards and Our Sensitive Personal Data and Information collection, usage, and disclosure practices and standards, and Your rights and choices concerning Your Personal Data and Information and Your Sensitive Personal Data and Information. By accessing and using Our Site and the Service, You agree to the terms of this Privacy Policy.

2.2 Scope of this Privacy Policy. This Privacy Policy applies to: (i) Us and Our Personnel; (ii) Our Partners their respective Personnel; and (iii) You. This Privacy Policy covers the Personal Data and Information and Sensitive Personal Data and Information of You and Our Partners and their respective Personnel.

2.3 Purpose of Personal Data and Information Collection, Processing, Use, Storage, Retaining, Transferring, and Protection. We may collect, process, use, disclose, store, retain, share, transfer, delete, and protect Your Personal Data and Information for reasonable purposes only, which may include:

a. To provide, maintain, develop, improve, and enhance Our Site and the Service FOR the performance of Our contract with You or to take steps at Your request before entering into a contract;

b. To ensuring a secure and personalized User experience and tailor Our Site and the Service to Your choices, needs, requirements, and preferences FOR customizing Our Site and the Service according to individual User needs, providing a more secure and relevant experience;

c. To communicate with You about updates, promotions, or any other relevant information FOR keeping the Users informed about essential updates, offers, and news related to Our Site and the Service, ensuring they have access to the latest information;

d. To process transactions, investigating and rectifying complaints received, verify Your identity, and prevent, detect, and protect against fraud, check Your credit FOR: (i) Our legitimate interests or those of a third-party, i.e., to minimize fraud that could be damaging to Us, Our Users, Our Partners, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services; (ii) protecting and maintaining the privacy, security, and integrity of Our Site and the Service by verifying User identities and ensuring smooth transactions; and (iii) complying with Our legal and regulatory requirements and obligations;

e. To screen for financial and other sanctions or embargoes FOR complying with Our legal and regulatory requirements and obligations;

f. To assist Our Partners FOR providing You with updates or information about their products and services and provide You with reminders;

g. To ensure Our internal policies, procedures, and guidelines are adhered to (e.g., policies covering security and internet use) FOR Our legitimate interests or those of a third-party, i.e., to ensure We are following Our own internal rules and regulations so We can deliver the Site and the Service effectively and efficiently to You;

h. To adjust for operational reasons, including improving efficiency, training, and quality control FOR Our legitimate interests or those of a third-party, i.e., to effectively and efficiently deliver the Site and the Service at appropriate prices;

i. To ensure the confidentiality of Your commercially sensitive information FOR Our legitimate interests or those of a third-party, i.e., to protect trade secrets and other commercially valuable information, and complying with Our legal and regulatory obligations and requirements;

j. To prevent unauthorized access and modification to the systems, servers, network of systems, and network of servers connected to Our Site and/or Service FOR Our legitimate interests or those of a third-party, i.e., to prevent and detect criminal activity that could be damaging for Us, Our Users, Our Partners, and for any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services and complying with Our legal and regulatory obligations and requirements;

k. To update and enhance Our customer records FOR the performance of Our contract with You or take steps at Your request before entering into a contract, complying with Our legal and regulatory obligations, and Our legitimate interests or those of a third-party (e.g., to ensure We can stay in touch with Our Users about their existing orders and new products or services);

l. To ensure statutory returns FOR complying with Our legal and regulatory obligations and requirements;

m. To ensure safe and working practices, staff administration, and assessments FOR Our legitimate interests or those of a third-party, i.e., to ensure We are following Our own internal rules and regulations so We can deliver the Site and Service effectively and efficiently to You and complying with Our legal and regulatory obligations and requirements;

n. To market Our Site and the Service to prospective, current, and past customers and any third parties who have expressed their interest in Our Service or any third-party with whom We have had no previous dealing FOR Our legitimate interests or those of a third-party, i.e., to promote Our business to prospective, current, and past customers;

o. To conduct audits and quality checks FOR Our legitimate interests or those of a third-party, i.e., to maintain Our accreditations, if any, so We can demonstrate We operate at the highest standards and complying with Our legal and regulatory obligations and requirements;

p. To perform research, analysis, and product development FOR gathering insights and data that help Us improve Our Site and the Service, develop new products, and stay ahead in the market and Our legitimate interests or those of third-party, i.e., to effectively and efficiently deliver the Site and the Service to You at appropriate prices;

q. To comply with legal, regulatory, and contractual obligations and requirements FOR ensuring Our operations remain compliant with all Applicable Laws and Regulations, and contractual obligations and requirements and safeguarding Us, Our Partners, Our Users, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services;

r. To gather and provide information required by or relating to audits, enquiries, or investigations by regulatory bodies FOR complying with Our legal and regulatory obligations;

s. To protect the rights, property, or safety of Us and Our Personnel, Our Users, Our Partners and their Personnel, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services FOR safeguarding the rights, property, and safety of all parties involved in Our operations, ensuring a safe and secure environment;

t. Any other purpose as may be outlined specifically under this Privacy Policy.

2.4 Purpose for Sensitive Personal Data and Information Collection, Use, and Disclosure. We may collect, use, and disclose Your Sensitive Personal Data and Information for reasonable purposes only, which may include:

a. Compliance with Legal and Regulatory Obligations and Requirements: We may collect, use, and disclose Sensitive Personal Data and Information to comply with applicable legal and regulatory obligations and requirements, including, but not limited to, responding to lawful requests from law enforcement, regulatory bodies, or courts, and fulfilling any reporting or disclosure requirements.

b. Identity Verification and Fraud Prevention: We may collect, use, and disclose Sensitive Personal Data and Information to verify Your identity, protect against fraud, and ensure the privacy, integrity, and security of Our Site and Service.

c. Provision of the Site and the Service: We may collect, use, and disclose Sensitive Personal Data and Information to provide You with the Site and the Service, including, but not limited to, tailoring Our Site and Service to meet Your specific choices, needs, requirements, and preferences.

d. Health, Safety, and Well-being: In certain circumstances, We may collect, use, and disclose Sensitive Personal Data and Information to protect the health, safety, and well-being of Us and Our Personnel, Our Users, Our Partners and their Personnel, and any third-party, person, or entity.

e. Equal Opportunities Monitoring: We may collect, use, and disclose Sensitive Personal Data and Information for the purposes of monitoring equal opportunities, promoting diversity and inclusion, and ensuring compliance with anti-discrimination laws and regulations.

f. Consent-Based Purposes: We may collect, use, and disclose Sensitive Personal Data and Information for purposes based on Your express prior written consent, including, but not limited to, providing personalized services or offers, conducting research or surveys, and enabling participation in contests or promotional events.

2.5 Legal Basis for Personal Data and Information Collection, Processing, Use, Disclosure, Storage, Retaining, Transferring, Deletion, and Protection. We may collect, process, use, disclose, store, retain, share, transfer, delete, and protect Your Personal Data and Information in accordance with the Applicable Laws and Regulations. The legal basis for Our data collection, processing, use, disclosure, storage, retaining, sharing, transferring, deletion, and protection activities may include:

a. Consent: We may collect, process, use, disclose, store, retain, transfer, delete, and protect Your Personal Data and Information when You have provided Your express prior written consent for specific purposes, including when We may ask for Your consent to send You marketing communications or to collect, use, and disclose Your Sensitive Personal Data and Information.

b. Contractual Obligations: We may collect, process, use, disclose, store, retain, transfer, delete, and protect Your Personal Data and Information to fulfill Our contractual obligations when You may enter into a contract with Us, such as providing You with the Site and the Service.

c. Legal Compliance: We may collect, process, use, disclose, store, retain, transfer, delete, and protect Your Personal Data and Information to: (i) comply with Applicable Laws and Regulations, court orders, subpoenas, investigations, warrants, lawful requests from public authorities, or other legal processes that may have been served upon Us, or as otherwise may be required by law; (ii) respond to claims, allegations, or notices that any content submitted, posted, uploaded, or otherwise that may have been made available on or through the Site and/or the Service that may infringe, misappropriate, or otherwise violate the intellectual property rights, proprietary rights, privacy rights, or any other rights of any User or third parties; or (iii) protect and defend the rights, property, or safety of Us and Our Personnel, Our Users, Our Partners and their Personnel, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services, as may be required or permitted by law, including, but not limited to, preventing or addressing issues of fraud, security, or technical issues.

d. Legitimate Interests: We may collect, process, use, disclose, store, retain, transfer, delete, and protect Your Personal Data and Information for Our legitimate interests, such as improving Our Site and the Service, providing customer support, or protecting the privacy and security of Our Site and the Service, as long as such interests do not override Your fundamental rights and freedoms. For example, We may analyze Your usage data to enhance Our Site’s and the Service’s User experience or detect fraudulent activity on Our Site and the Service.

e. Any other legal basis as may be outlined specifically under this Privacy Policy.

3. Third-Party Links and Services

3.1 Overview. . Our Site and the Service may engage and/or contain links to content, websites, resources, or services provided by third-party service providers, persons, or entities, including, but not limited to, advertisers, sponsors, legal, accounting, insurance, and business advisory consultants services, and any other third-party websites, platforms, and services, for the purpose to perform various functions on Our behalf, including, but not limited to, data analytics, data aggregation, and for the purposes laid down in this Privacy Policy for data collection, processing, use, storage, retaining, transferring, disclosure, deletion, and protection. Our Site and the Service may engage and/or contain links to content, websites, resources, or services provided by Our Partners (though Our Partners are not a third-party per se) for the purposes laid down in this Privacy Policy for data collection, processing, use, storage, retaining, transferring, disclosure, deletion, and protection. Such content, websites, resources, or services by Our Partners (though Our Partners are not a third-party per se) and/or third-party service providers, persons, or entities are not operated or controlled by Us. Our Partners (though Our Partners are not a third-party per se) and third-party service providers, persons, and entities may obtain Your Personal Data and Information and Sensitive Personal Data and Information through Us. Our Partners and these third-party service providers, persons, and entities are required to maintain the confidentiality of Your Personal Data and Information and Sensitive Personal Data and Information to implement security measures consistent with Our own.

3.2 Third-Party Privacy Practices and Standards. Please be cautious and mindful that the data privacy and protection practices and standards of any content, websites, resources, and services by Our Partners (though Our Partners are not a third-party per se) and third-party service providers, persons, and entities may differ from Our own. Although We carefully select the Partners (though Our Partners are not a third-party per se) and third parties and mandate compliance with Applicable Laws and Regulations and monitor their performance regularly to ensure that they continue to maintain appropriate data protection, privacy, and security standards, We are not liable and responsible for the data privacy or data practices and standards or the content, websites, resources, or services of Our Partners (though Our Partners are not a third-party per se) and the third-party service providers, persons, and entities. We encourage You to review the privacy policies and other applicable agreements, policies, or guidelines of Our Partners (though Our Partners are not a third-party per se) and these third-party service providers, persons and entities, to understand their data practices and standards before providing them with Your Personal Data and Information and Sensitive Personal Data and Information.

3.3 User Responsibility. It is Your risk, liability, and responsibility to review and understand the privacy policies, practices, and standards of Our Partners (though Our Partners are not a third-party per se) and any third-party service provider, person, or entity You may choose to interact with on Our Site. By accessing and/or using the content, websites, resources, or services by Our Partners (though Our Partners are not a third-party per se) and third-party service providers, persons, and entities, You acknowledge and agree that We are not responsible and liable for the data privacy and protection practices and standards or the handling of Your Personal Data and Information and Sensitive Personal Data and Information by Our Partners and such third parties.

4. Compliance with Data Protection Laws, Data Privacy Laws, and any other Applicable Laws and Regulations in the Australia

4.1 Commitment to Compliance. We are committed to complying with all Applicable Laws and Regulations that may apply to Our business operations. This Privacy Policy outlines Our approach to ensuring compliance with Our legal and regulatory obligations and requirements.

4.2 Data Protection Officer. We have designated a Data Protection Officer (“DPO”) who is responsible to oversee Our data protection and privacy practices and standards, and ensuring compliance with Applicable Laws and Regulations. The DPO can be contacted at [email protected].

4.3 Staff Training and Awareness. We provide regular training and awareness programs for Our Personnel to ensure they understand and adhere to Our data protection and privacy policies, and Applicable Laws and Regulations. This includes training on the handling of Your Personal Data and Information and Sensitive Personal Data and Information, data privacy and security, and incident response procedures.

4.4 Data Protection Impact Assessments. Where required by Applicable Laws and Regulations, or as part of Our internal risk management processes, We may conduct Data Protection Impact Assessments (“DPIAs”) to identify and mitigate any potential risks to the privacy and security of Our Users’ Personal Data and Information and Sensitive Personal Data and Information.

4.5 Security Measures. We have implemented appropriate technical and organizational measures to protect the privacy and security of Your Personal Data and Information and Sensitive Personal Data and Information, in accordance with applicable data protection and privacy laws.

4.6 Cooperation with Regulators. We are committed to cooperating with data protection and privacy regulators in the Australia and will attempt to promptly respond to any inquiries or requests for information from such regulators. We will also endeavor to take appropriate action to address any identified non-compliance with Applicable Laws and Regulations.

4.7 Updates and Changes to Compliance. We continually monitor and review Our data protection and privacy practices and standards to ensure ongoing compliance with Applicable Laws and Regulations. We will update Our Privacy Policy and related procedures as may be deemed necessary and appropriate by Us to reflect any changes or amendments in Our practices and standards or the Applicable Laws and Regulations.

4.8 Rights and Responsibilities. We respect Your rights under applicable data protection and privacy laws, including the right to access, correct and/or update, and delete Your Personal Data and Information, and the right to object to the collection, processing, usage, disclosure, storage, retention, sharing, and/or transfer of Your Personal Data and Information, and the right to limit the collection, usage, and disclosure of Your Sensitive Personal Data and Information. We will respond to any requests to exercise these rights in accordance with the Applicable Laws and Regulations. Users also have the responsibility to provide accurate and up-to-date Personal Data and Information and Sensitive Personal Data and Information, and to inform Us of any changes to their Personal Data and Information and Sensitive Personal Data and Information.

4.9 Frequency to Exercise Your Privacy Rights. According to the Applicable Laws and Regulations, You may exercise Your privacy rights no more than twice in a 12-month period. We are not obligated to provide You Personal Data and Information in exercise of Your privacy rights no more than twice in a 12-month period.

4.10 Record Keeping. We maintain accurate and up-to-date records of Our data activities, including the types of Your Personal Data and Information We may collect, process, use, disclose, store, retain, share, transfer, delete, and protect, types of Your Sensitive Personal Data and Information We may collect, use, and disclose, the purposes for which Personal Data and Information and Sensitive Personal Data and Information is used, the Parties with whom Personal Data and Information is shared, and any other relevant information required by Applicable Laws and Regulations. We may make these records available to regulators upon request.

4.11 Audits and Inspections. We regularly conduct audits and inspections of Our data protection and privacy practices and standards to ensure ongoing compliance with the Applicable Laws and Regulations. These audits may be conducted internally or by independent third-party auditors. We will address any identified non-compliance issues and implement appropriate corrective actions.

4.12 Policy Enforcement. We take any violations and breaches of Our Privacy Policy seriously and will take appropriate disciplinary action against any Personnel, User, Partner, third-party, person, or entity found to have violated Our data protection and privacy policies, procedures, or Applicable Laws and Regulations. This may include, but is not limited to, termination of employment, suspension of access to Our systems, or legal action, as deemed appropriate by Us.

5. Data Collection

5.1 Purpose of Data Collection. We collect Your Personal Data and Information in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

5.2 Legal Basis for Data Collection. We collect Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

5.3 Types of Data Collected. We may collect various types of Personal Data and Information from You that may be as follows:

a. Personal Identifiers: This refer to Your Personal Data and Information that may be used to identify You, directly or indirectly, including, but not limited to, name, date of birth, email address, telephone number(s) and residential address, business addresses and postcodes or other similar identifiers. It may also include the Personal Data and Information that may identify, relate to, describe, or may be capable of being associated with You, including, but not limited to, Your signature, social security number, passport number, driver’s license or state identification card number, insurance policy number, education data and information [defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)], employment, employment history, profession-related data and information, bank account number, credit card number, debit card number, or any other financial data and information, medical data and information, or health insurance data and information.

b. Family Data and Information: This may include data and information about Your family members, relationships, and family history, such as names, dates of birth, addresses, and any other relevant details.

c. Commercial and Transaction Data and Information: This may include records of any products or services purchased, obtained, or considered by You on the Site and the Service, data and information about the products or services You may have purchased from Us, the date and time of the transaction, the transaction amount, or any other relevant data and information related to the transaction, or any other purchasing or consuming histories or tendencies.

d. Payment Data and Information: We may collect Your Personal Data and Information necessary to help facilitate the processing of Your payment if You make purchases, including Your credit card number, debit card number, bank account number, security codes associated with Your payment instrument such as CVV or CID number for credit and debit cards, billing address, phone number, and e-mail address, and any other financial data and information necessary and required to process Your transaction with Us.

e. User-Generated Content: This may include any content You may submit, post, upload, or otherwise may make available on or through the Site or the Service, including, but not limited to, photos, videos, documents, messages, comments, and any other form of User-generated content.

f. Usage Information: This refers to data about how You may interact with Our Site and the Service, including, but not limited to, Service usage, payment patterns and history that may have been registered with Us, inquiries and complaints that may have been registered with Us, the frequency and duration of Your visits, pages viewed, links clicked, commercial data and information like records of Our products or services that may have been purchased, obtained, or considered from Our Site and the Service, and any other usage-related data and information.

g. Technical Data and Information: This may include data related to Your device and internet connection, such as Internet Protocol (“IP”) address, browser or device type, operating system, browsing history, search history, data and information regarding Your interaction with Our Site, the Service, and third-party content, websites, resources, or services that may be available on Our Site, and any other technical identifiers.

h. Location Data and Information: This may involve data about Your geographical location, which may be derived from Your IP address, Global Positioning System (“GPS”), or any other location-based technologies.

i. Other Data and Information: Inferences drawn from any of the data and information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

j. Sensitive Personal Data and Information: We generally do not collect such data and information, but We may collect such data and information for the purposes outlined in this Privacy Policy.

5.4 Methods of Collection. We may collect Personal Data and Information and Sensitive Personal Data and Information from You through various methods, which may include:

a. We may collect Your Personal Data and Information from Our customer service center or Personnel via e-mail, text message (WhatsApp, Facebook, etc.), and phone calls.

b. We may collect Your Personal Data and Information from publicly accessible sources including property records.

c. Directly from Users: We may collect Personal Data and Information and Sensitive Personal Data and Information You expressly consent and provide to Us when You create an account, complete Your profile, interact with Our Site, use Our Service, or communicate with Us.

d. Automatically: We may use cookies, web beacons, and other tracking technologies to gather Personal Data and Information about Your usage patterns and technical specifications as You may interact with Our Site and the Service.

e. From Third Parties: We may receive data and information about You from third-party sources, such as sanctions screening providers, credit reporting agencies, customer due diligence providers, social media platforms, marketing partners, data brokers, social media platforms, from those third-parties that You may consent to collect Your Personal Data and Information from like Your bank, or any other service providers, persons, or entities which We may combine with the Personal Data and Information We may collect from You directly through Your express prior written consent.

f. We may collect Your Personal Data and Information from data aggregation services.

g. We may collect Your Personal Data and Information from Our Information Technology (“IT”) systems, including:

i. Door entry systems and reception logs;

ii. Automated monitoring of Our websites and other technical systems, such as Our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and

iii. Any other IT systems We may implement from time to time.

5.5 Cookies and Tracking Technologies

a. Cookies: We may use cookies, which are small text files placed on Your device, for various purposes, which may include to: (i) enhance Your experience on Our Site and the Service; (ii) remember Your preferences on Our Site and the Service; (iii) gather Your Personal Data and Information about Your usage patterns and technical specifications as You may interact with Our Site and the Service and analyze Your behavior and trends; (iv) improve and personalize Your experience on Our Site; and (v) and deliver targeted advertising. These technologies may collect Your Personal Data and Information, including, but not limited to, Your IP address, browser type, operating system, referring Uniform Resource Locators (“URLs”), and the pages You may visit on Our Site and Service. When You use Our Site and the Service, We send a cookie that gives each computer a unique identification number. Cookies do not identify individuals, although they may enable Us to identify Your browser type, Internet Service Provider (“ISP”), and other similar data and information. Your browser may be configured to accept all cookies, reject all cookies, or notify You when a cookie is sent. If You reject all cookies, You may not be able to functionally use Our Site and the Service. You may manage and control Your cookie preferences and opt-out of non-essential cookies through Your browser settings or by using opt-out tools provided by industry organizations as and where applicable. Please note that disabling cookies may affect the functionality and performance of Our Site and the Service and Your experience related to them.

b. Web Beacons: We may employ web beacons, also known as pixel tags or clear GIFs, which are small, transparent images embedded in Our Site and the Service to track User activities and collect usage data and information.

c. Analytics: We may use third-party analytics providers (e.g., Google Analytics) to help Us better understand how Our Users interact with Our Site and the Service and to optimize Our Site and the Service accordingly.

6. Data Processing

6.1 Purpose of Data Processing. We process Your Personal Data and Information in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

6.2 Legal Basis for Data Processing. We process Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

6.3 Automated Data Processing. We may use automated systems and algorithms to process Your Personal Data and Information to make decisions or to provide tailored content and recommendations based on Your activity on Our Site and the Service. This processing may involve using Your Personal Data and Information to analyze or predict aspects of Your behavior, preferences, or interests.

6.4 Data Processing by Third Parties. We may engage third-party service providers, persons, or entities to process Your Personal Data and Information on Our behalf, subject to strict confidentiality agreements and compliance with Applicable Laws and Regulations. We may enter into Data Processing Agreements (“DPAs”) with third-party processors to ensure that they process Your Personal Data and Information in accordance with this Privacy Policy, Our instructions, and all Applicable Laws and Regulations.

6.5 Data Minimization. We are committed to processing only the minimum amount of Your Personal Data and Information that is relevant, adequate, and limited to what is necessary for the purposes stated in this Privacy Policy.

6.6 Data Accuracy. We take reasonable steps to ensure the accuracy of Your Personal Data and Information We collect, process, use, disclose, store, retain, share, transfer, delete, and protect. If You believe that any Personal Data and Information We hold about You is inaccurate, outdated, or incomplete, please contact Us using the contact information provided in this Privacy Policy.

7. Data Use

7.1 Purpose of Data Use. We use Your Personal Data and Information and Sensitive Personal Data and Information in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

7.2 Legal Basis for Data Use. We use Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

7.3 Types of Data Used. We may use various types of Personal Data and Information that may be as follows:

a. Personal Identifiers: This refer to Your Personal Data and Information that may be used to identify You, directly or indirectly, including, but not limited to, name, date of birth, email address, telephone number(s) and residential address, business addresses and postcodes or other similar identifiers. It may also include the Personal Data and Information that may identify, relate to, describe, or may be capable of being associated with You, including, but not limited to, Your signature, social security number, passport number, driver’s license or state identification card number, insurance policy number, education data and information [defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)], employment, employment history, profession-related data and information, bank account number, credit card number, debit card number, or any other financial data and information, medical data and information, or health insurance data and information.

b. Family Data and Information: This may include data and information about Your family members, relationships, and family history, such as names, dates of birth, addresses, and any other relevant details.

c. Commercial and Transaction Data and Information: This may include records of any products or services purchased, obtained, or considered by You on the Site and the Service, data and information about the products or services You may have purchased from Us, the date and time of the transaction, the transaction amount, or any other relevant data and information related to the transaction, or any other purchasing or consuming histories or tendencies.

d. Payment Data and Information: We may use Your Personal Data and Information necessary to help facilitate the processing of Your payment if You make purchases, including Your credit card number, debit card number, bank account number, security codes associated with Your payment instrument such as CVV or CID number for credit and debit cards, billing address, phone number, and e-mail address, and any other financial data and information necessary and required to process Your transaction with Us.

e. User-Generated Content: This may include any content You may submit, post, upload, or otherwise may make available on or through the Site or the Service, including, but not limited to, photos, videos, documents, messages, comments, and any other form of User-generated content.

f. Usage Information: This refers to data about how You may interact with Our Site and the Service, including, but not limited to, Service usage, payment patterns and history that may have been registered with Us, inquiries and complaints that may have been registered with Us, the frequency and duration of Your visits, pages viewed, links clicked, commercial data and information like records of Our products or services that may have been purchased, obtained, or considered from Our Site and the Service, and any other usage-related data and information.

g. Technical Data and Information: This may include data related to Your device and internet connection, such as Internet Protocol (“IP”) address, browser or device type, operating system, browsing history, search history, data and information regarding Your interaction with Our Site, the Service, and third-party content, websites, resources, or services that may be available on Our Site, and any other technical identifiers.

h. Location Data and Information: This may involve data about Your geographical location, which may be derived from Your IP address, Global Positioning System (“GPS”), or any other location-based technologies.

i. Other Data and Information: Inferences drawn from any of the data and information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

j. Sensitive Personal Data and Information: We generally do not use such data and information, but We may use such data and information for the purposes outlined in this Privacy Policy.

7.4 Third-Party Advertising and Analytics. We may partner with third-party advertising and analytics providers to deliver targeted advertising and may analyze the effectiveness of Our Site and the Service. These third parties may use cookies and other tracking technologies to collect Personal Data and Information about Your access and use of Our Site and Service, and they may combine this data and information with Personal Data and Information from other sources. By using Our Site and the Service, You consent to the collection and use of Your data and information by these third parties, subject to their privacy policies and any other applicable policies, procedures, and agreements of these third parties.

8. Data Disclosure

8.1 Purpose of Data Disclosure. We disclose Your Personal Data and Information in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

8.2 Legal Basis for Data Disclosure. We disclose Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

8.3 Disclosure to intra-group. Your Personal Data and Information may be disclosed among any of Our related Bodies Corporate, any of Our associated affiliates, Our group entities and other companies in the Family.Estate group.

8.4 Disclosure to Partners. We may disclose Your Personal Data and Information to Our Partners, who may be involved in providing the Service on Our Site, as necessary and required by them.

8.5 Disclosure to Third-Parties. We may disclose Your Personal Data and Information to third-party service providers, persons, or entities who assist Us in providing, maintaining, developing, improving, and enhancing Our Site and the Service. These third parties may include, but are not limited to, hosting providers, payment processors and aggregators, marketing agencies, and any other third-party that may be engaged by Us.

8.6 Disclosure for Legal Reasons. We may disclose Your Personal Data and Information for various purposes which may include to: (i) comply with Applicable Laws and Regulations, court orders, subpoenas, investigations, warrants, lawful requests from public authorities, or other legal processes that may have been served upon Us, or as otherwise may be required by law; (ii) respond to claims, allegations, or notices that any content submitted, posted, uploaded, or otherwise may have been made available on or through the Site and/or the Service may infringe, misappropriate, or otherwise violate the intellectual property rights, proprietary rights, privacy rights, or any other rights of any User or third parties; or (iii) protect and defend the rights, property, or safety of Us and Our Personnel, Our Users, Our Partners and their Personnel, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services, as may be required or permitted by law, including, but not limited to, preventing or addressing issues of fraud, security, or technical issues.

8.7 Disclosure in Connection with Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, We may disclose Your Personal Data and Information to a third-party involved in such a process, subject to appropriate confidentiality obligations and in accordance with the Applicable Laws and Regulations.

8.8 Disclosure with Your Consent. We may disclose Your Personal Data and Information to other parties with Your express prior written consent or at Your request.

8.9 Disclosure of Sensitive Personal Data and Information: We generally do not disclose such data and information, but We may disclose such data and information, only with Your express prior written consent, to Our Partners, third-party service providers, persons, or entities who assist Us in providing, maintaining, developing, improving, and enhancing Our Site and the Service, and in connection with business transfers for the purposes outlined in this Privacy Policy.

9. Data Storage

9.1 Purpose of Data Storage. We store Your Personal Data and Information in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

9.2 Legal Basis for Data Storage. We store Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

9.3 Data Storage. By accessing and/or using Our Site and/or Service, Your Personal Data and Information may be automatically collected, processed, and stored on secure servers located in the Australia. We may also use cloud-based storage solutions provided by third-party service providers, persons, or entities to store and manage Your data. We may retain Your Personal Data and Information in accordance with this Privacy Policy. Once Your Personal Data and Information is no longer needed, We may securely delete or anonymize it in accordance WITH with the Applicable Laws and Regulations. We are not required to reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data and Information.

9.4 Data Security Measures. We are committed to protecting the privacy and security of Your Personal Data and Information and Sensitive Personal Data and Information in accordance with this Privacy Policy and Applicable Laws and Regulations.

9.5 Data Breach Notification. In the event of any data or security breach or unauthorized access to Your Personal Data and Information and Sensitive Personal Data and Information that compromises the security, privacy, confidentiality, or integrity of Your Personal Data and Information, We shall take appropriate steps to investigate, mitigate, and rectify the situation, in accordance with this Privacy Policy and the Applicable Laws and Regulations.

10. Data Retention

10.1 Legal Basis for Data Retention. We retain Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

10.2 Purpose and Retention Period. We may retain Your Personal Data and Information for as long as necessary for various purposes which may include to: (i) resolve disputes; (ii) enforce Our applicable policies, procedures, and agreements; (iii) respond to any questions, complaints, or claims made by You or on Your behalf; (iv) show that We treated You fairly, reasonably, and in compliance with the Applicable Laws and Regulations; (v) keep records required by law; and (vi) as may be required or permissible by the Applicable Laws and Regulations.

10.3 Criteria for Retention. The length of time We may retain Your Personal Data and Information may depend on various factors, which may include: (i) nature and sensitivity of the Personal Data and Information; (ii) the purpose for which the Personal Data and Information may have been collected, processed, used, disclosed, stored, retained, shared, transferred, deleted, or protected; (iii) the potential risk of harm from unauthorized, illegal, or unlawful collection, processing, use, disclose, storage, retention, sharing, transferring, deletion, or protection of the Personal Data and Information; and (iv) any applicable legal and regulatory obligations and requirements. We may retain Your data for a longer period if required by law, to protect Our legal rights or to comply with legal and regulatory obligations and requirements.

10.4 Data Deletion. When Your Personal Data and Information is no longer necessary for the purposes for which it was collected, We may securely delete or anonymize it in accordance with the Applicable Laws and Regulations.

10.5 Data Archiving. We may archive Your Personal Data and Information for historical or statistical purposes by ensuring appropriate safeguards are in place to protect Your privacy and any other legal rights. Personal Data and Information, if archived, shall be securely stored and access to such data and information shall be strictly controlled by Us in accordance with the Applicable Laws and Regulations.

10.6 Review of Retention Practices and Standards. We periodically review Our data retention practices and standards to ensure that they remain in compliance with Applicable Laws and Regulations.

11. Data Sharing

11.1 Circumstances for Sharing of Personal Data and Information. We may share Your Personal Data and Information under various circumstances which may include:

a To comply with Applicable Laws and Regulations, court orders, subpoenas, investigations, warrants, lawful requests from public authorities, or other legal processes that may have been served upon Us, or as otherwise may be required by law;

b. To respond to claims, allegations, or notices that any content submitted, posted, uploaded, or otherwise made available on or through the Site and/or the Service that may infringe, misappropriate, or otherwise violate the intellectual property rights, proprietary rights, privacy rights, or any other rights of any User or third parties;

c. In connection with a merger, acquisition, or asset sale;

d. To comply with the purposes that may have been set forth in this Privacy Policy.

11.2 Sharing within Family.Estate Group. We may share Your Personal Data and Information among any of Our related Bodies Corporate, any of Our associated affiliates, Our group entities and other companies in the Family.Estate group, and their respective Personnel.

11.3 Sharing with Our Partners. We may share Your Personal Data and Information with Our Partners and their respective Personnel who may be involved in providing the Service on Our Site. These Partner are required to protect Your Personal Data and Information in a manner consistent with this Privacy Policy and in compliance with Applicable Laws and Regulations.

11.4 Sharing with Third Parties. We may share Your Personal Data and Information with various third-parties, service providers, persons, or entities and their respective Personnel who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services.

11.5 Sharing for Legal Reasons. We may share Your Personal Data and Information for various purposes which may include to: (i) comply with Applicable Laws and Regulations, court orders, subpoenas, investigations, warrants, lawful requests from public authorities, or other legal processes that may have been served upon Us, or as otherwise may be required by law; (ii) respond to claims, allegations, or notices that any content submitted, posted, uploaded, or otherwise that may be made available on or through the Site and/or the Service that may infringe, misappropriate, or otherwise violate the intellectual property rights, proprietary rights, privacy rights, or any other rights of any User or third parties; or (iii) protect and defend the rights, property, or safety of Us and Our Personnel, Our Users, Our Partners and their Personnel, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services, as required or permitted by law, including, but not limited to, preventing or addressing issues of fraud, security, or technical issues.

11.6 Sharing in Connection with Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, We may share Your Personal Data and Information to a third-party involved in such a process, subject to appropriate confidentiality obligations and in accordance with the Applicable Laws and Regulations.

11.7 We may share Your Personal Data and Information with Our insurers, brokers, and bank.

11.8 The following shall be subject to their own privacy policies, confidentiality agreements, DPAs, and any other applicable policies, procedures, and agreements: (i) Our related Bodies Corporate; (ii) Our associated affiliates; (iii) Our group entities and other companies in the Family.Estate group; (iv) Our Partners; and (v) various third-party service providers, persons, or entities who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services. We shall not be responsible and liable for the privacy policies, confidentiality agreements, DPAs, and any other applicable policies, procedures, and agreements of Our Partners and various third-party service providers, persons, or entities who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services.

12. Data Transfers

12.1 Overview of Data Transfers. We may need to transfer Your Personal Data and Information to any of Our related Bodies Corporate, any of Our associated affiliates, Our Partners, and any other third-party service provider, person, or entity who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services, within the Australia, to provide Our Site and the Service effectively and efficiently and in accordance with the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations. Some of Our Partners and/or service providers may be located in overseas locations. If We may be permitted by law to do so, We may transfer Your Personal Data and Information to these providers or Our Partners to provide Our Site and the Service to You.

12.2 Legal Basis for Data Transfer. We transfer Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

12.3 Types of Data Transfers.

a. Intra-group Transfers: We may transfer Your Personal Data and Information among any of Our related Bodies Corporate, any of Our associated affiliates, Our group entities and other companies in the Family.Estate group.

b. Partners: We may transfer Your Personal Data and Information to Our Partners who may provide or may be involved in providing their Service on the Site.

c. Third-parties: We may transfer Your Personal Data and Information to third-parties who may help Us deliver, maintain, and improve Our Site and the Service or may be involved in providing Us products and services, including, but not limited to, hosting providers, payment processors and aggregators, marketing agencies, and any other third-party that may be engaged by Us.

d. Business Transfers: In the event of a merger, acquisition, reorganization, or sale of all or part of Our assets, Your Personal Data and Information may be transferred to the acquiring entity or the successor entity.

e. Legal Obligations and Enforcement: We may transfer Your Personal Data and Information for various purposes which may include to: (i) comply with Applicable Laws and Regulations, court orders, subpoenas, investigations, warrants, lawful requests from public authorities, or other legal processes that may have been served upon Us, or as otherwise may be required by law; and (ii) respond to claims, allegations, or notices that any content submitted, posted, uploaded, or otherwise that may have been made available on or through the Site and/or the Service that may infringe, misappropriate, or otherwise violate the intellectual property rights, proprietary rights, privacy rights, or any other rights of any User or third-parties.

12.4 Safeguards for Data Transfers. We are committed to ensuring that Your Personal Data and Information are protected during data transfers. We have implemented appropriate safeguards, such as DPAs, standard contractual clauses, binding corporate rules, or other legally recognized mechanisms, to ensure that Your data and information is protected in accordance with this Privacy Policy and applicable data protection laws.

13. Data Deletion

13.1 Legal Basis for Data Deletion. We delete Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

13.2 Right to Deletion. You have the right to request the deletion of Your Personal Data and Information under certain circumstances, such as: (i) when Your Personal Data and Information may be no longer necessary for the purposes for which it was collected, processed, used, disclosed, stored, retained, shared, transferred, deleted, and protected; and/or (ii) when You have withdrawn Your consent for the collection, processing, use, disclosure, storage, retention, sharing, transferring, deletion, or protection of Your Personal Data and Information.

13.3 Deletion Process. Upon receiving a request for deletion, We will take appropriate steps to delete Your Personal Data and Information from Our systems and inform any third-party service providers, persons, or entities that may have access to Your Personal Data and Information about Your request for deletion. We will attempt to respond to Your request within a reasonable timeframe and in accordance with Applicable Laws and Regulations.

13.4 Exceptions. There may be circumstances where We are unable to delete Your Personal Data which may include to: (i) complete the transaction for which the Personal Data and Information may have been collected, or provide the Service requested by You, or reasonably anticipated within or otherwise perform a contract between You and Us; (ii) detect security and privacy incidents, protect against malicious, deceptive, fraudulent, or illegal activity; (iii) debug to identify and repair errors that may impair existing intended functionality of the Site and the Service; (iv) exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to Applicable Laws and Regulations, when Our deletion of the Personal Data and Information is likely to render impossible or seriously impair the achievement of such research, provided We have obtained Your express prior written consent; (vii) enable solely internal uses that are reasonably aligned with Your expectations based on Your relationship with Us; (viii) comply with an existing legal obligation or any other legal, regulatory, or contractual obligations; or (ix) otherwise use Your Personal Data and Information, internally, in a lawful manner that is compatible with the purposes for which You provided the Personal Data and Information. In such cases, We will attempt to inform You of the reasons for not being able to delete Your Personal Data and Information and may retain it only for the duration necessary to fulfill those obligations.

13.5 Anonymized Data. We may retain anonymized or aggregated data that may not be used to identify You for statistical, research, or product development purposes, even after Your Personal Data and Information has been deleted from Our systems.

14. Data Protection and Security

14.1 Purpose of Data Protection and Security. We employ various technical, administrative, and physical security measures designed to safeguard and to protect Your Personal Data and Information from unauthorized, illegal, and unlawful access, collection, processing, use, disclosure, storage, retention, sharing, transfer, deletion, and protection and Your Sensitive Personal Data and Information from unauthorized, illegal, and unlawful access, collection, use, and disclosure to achieve and fulfill the purposes set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

14.2 Legal Basis for Data Protection and Security. We protect the privacy and security of Your Personal Data and Information in accordance with the legal basis set forth in this Privacy Policy and as required by the Applicable Laws and Regulations.

14.3 Physical Security Measures. We maintain secure facilities and restricted access to areas where Your Personal Data and Information may be stored or processed and where Your Sensitive Personal Data and Information may be collected, used, and disclosed. This may include implementing access controls, surveillance systems, and other security measures to prevent unauthorized, illegal, and unlawful access, collection, processing, use, disclosure, storage, retention, sharing, transfer, deletion, and protection, and protect the physical integrity of the stored Personal Data and Information and other security measures to prevent unauthorized, illegal, and unlawful access, collection, use, and disclosure and protect the physical integrity of the Sensitive Personal Data and Information.

14.4 Technical Security Measures. We employ a range of technical security measures, such as encryption, firewalls, intrusion detection systems, and Secure Socket Layer (“SSL”) technology, to protect Your Personal Data and Information and Sensitive Personal Data and Information both during transmission and at rest.

14.5 Administrative Security Measures. We implement administrative measures, including policies, procedures, and Personnel training programs, to ensure that Our Personnel are aware of their responsibilities in safeguarding Your Personal Data and Information and Sensitive Personal Data and Information and comply with Applicable Laws and Regulations, and best data practices and standards.

14.6 Access Controls and Authentication. We may restrict access to Your Personal Data and Information and Sensitive Personal Data and Information to authorized Personnel who have a legitimate need and require the access to Your Personal Data and Information and Sensitive Personal Data and Information to perform their job duties and functions. We may implement strong User authentication procedures and may require Our Personnel to use unique usernames and complex passwords that may be regularly updated to maintain the security of their accounts.

14.7 Regular Security Assessments and Audits. We may conduct regular security assessments and audits to evaluate the effectiveness of Our security measures and identify potential vulnerabilities or areas for improvement. This may include engaging third-party security experts to perform independent assessments and providing recommendations for enhancing Our data protection and security practices and standards.

14.8 Incident Management and Breach Notification. We may establish an incident management process to identify, respond to, and mitigate security incidents or breaches promptly. In the event of a Personal Data and Information and/or Sensitive Personal Data and Information breach, We may try or attempt to notify the affected individuals and relevant supervisory authorities in accordance with the Applicable Laws and Regulations.

14.9 Data Processing Agreements and Subprocessors. When engaging third-party service providers, persons, or entities that may process Personal Data and Information on Our behalf, We require them to implement appropriate security measures and comply with Our DPAs, which include obligations to maintain the confidentiality, integrity, and availability of Your Personal Data and Information.

14.10 Limitations. While We strive to maintain the highest levels of security to protect the privacy and security of Your Personal Data and Information and Sensitive Personal Data and Information, no method of transmission over the internet, electronic storage, or any other data protection systems can guarantee absolute security, privacy, and safety of Your Personal Data and Information and Sensitive Personal Data and Information. As such, We cannot warrant or ensure the complete and infallible security, privacy, and safety of Your Personal Data and Information and Sensitive Personal Data and Information.

14.11 Continuous Improvement. We are committed to continuously improving Our data protection, privacy, and security practices and standards by staying informed about the latest industry standards, technological and legal advancements, and evolving threats. This enables Us to adapt Our protection, privacy, and security measures and respond effectively to emerging risks.

14.12 Data Breach Notification. In the event of any data or security breach or unauthorized access to Your Personal Data and Information and/or Sensitive Personal Data and Information that compromises the security, confidentiality, or integrity of Your Personal Data and Information and/or Sensitive Personal Data and Information, We may attempt to promptly notify You and take appropriate steps to investigate, mitigate, and rectify the situation, in accordance with Applicable Laws and Regulations. By using the Site and the Service, You acknowledge and agree to the inherent risks associated with the electronic transmission and collection, processing, usage, disclosure, storage, retaining, sharing, transferring, deletion, and protection of Your Personal Data and Information and collection, use, and disclosure of Your Sensitive Personal Data and Information and agree not to hold Us liable or responsible for any unauthorized access, disclosure, loss, or damage, partially or fully, of or to Your Personal Data and Information and/or Sensitive Personal Data and Information. To further protect Your Personal Data and Information and/or Sensitive Personal Data and Information, You are encouraged to adopt best practices and standards, including, but not limited to, using strong and unique passwords and regularly updating Your account data and information. In addition to Our legal obligations, We may take the reasonable steps to minimize the harm to You and to restore the protection, privacy, and security of Your Personal Data and Information and/or Sensitive Personal Data and Information as quickly as possible.

15. Data Access

15.1 Right to Access. We recognize the importance of ensuring that Our Users have access to their Personal Data and Information as necessary. Under the California Consumer Privacy Act of 2018 (“CCPA”) (including those amendments that might come into effect from time to time), Virginia Consumer Data Protection Act of 2023 (“CDPA”) (including those amendments that might come into effect from time to time), and certain other privacy and data protection laws (including those amendments that might come into effect from time to time), as applicable, You have the right to request access to Your Personal Data and Information We may hold about You. This includes the right to: (i) know the categories and specific pieces of Personal Data and Information We may have collected; (ii) the sources from which We may have collected Your Personal Data and Information; (iii) the purposes for which We may collect, process use, disclose, store, retain, share, transfer, delete, or protect Your Personal Data and Information; and (iv) the categories of third parties, persons, and entities with whom We may have shared and/or transferred Your Personal Data and Information.

15.2 Right to Access Personal Data and Information Sold or Used for a Business Purpose. Under the CCPA (including those amendments that might come into effect from time to time), CDPA (including those amendments that might come into effect from time to time), and certain other privacy and data protection laws (including those amendments that might come into effect from time to time), as applicable, in connection with any Personal Data and Information We may sell or disclose to a third-party for a business purpose, You have the right to know: (i) the categories of Personal Data and Information about You that We may have sold for a business purpose and the categories of third parties to whom the Personal Data and Information may have been sold; and (ii) the categories of Personal Data and Information that We may have disclosed about You for a business purpose and the categories of third parties to whom the Personal Data and Information may have been disclosed. Under the CCPA (including those amendments that might come into effect from time to time), CDPA (including those amendments that might come into effect from time to time), and certain other privacy and data protection laws (including those amendments that might come into effect from time to time), as applicable, You have the Right to opt-out of the sale or disclosure of Your Personal Data and Information. If You exercise Your right to opt-out of the sale or disclosure of Your Personal Data and Information, We will refrain from selling or disclosing Your Personal Data and Information unless You subsequently provide express prior written consent for the sale or disclosure of Your Personal Data and Information. To exercise Your opt-out rights, contact Us on the contact information given in this Privacy Policy. We shall respond to You within a reasonable timeframe.

15.3 How to Submit a Data Access Request. To exercise Your right to access Your Personal Data and Information, You may submit a request through Our designated contact channels mentioned in this Privacy Policy available under the “Contact Information” clause. You must provide (i) specific Personal Data and Information You wish to access; (ii) valid, sufficient, accurate and latest data and information to identify Your identity (e.g., Your full name, residential address, and customer or matter reference number); (iii) proof of Your identity and address (e.g., a copy of Your driving license or passport and a recent utility or credit card bill or any other forms of identification or data and information). Any Personal Data and Information We may collect from You to verify Your identity in connection with Your data access request may be used solely for the purposes of verification. We are not obligated to accept a data access request if We cannot verify that the person making the request is the person about whom We collected the Personal Data and Information, or is someone authorized to act on such person’s behalf.

15.4 Verification Process. To protect the privacy and security of Your Personal Data and Information, We may take reasonable steps to verify Your identity before granting access to Your Personal Data and Information. This may include requesting additional data and information or documentation to confirm Your identity, such as a government-issued identification, utility bill, or any other forms of identification or data and information.

15.5 Response Time. We will make reasonable efforts to provide You with access to Your Personal Data and Information in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to Your data access request within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date.

15.6 Format of Access. We may provide the requested Personal Data and Information in a commonly used electronic format unless You request a different format or where it is not technically feasible to do so.

15.7 Fees and Charges. We will generally provide access to Your Personal Data and Information free of charge. However, We reserve the right to charge a reasonable fee to cover Our administrative costs if Your request is excessive, repetitive, or manifestly unfounded. We will inform You of any applicable fees before processing Your request.

15.8 Exceptions. Please note that certain legal and practical exceptions may apply. We may deny access to Your Personal Data and Information in certain circumstances, such as: (i) when may be required or permitted by legal, regulatory, or contractual obligations and requirements; (ii) when Your request violates any Applicable Laws and Regulations or interferes with the rights and freedoms of other persons or entities; (iii) when providing access would have an unreasonable impact on the privacy of other persons or entities; (iv) when Your data access request may be excessive, repetitive, or manifestly unfounded; or (v) when the Personal Data and Information is subject to legal privilege or other lawful exemptions. In such cases, We will inform You of the reason for the denial and may provide You with available options for recourse.

15.9 Record Keeping. We may maintain a record of all data access requests and the actions taken in response to them. This record shall be kept in accordance with this Privacy Policy and Applicable Law and Regulations.

15.10 Assistance for Disabled Users. If You have a disability that prevents You from submitting a data access request through Our standard contact channels, please inform Us so that We may attempt to provide reasonable accommodations or alternative means for You to exercise Your rights.

16. Data Updation and Correction

16.1 Right to Updation and Correction. We recognize the importance of ensuring that Our Users have the ability to review, update, and/or correct their Personal Data and Information as necessary. Under the CCPA (including those amendments that might come into effect from time to time ), CDPA (including those amendments that might come into effect from time to time), and certain other privacy and data protection laws (including those amendments that might come into effect from time to time), as applicable, You have the right to request updation and/or corrections to any inaccurate, outdated, or incomplete data We may hold about You, subject to certain exceptions under Applicable Laws and Regulations. We will make reasonable efforts to accommodate such request in a timely manner.

16.2 Requesting Data Updation and Correction. To request an updation and/or correction to Your Personal Data and Information, please contact Us at using the contact information provided in this Privacy Policy and provide the following data and information:

a. valid, sufficient, accurate and latest data and information to identify Your identity (e.g., Your full name, residential address, and customer or matter reference number);

b. Proof of Your identity and address (e.g., a copy of Your driving license or passport and a recent utility or credit card bill or any other forms of identification or data and information);

c. A clear description of the data and information You may believe is inaccurate, outdated, or incomplete;

d. The specific updation and/or correction(s) You would like Us to make; and

e. Any supporting documentation or evidence that supports Your request.

16.3 Verification Process. To protect the privacy and security of Your Personal Data and Information, We may take reasonable steps to verify Your identity before updating and/or correcting Your Personal Data and Information. This may include requesting additional data and information or documentation to confirm Your identity, such as a government-issued identification, utility bill, or any other forms of identification or data and information.

16.4 Response Time. We will make reasonable efforts to update and/or correct Your Personal Data and Information in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to Your data updation and/or correction request within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date.

16.5 Limitation and Exceptions. Please note that certain legal and practical exceptions may apply. We may deny Your updation and/or correction request in certain circumstances, such as: (i) when required or permitted by legal, regulatory, or contractual obligations and requirements; (ii) when Your request violates any Applicable Laws and Regulations or interferes with the rights and freedoms of other persons or entities; (iii) when granting the request would have an unreasonable impact on the privacy of other persons or entities; (iv) when Your data updation and/or correction request may be excessive, repetitive, or manifestly unfounded; or (v) when the Personal Data and Information is subject to legal privilege or other lawful exemptions. In such cases, We will inform You of the reason for the denial and may provide You with available options for recourse.

16.6 Record Keeping. We may maintain a record of all data updation and/or correction requests and the actions taken in response to them. This record shall be kept in accordance with this Privacy Policy and Applicable Law and Regulations.

17. Shine the Light Law

17.1 Overview. In accordance with California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents who provide Personal Data and Information to Us to obtain Our Service are entitled to request and obtain, once a calendar year, information about the Personal Data and Information We may have shared, if any, with third parties for third parties’ direct marketing purposes.

17.2 Request for Information. If You are a California resident and would like to make a request for data and information under the Shine the Light law, please contact Us using the contact information provided in this Privacy Policy.

17.3 Verification Process. To protect the privacy and security of Your Personal Data and Information, We may take reasonable steps to verify Your identity before providing You data and information under the Shine the Light Law. This may include requesting additional data and information or documentation to confirm Your identity, such as a government-issued identification, utility bill, or any other forms of identification or data and information.

17.4 Response and Response Time. We will make reasonable efforts to provide You with data and information under the Shine the Light Law in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to Your request within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date. We shall provide You a list of the categories of Personal Data and Information, if any, that We disclosed to third parties for third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. Please note that, under California law, We are only required to respond to a customer request once during any calendar year.

17.5 Limitations. Please be aware that not all Personal Data and Information sharing is covered by the Shine the Light requirements, and only that Personal Data and Information sharing covered under the Shine the Light Law shall be included in Our response.

18. Right to Limit Collection, Usage, and Disclosure of Your Sensitive Personal Data and Information

18.1 We generally do not collect, use and/or disclose Sensitive Personal Data and Information, but if We do, You have the right to request Us to limit the collection, usage, and/or disclosure of such data and information only to the following purposes which may be necessary: (i) to provide the Site and the Service for ensuring the security and integrity to the extent the use of the consumer’s Personal Data and Information may be reasonably necessary and proportionate for these purposes; (ii) for short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with Our business, provided that the consumer’s Personal Data and Information may not be disclosed to another third party and may not be used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with Our business; (iii) for providing the Site and the Service on behalf of Our business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer data and information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Our business; (iv) for undertaking activities to verify or maintain the quality the Site and the Service owned and controlled by Us, and to improve, upgrade, and enhance the Site and the Service owned and controlled by Us; and (v) for the functionality of the Site and the Service. On receipt of Your request, We are no longer allowed to collect, use, and/or disclose Your Sensitive Personal Data and Information for any other purpose unless You provide express prior written consent for additional purposes.

18.2 How to Submit a Request. To exercise Your right to limit the collection, usage, and/or disclosure of Your Sensitive Personal Data and Information, You may submit a request through Our designated contact channels mentioned in this Privacy Policy available under the “Contact Information” clause. You must provide (i) specific Sensitive Personal Data and Information You wish to limit; (ii) valid, sufficient, accurate and latest data and information to identify Your identity (e.g., Your full name, residential address, and customer or matter reference number); (iii) Proof of Your identity and address (e.g., a copy of Your driving license or passport and a recent utility or credit card bill or any other forms of identification or data and information). Any Personal Data and Information We may collect from You to verify Your identity in connection with Your data limit request may be used solely for the purposes of verification. We are not obligated to accept a data limit request if We cannot verify that the person making the request is the person about whom We collected the Personal Data and Information, or is someone authorized to act on such person’s behalf.

18.3 Verification Process. To protect the privacy and security of Your Sensitive Personal Data and Information, We may take reasonable steps to verify Your identity before approving Your data limit request for Your Sensitive Personal Data and Information. This may include requesting additional data and information or documentation to confirm Your identity, such as a government-issued identification, utility bill, or any other forms of identification or data and information.

18.4 Response Time. We will make reasonable efforts to approve Your data limit request in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to Your data limit request within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date.

19. Right to Opt-out of Targeted Advertising

19.1 Overview. We may work with third-party advertising service providers, persons, or entities to display targeted advertisements on Our Site and the Service. These targeted advertisements may be based on Your browsing behavior, preferences, or other Personal Data and Information. This practice, commonly known as “targeted advertising” or “behavioral advertising,” helps Us provide more relevant ads to You.

19.2 Your Rights. If You do not wish to receive targeted advertising, You have the right to opt-out. By opting out, You may still see ads, but they may be less relevant to Your interests, preferences, and requirements.

19.3 Opt-Out Mechanisms. To opt-out of targeted advertising, You may use the following mechanisms:

a. Site Advertising: To opt-out of targeted ads on Our Site, You may adjust Your web browser settings to block or limit the use of cookies and other tracking technologies. However, please note that blocking or disabling cookies may affect the functionality of Our Site and the Service.

b. Mobile App Advertising: To opt-out of targeted ads in mobile apps, You may adjust the in-app settings on Your mobile device.

19.4 Effect of Opting Out. Please note that opting out of targeted advertising does not mean that You will no longer receive advertising, but rather the advertising You see will not be tailored to Your interests, preferences, and requirements.

20. Protection Against Discrimination

20.1 You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA (including those amendments that might come into effect from time to time), CDPA (including those amendments that might come into effect from time to time), or any other privacy and data protection laws (including those amendments that might come into effect from time to time). We cannot, amongst other things, do the following solely because You exercised any of Your rights under the CCPA (including those amendments that might come into effect from time to time), CDPA (including those amendments that might come into effect from time to time), or any other privacy and data protection laws (including those amendments that might come into effect from time to time):

a. Deny the Site and Service to You;

b. Charge different prices or rates for the Service, including through the use of discounts or other benefits or imposing penalties;

c. Provide a different level or quality of the Site and Service to You; or

d. Suggest that You will receive a different price or rate for the Service or a different level or quality of Service.

21. Right to Object

21.1 General Right to Object. We respect Your right to object to the collection, processing, usage, disclosure, storage, retention, sharing, and/or transferring of Your Personal Data and Information in certain circumstances, as provided under Applicable Laws and Regulations. If You wish to exercise Your right to object, please contact Us using the contact information provided in this Privacy Policy.

21.2  Objection for Legitimate Interests. You may have the right to object to the collection, processing, usage, disclosure, storage, retention, sharing, and/or transferring of Your Personal Data and Information based on Our legitimate interests, as provided under Applicable Laws and Regulation. If You exercise Your right to object, We will carefully consider Your request and either cease, restrict, or provide You with a compelling reason to continue the collection, processing, usage, disclosure, storage, retention, sharing, and/or transfer of Your Personal Data and Information, as required by law.

21.3 Exercising Your Right to Object. To exercise Your right to object, please contact Us using the contact information provided in this Privacy Policy. We may require You to provide additional data and information to verify Your identity and confirm Your request. We will respond to We will make reasonable efforts to respond to You in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to You within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date.

21.4 No Adverse Consequences. Exercising Your right to object will not result in any adverse consequences or penalties.

21.5 Right to Lodge a Complaint. If You believe that Your right to object has not been respected, or if You are dissatisfied with Our response to Your objection, You have the right to lodge a complaint with the appropriate authority or data protection authority, as may be available under Applicable Laws and Regulations.

22. Right to Opt-Out of Profiling

22.1 Overview. Profiling means any form of automated processing that may be performed on Personal Data and Information to evaluate, analyze, or predict personal aspects related to an identified or identifiable natural person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We may engage in profiling activities to enhance and personalize Your experience on Our Site and Service.

22.2 Right to Opt-Out. You have the right to opt-out of profiling activities based on Your Personal Data and Information, particularly when such activities may be used for direct marketing purposes or have legal or similarly significant effects on You. To exercise Your right to opt-out of profiling, you may follow the steps outlined below:

a. Direct Marketing: If You would like to opt-out of profiling for direct marketing purposes, You may do so by using the “unsubscribe” link that may be provided in Our marketing e-mails or by contacting Us using the contact information provided in this Privacy Policy.

b. Other Profiling Activities: If You would like to opt-out of other profiling activities that may have legal or similarly significant effects on You, please contact Us using the contact information provided in this Privacy Policy. In Your request, please specify the profiling activities to which You want to opt-out of.

22.3 Timeframes and Verification. We may require You to provide additional data and information to verify Your identity and confirm Your request. We will make reasonable efforts to approve Your request in a timely manner, subject to Applicable Laws and Regulations and any legal or practical limitations. We will respond to Your request within a reasonable timeframe, generally within sixty (60) days from the date We receive Your request, unless an extension of additional thirty (30) days is necessary due to the complexity of the request or other legitimate reasons. In such cases, We will inform You of the extension and the reason for it. If We are unable to complete Your request within the original and/or extended timeframe, We may notify You of the reasons for the delay and provide an estimated completion date.

22.4 Consequences of Opting Out. If You choose to opt-out of profiling activities, You may still access and use Our Site and Service. We will endeavor to respect Your choice and ensure that Your Personal Data and Information is no longer used for the purposes of profiling.

23. Online Interactions and Tracking Technologies

23.1 Use of Cookies and Similar Technologies. We may use cookies, web beacons, and other tracking technologies for various purposes which may include to: (i) enhance Your experience on Our Site and the Service; (ii) remember Your preferences on Our Site and the Service; (iii) gather Your Personal Data and Information about Your usage patterns and technical specifications as You may interact with Our Site and the Service and analyze Your behavior and trends; (iv) improve and personalize Your experience on Our Site; and (v) and deliver targeted advertising. These technologies may collect Your Personal Data and Information, including, but not limited to, Your IP address, browser type, operating system, referring URLS, and the pages You may visit on Our Site and Service. When You use Our Site and the Service, We may send a cookie that gives each computer a unique identification number. Cookies do not identify individuals, although they may enable Us to identify Your browser type, ISP, and other similar data and information.

23.2 Your Choices and Control. Your browser may be configured to accept all cookies, reject all cookies, or notify You when a cookie is sent. If You reject all cookies, You may not be able to use Our Site and the Service. You may manage and control Your cookie preferences and opt-out of non-essential cookies through Your browser settings or by using opt-out tools provided by industry organizations as and where applicable. Please note that disabling cookies may affect the functionality and performance of Our Site and the Service and Your experience related to them.

24. Opt-In for Telemarketing, Commercial, Advertising Communications

24.1 By accessing and/or using the Site and the Service, You opt-in to receiving telemarketing, commercial, and advertising communications from Us via various channels, including, but not limited to, e-mails, text messages (through SMS, WhatsApp, Facebook, etc.), and phone calls, for which the User may be charged as per the User’s telephone carrier as and when wherever and however applicable. By accessing and/or using the Site and the Service, You are opting in and expressly providing Your express prior written consent to receive such communications from Us which may include the use of prerecorded or artificial voice messages and/or the use of an automatic telephone dialing system.

24.2 The communications You may receive from Us may include, but are not limited to:

a. Updates and announcements about the Site and the Service, promotions, or events;

b. Information and resources related to the Service You have requested through the Site;

c. Notifications, reminders, and confirmations related to Your account, appointments, or transactions with Your matched Partner;

d. Customer service and support communications; and

e. Any other information or materials that We may deem relevant, useful, or necessary for Our Users.

24.3 By opting in for these communications, You acknowledge and agree that We may collect, process, use, disclose, store, retain, and protect Your Personal Data and Information, including, but not limited to, Your name, e-mail address, phone number, and other contact information, to send You these communications. We shall handle Your Personal Data and Information in accordance with Our Privacy Policy.

24.4 We shall ask You to confirm or update Your marketing preferences if You instruct Us to provide further Service in the future, or if there are changes in the Applicable Laws and the Regulations, or the structure of Our business.

25. Opt-Out from Telemarketing, Commercial, Advertising Communications

25.1 In compliance with the CAN-SPAM Act, TCPA, National Do Not Call Registry, and Our internal Do-Not-Call list, You may opt-out of receiving any and all telemarketing, commercial, and advertising communications from Us at any time by following the opt-out or unsubscribe mechanism provided in the communications (such as the e-mails, text messages, or phone calls) or by contacting Our Customer Support Team at [email protected] or +16468289906. Upon receiving Your opt-out request, We shall promptly process and remove Your details from Our internal registry within ten (10) days from the receipt of the opt-out request and stop sending e-mails, text messages, and phone calls to You in accordance with the Applicable Laws and Regulations. We shall not sell or transfer Your Personal Data and Information, used for communications, after the opt-out request has been processed by Us.

26. Special Notices for Specific Regions

26.1 Other Regions. If You are a resident of a jurisdiction that has data protection and privacy laws that are not specifically addressed in this Privacy Policy, We may endeavor to comply with those laws to the extent required. To exercise any rights You may have under these laws, please contact Us using the contact information provided in this Privacy Policy.

27. Governing Law

27.1 This Privacy Policy shall be governed by and construed in accordance with the laws of Delaware, Australia, without regard to its conflict of law provisions.

27.2 This Privacy Policy and any disputes, claims, or controversies arising out of or in connection with this Privacy Policy (including but not limited to the interpretation, performance, enforceability, or validity of this Privacy Policy) and access and use of the Site and/or the Service shall be governed by, construed, and enforced in accordance with the laws of Delaware, Australia, without regard to its conflict of laws principles.

27.3 By accessing and/or using the Site or the Service, the User expressly agrees that any legal action, proceeding, or dispute arising out of or in connection with this Privacy Policy, the Site, or the Service shall be brought exclusively in the state or federal courts located in Delaware, Australia. The User hereby expressly consents and submits, irrevocably and unconditionally, to the jurisdiction of state or federal courts located in Delaware, Australia and any courts which may hear appeals from state or federal courts mentioned above, for the purpose of litigating any such action, proceeding, or dispute.

28. Complaints and Dispute Resolution

28.1 Submitting a Complaint. If You have any concerns or complaints about the way We may handle Your Personal Data and Information and Sensitive Personal Data and Information, You may contact Us using the contact information provided in this Privacy Policy. We will acknowledge Your complaint within a reasonable timeframe and will provide a response within a reasonable timeframe, typically within sixty (60) days.

28.2 Internal Investigation. Upon receiving a complaint, We will conduct an internal investigation and may request additional data and information from You to help Us understand, address, and resolve Your concerns. We will work in good faith to resolve the issue to Your satisfaction.

28.3 Appeal. If You are not satisfied with Our action related to the exercise of one of Your privacy rights as described above, or If You are not satisfied with the outcome of Our internal investigation, or if You believe We have not adequately addressed any of Your concerns, You may appeal and lodge a complaint with the relevant authority or data protection authority in the jurisdiction of Delaware, Australia.

28.4 Alternative Dispute Resolution (“ADR”). In the event of a dispute that cannot be resolved through Our internal complaint handling process, You may choose to pursue ADR mechanisms, such as virtual/remote mediation or arbitration. The rules, method, and procedure for the virtual/remote mediation and arbitration shall be mutually decided by the concerned parties in writing. The seat of the arbitration shall be Delaware, Australia and the venue for arbitration shall be Delaware, Australia wherein the proceedings shall be attended by the Parties virtually/remotely. We will cooperate with any ADR processes and will strive to reach a mutually agreeable settlement.

29. Updates and Changes to this Privacy Policy

29.1 Periodic Review. We may, from time to time, without notice and liability, modify, amend, suspend, discontinue, terminate, or impose limits or restrict this Privacy Policy at Our discretion periodically to reflect changes in Our business practices and standards, technology, legal requirements, or other factors. We encourage You to review this Privacy Policy regularly to stay informed about Our data practices and standards and any changes to this Privacy Policy.

29.2 Notice of Changes. We may notify You of any such changes by posting an update on Our Site or by sending You an e-mail. It is Your sole and exclusive liability and responsibility to review this Privacy Policy regularly to stay informed about Our data practices and standards.

29.3 Date of Last Update. The date of the last update to this Privacy Policy shall be indicated at the top of this document. It is Your responsibility and liability to check this Privacy Policy regularly for any updates or changes.

29.4 Continued Use. Your continued use of Our Site and Service after any changes to this Privacy Policy constitutes Your acknowledgment, consent, agreement, and acceptance of the changes that may be made to this Privacy Policy. If You do not agree with the changes, You should discontinue Your access and use of Our Site and the Service.

29.5 Additional Assistance. If You require assistance with exercising Your opt-out or any other rights related to this Privacy Policy, updating Your Personal Data and Information, or submitting a complaint, Our dedicated customer support team is available to assist You.

30. Contact Information

30.1 Contact Details. If You have any questions, concerns, or comments about this Privacy Policy or Our privacy and data practices and standards, please contact Us using the following information:

Email: [email protected]

Postal Address: 8 The Green, STE A, Dover, Delaware, 19901, United States

Telephone: (302) 564-3133 

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