INGENIOUS AI PRIVACY POLICY - PLATFORM

1 PURPOSE OF OUR POLICY

1.1 inGenious AI Pty Ltd ABN 63 617 284 492 (we, us or our) has adopted this Privacy Policy to ensure that we have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:

(a) Providing the system and services that we offer; and (b) The normal day-to-day operations of our business.

1.2 This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act).

1.3 By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

1.4 This privacy policy may be updated from time to time by us as our business changes and if laws or regulations change.

2 WHO AND WHAT THIS POLICY APPLIES TO

2.1 Our Privacy Policy deals with how we handle “personal information” as it is defined in the Privacy Act (Personal Information).

2.2 We handle Personal Information in our own right and also for and on behalf of our customers and users.

2.3 Our Privacy Policy does not apply to information we collect about businesses or companies, however it does apply to information about the people in those businesses or companies that we store.

2.4 The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

2.5 If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person’s consent to provide such information for the purpose specified.

2.6 Our website and services are unavailable to children (persons under the age of 18 years) without their parent or legal guardian’s consent.

3 THE INFORMATION WE COLLECT

3.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the kind of personal information we may collect is:

(a) Your full name (b) Address (c) Company name (d) Email address (e) Phone number (f) Information made available to us by you via our social media account services (Facebook, YouTube, Google+, twitter, Linkedin and any similar service) (g) Information about your credit or trading history (h) Your transaction and repayment history with us (i) Banking or credit card details (j) Statistical information (k) Personal correspondence sent by you or sent by others relating to you

3.2 We do not generally collect sensitive information about you. Sensitive information includes things like information or opinions about your racial or ethnic origin, political opinion, religious beliefs and sexual orientation. We will only collect sensitive information with your consent, and where that information is reasonably necessary for us to provide the services to you.

3.3 We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.

3.4 We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.

4 HOW INFORMATION IS COLLECTED

4.1 Most information will be collected in association with an individual’s use of inGenious AI, an enquiry about inGenious AI or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:

(a) Accessing our service. When an individual provides Personal Information when using our service. (b) Registrations/Subscriptions. When an individual registers or subscribes for a service, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction; (c) Sharing with other Users. When an individual provides Personal Information to other users of the website or service; (d) Supply. When an individual supplies us with goods or services; (e) Contact. When an individual contacts us in any way; (f) Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or (g) Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.

4.2 We also collect the content you create, upload, or receive from others when using our services, which may include Personal Information.

4.3 As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.

4.4 Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.

4.5 We may also receive personal information about you from third parties, where reasonably necessary to provide you with services. If we do, we will handle and protect it as set out in this Privacy Policy.

5 HOW WE HOLD PERSONAL INFORMATION

5.1 We will take reasonable steps to protect your personal information while it is in our control, but please be aware that despite our best efforts, no data security or other measures can guarantee 100% security.

5.2 We keep the personal information you provide to us:

(a) If it is in hardcopy form, in secure buildings with secure systems and processes. (b) If it is in electronic form, in secure systems protected by passwords, virus protection software and firewalls.

5.3 Certain personal information about you may be linked with other information about you. Only our authorised officers can access your personal information and our databases are protected by passwords.

6 RETENTION OF PERSONAL INFORMATION

6.1 How long we keep information we collect about you depends on the type of information and what it is used for. We retain personal information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolves disputes and enforce our agreements).

6.2 We will take reasonable steps to de-identify or destroy your personal information if we no longer require it. This includes requesting that any backup copies of information held by third parties are returned to us, de-identified or destroyed, and taking steps to ensure that this has occurred. We note that residual copies of information may persist for up to 180 days due to the backup systems that we use.

6.3 If you provide us with Personal Information when using our services, you have a right to request that we destroy the Personal Information if the Personal Information is not reasonably necessary to us to provide you with our services.

7 WHEN PERSONAL INFORMATION IS USED & DISCLOSED

7.1 In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.

7.2 If it is necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business, we will inform you that we intend to do so and obtain your consent before doing so, except in circumstances where we are required by law to disclose to a third party (eg to enforcement agencies, government agency and regulatory bodies).

7.3 We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.

7.4 Information is used to enable us to operate our business, especially as it relates to an individual. This may include: (a) The provision of goods and services between an individual and us; (b) Verifying an individual’s identity; (c) Communicating with an individual about: i) Their relationship with us; ii) Our goods and services; iii) Our own marketing and promotions to customers and prospects; iv) Offers from our partners to our customers; v) Competitions, surveys and questionnaires; (d) Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or (e) As required or permitted by any law (including the Privacy Act).

7.5 There are some circumstances in which we must disclose an individual’s information:

(a) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of; (b) As required by any law (including the Privacy Act); and/or (c) In order to sell our business (in that we may need to transfer Personal Information to a new owner).

7.6 Personal Information collected by us will be stored in Australia. We will not disclose an individual’s Personal Information to any entity outside of Australia.

7.7 For client’s located outside Australia, we may store personal information in your country or region of origin, such as the European Union, United States, Singapore or where required to meet laws of your country or region of origin. We currently store personal information from these countries / regions in: Australia.

8 OPTING “IN” OR “OUT”

8.1 An individual may opt to not have us collect their Personal Information. This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us. They will be aware of this when:

(a) Opt In. Where relevant, the individual will have the right to choose to have information collected and/or receive information from us; or (b) Opt Out. Where relevant, the individual will have the right to choose to exclude himself or herself from some or all collection of information and/or receiving information from us.

8.2 If an individual believes that they have received information from us that they did not opt in or out to receive, they should contact us on the details below.

9 THE SAFETY & SECURITY OF PERSONAL INFORMATION

9.1 We may appoint a Privacy Officer to oversee the management of this Privacy Policy and compliance with the Australian Privacy Principles and the Privacy Act. This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.

9.2 We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks.

9.3 inGenious AI uses encryption to store and transfer Personal Information. Despite this, the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet, over the phone or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.

9.4 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.

9.5 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.

9.6 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.

10 ANONYMITY

10.1 You may deal with us by using a pseudonym, or by remaining anonymous.

10.2 However, if you use a pseudonym or remain anonymous, we may not be able to provide you with our services or handle your enquiries or complaints to the fullest extent.

10.3 We may also be required by law to identify you when we supply you with services.

11 YOUR RIGHTS RELATING TO PERSONAL INFORMATION

11.1 You have certain rights under law regarding your personal information, including:

(a) a right to request access, correction, update or deletion of your personal information; (b) a right to object to processing of your personal information or withdraw your consent to our processing of your personal information at any time; (c) a right to restrict our processing of your personal information or request that we provide you with a copy of your personal information; and (d) the right to lodge a complaint with a supervisory authority if you think our processing of your personal information infringers applicable laws. The process for a complaint is set out below.

11.2 If you wish to exercise any of those rights, you can contact notices@ingenious.ai.

12 HOW TO ACCESS AND/OR UPDATE INFORMATION

12.1 Users of inGenious AI can update their Personal Information from within their inGenious AI account or profile.

12.2 Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.

12.3 If an individual cannot update its own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.

12.4 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.

12.5 We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.

13 COMPLAINTS AND DISPUTES

13.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.

13.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.

13.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.

14 CONTACTING INDIVIDUALS

14.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.

15 CONTACTING US

15.1 All correspondence with regards to privacy should be addressed to:

The Privacy Officer inGenious AI Pty Ltd Level 4, 152 Elizabeth Street Melbourne, Victoria, 3000 notices@ingenious.ai

You may contact the Privacy Officer by email in the first instance.

16 ADDITIONS TO THIS POLICY

16.1 If we decide to change this Privacy Policy, we will post the changes on our webpage at http://ingenious.ai/privacy. Please refer back to this Privacy Policy to review any amendments.

16.2 We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.

Version 3.0 (30/10/2022)