1. About our Privacy Policy

1.1 The privacy of your Personal Information is important to us. We respect your rights to privacy and rights under the Privacy Act and are committed to complying with the requirements of the Privacy Law in the collection and handling of your Personal Information.

1.2 This policy explains how we collect, retain, process, share, transfer and handle your Personal Information and describes the kinds of Personal Information we collect, use, disclose and our purposes for doing so when you use the QOIPR Platform (the Platform), including involving a licensee (Licensee).

1.3 A Licensee may provide their own additional disclosure regarding their usage of your Personal Information and you should ensure you read and understand any Privacy Policy published by a Licensee in connection with your dealings via the Platform.

1.4 Defined terms are used in this policy. You can find the meaning of each defined term at the end of this policy.

1.5 Personal Information is information which may be used to reasonably identify you. For example, your name, address, date of birth, gender, email address, telephone number is generally considered to be Personal Information. Personal Information may also include information we collect about your individual preferences, information relating to your creditworthiness and Credit Information and, if applicable, employment information. We do not collect sensitive information (as defined in the Privacy Act) from you.

1.6 This policy applies to your Personal Information when you use the Platform, and interact generally with the Platform but does not apply to Third Party Sites. The responsibility for privacy policies or content of Third Party Sites belongs with the operators of those sites.

1.7 For the avoidance of doubt, unless stated otherwise, this policy will govern collection of your Personal Information on the Platform irrespective of the forum.

1.8 This policy may be updated from time to time and the most up to date version will be published on the Platform. You should check the Platform periodically to ensure that you are aware of the current policy.

1.9 Your continued usage of the Platform and/or services will be taken to indicate your acceptance of the terms of this privacy policy insofar as it relates to the Platform.

2. Why we collect Personal Information

2.1 When you visit the Platform, your Personal Information is collected so you can be provided with products and services and the performance of the Platform can be improved and customised. Personal Information is collected if it is reasonably necessary for the functions and activities of the Platform.

2.2 The purposes for which your Personal Information is collected includes:

(a) to deliver our products and services to you;

(b) to improve our products and services;

(c) to manage the Licensees relationship with you, evaluate their business performance and build their customer database;

(d) to respond to your requests and seek your feedback;

(e) to provide and improve technical support and customer service;

(f) to conduct research, compare information for accuracy and verification purposes, compile or analyse statistics relevant to the operations of a Licensee’s or the Licensor’s business;

(g) to facilitate internal business operations, including fulfilment of any legal and regulatory requirements and monitoring, analysing and improving the performance and functionality of the Platform and investigating breaches of or enforcement of any legal terms applicable to the Platform;

(h) to protect our property, the Platform or any legal rights including to create backups of business records;

(i) to manage risk and protect the Platform from fraud by verifying your identity and helping to detect and prevent fraudulent use of the Platform;

(j) for the direct marketing and promotional purposes as set out below; and

(k) to manage the business of a Licensee, including analysing data collected from the Platform concerning visits and activities of users of the Platform including the Analytics Services. This analysis helps the Platform run more efficiently and improve and personalise your experience.

3. What Personal Information are collect?

3.1 The kinds of Personal Information collected will depend on the type of interaction you have with the Platform. Generally, the kinds of Personal Information collected may include:

(a) your name, address (postal and residential), email address, telephone number(s), date of birth and gender when you register;

(b) information from third party sources such as data providers and credit organisations, where permitted by law;

(c) details of the device you have used to access any part of the Platform, including carrier/operating system, connection type, IP address, browser type and referring URLs and other information may be collected and used by us automatically if you use the Platform, through the browser on your device or otherwise;

(d) demographic information;

(e) location data;

(f) your connections with others whose personal information which may be collected or hold; and

(g) data regarding your feature usage patterns, interactions on the Platform.

3.2 Telephone calls to a Licensee or our Licensor (if applicable) may also be recorded for training and quality assurance purposes.

4. With whom do we share Personal Information?

4.1 Personal Information collected from you may be disclosed:

(a) To our Licensor, if you are accessing the Platform under licence from an Licensee, and otherwise to our and our Licensor’s related entities, employees, officers, agents, contractors, other companies that provide services to us, sponsors, government agencies or other third parties to satisfy the purposes for which the information was collected (as outlined in clause 2.2 of this policy) or for another purpose if that other purpose is closely related to the primary purpose of collection and an individual would reasonably expect us to disclose the information for that secondary purpose;

(b) to third parties who help verify the identity of users, and other software service providers who assist in providing services we provide to you;

(c) to third parties who help analyse the information collected to administer, support, improve or develop the Platform and the services it provides to you including cloud hosting services, off-site back ups and customer support;

(d) to merchants and the recipients of funds to identify you as the sender of the funds and to a party whom sends you funds in connection with a transfer to you of funds;

(e) if the disclosure is required by a law, or legal process, requested by a government agency or other third parties pursuant to a subpoena, court or other legal process with which we are required to comply, including in relation to our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth);

(f) if disclosure is required to enforce the terms of this policy or to enforce any applicable terms and conditions;

(g) to professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors for the purposes of meeting regulatory obligations, and administer, support, improve or develop business operations;

(h) to debt recovery agencies who assist in the recovery of debts;

(i) to any other person, with your consent (express or implied);

(j) to facilitate the sale of all or a substantial part of the assets or business or to companies with which a proposed merge or acquisition has been made;

(k) to protect the interests of users, clients, customers and third parties from cyber security risks or incidents and other risks or incidents; and

(l) to maintain the integrity of the Platform and protect our rights, interests and property and those of third parties.

4.2 In addition to the above recipients, your Personal Information will be disclosed if required under law or if the disclosure is made in connection with either the normal operation of the Platform in a way that you might reasonably expect, for example, if such disclosure is incidental to IT services being provided or for the resolution of any dispute that arises involving you. This disclosure may involve your Personal Information being transmitted Overseas.

4.3 In the event of a proposed restructure or sale or where a company proposes to acquire or merge with our Licensor (if applicable) or a Licensee, Personal Information may be disclosed to the buyer and their advisers without your consent subject to compliance with the Privacy Law. If the business is sold as a share sale, you acknowledge that this transaction will not constitute the ‘transfer’ of Personal Information.

4.4 De-identified, aggregated data may be disclosed to third parties for marketing, advertising, and analytics purposes. We do not sell or trade your personal information to third parties.

5. How is Personal Information collected, stored and transmitted?

5.1 Information is collected in paper, physical and electronic form when you communicate with us by telephone, email, web-based form, letter, facsimile or other means, including when:

(a) you contact us over the phone;

(b) we provide you with our services via telephone, email or the Platform;

(d) you participate in our functions, events or activities or on our social media pages;

(e) you request that we provide you with information concerning our products or services;

(f) you upload or submit information to us or the Platform; or

(g) you complete any forms requesting information from you, including on registration with us, complete any survey or provide feedback to us concerning our products or services.

5.2 Where practicable we will only collect information from you personally. However, we will also collect your Personal Information through our partners and third parties who supply services to us.

5.3 Please note that we use our own and third party computer servers including the Platform hosts, data backups and payment gateway(s), which may be located Overseas and your Personal Information will likely be stored and transmitted Overseas as part of the normal operation of our business.

5.4 We also collect information from your computer or mobile device automatically when you browse the Platform. This information may include:

(a) the date and time of your visit;

(b) your domain;

(d) operating system;

(e) the server your computer or mobile is using to access the Platform;

(f) your browser and version number;

(g) search terms you have entered to find the Platform or access the Platform;

(h) pages and links you have accessed both on the Platform and on other websites;

(i) the last website you visited;

(j) the pages or modules of the Platform that you access;

(k) the device you use to access the Platform; and

(l) your IP Address.

5.5 While we do not use some of this information to identify personally, we may record certain information about your use of the Platform such as which pages you visit and the time and date of your visit and that information could potentially be used to identify you.

5.6 It may be possible for us to identify you from information collected automatically from your visit(s) to the Platform. If you have registered an account with us, we will able to identify you through your user name and password when you log into the Platform. Further, if you access the Platform via links in an email we have sent you, we will be able to identify you.

5.7 The device you use to access the Platform may collect information about you including your location using longitude and latitude co-ordinates obtained through GPS, Wi-Fi or cell site tri-angulation. For information about your ability to restrict the collection and use of such information, please use the settings available on your device.

5.8 We may use statistical analytics software tools and software known as cookies which transmit data to third party servers located Overseas. To our knowledge, our analytic providers do not identify individual users or associate your IP Address with any other data held by them.

5.9 We will retain your Personal Information for anytime period we consider necessary to provide our products and services to you and to comply with our legal obligations. The period may vary depending on the type of Personal Information we hold.

6. How we protect your Personal Information

6.1 We will endeavour to take all reasonable steps to keep secure and protect any Personal Information which we hold about you, including:

(a) securing our physical premises and digital storage media;

(b) using computer safeguards such as Secure Socket Layer (SSL) technology to ensure that your information is encrypted and sent across the Internet securely;

(c) placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure; and

(d) taking regular back-ups of our electronic systems.

6.2 Notwithstanding that we will take all reasonable steps to keep your Personal Information secure, data transmission over the internet is never guaranteed to be completely secure. We do not and cannot warrant the security of any information you transmit to us or from any online services.

7. Use of Cookies

7.1 When you visit the Platform or the website of any of our partners, we and our partners may use cookies and other tracking technology (Cookies) to recognise you and customise your online experience. Cookies are small files that store information on your computer, mobile phone or other device. They enable us to recognise you across different websites, services, devices and/or browsing sessions. Cookies also assist us to customise online content and advertising, save your preferences for future visits to the Platform, measure the effectiveness of our promotions, prevent potential fraud and analyse your and other users’ interactions with the Platform.

7.2 If you do not wish to grant us the right to use cookies to gather information about you while you are using the Platform, then you may set your browser settings to delete, disable or block certain Cookies. You can find information on popular browsers and how to adjust cookie preferences at the following websites: Microsoft Internet Explorer, Mozilla Firefox, Google Chrome and Apple Safari.

7.3 You may be requested to consent to use of Cookies when you access certain parts of the Platform, for example, when you are asked if you want to “save” certain settings.

7.4 Certain aspects and features of the Platform are only available through use of Cookies. If you disable Cookies, your use of the Platform may be limited or not possible or parts of the Platform may not function properly when you use them.

7.5 Upon first your first visit to the Platform (or the first visit after you delete your Cookies), you may be prompted by a banner to accept our use of Cookies and other tracking technology (Cookies policy). Unless you have adjusted your browser setting so that it will refuse cookies and or declined to accept our Cookies policy, our system will issue Cookies when you access the Platform.

7.6 The Platform may contain web beacons (also called single-pixel gifs) or similar technologies (Web Beacons) which are electronic images that we use:

(a) to help deliver Cookies;

(b) to count users who have visited the Platform; and

7.7 We may also work with third-parties:

(a) to place Web Beacons on their websites or in their promotional materials as part of our business development and data analysis; and to

(b) to allow Web Beacons to be placed on the Platform from Analytics Services to help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations.

7.8 The Web Beacons of Analytics Services may enable such providers to place Cookies or other identifiers on your device, through which they may collect information about your online activities across applications, websites or other products.

8. How we use Personal Information for communicating with you and direct marketing

8.1 We may communicate with you by phone, email, SMS or push notification, to inform you about existing and new products and services that may be of interest to you including administering contests, promotions, surveys or other site features.

8.2 We will ensure that any email we send as direct marketing complies with the SPAM Act 2003 (Cth) and contain an ‘unsubscribe’ option so that you can remove yourself from any further marketing communications. To opt-out of communications via SMS, reply with “STOP”. You may decline marketing messages sent by push notifications by refusing the relevant permission in your phone or tablet settings, however this setting will prevent you from receiving other messages from us via push notification. You may also opt-out of receiving marketing materials from us using the contact details set out below or adjusting your user dashboard on the Platform.

8.3 You can also call or write to us to request that your details be removed from our direct marketing list. We will endeavour to remove your details from our direct marketing list within a reasonable time (ordinarily 5 working days).

8.4 Our direct marketing list may be operated by software and servers located Overseas and your Personal Information may be sent Overseas as part of our marketing.

8.5 We will also send communications that are required or necessary to send to users of the Platform that contain information about important changes or developments to or the operation of the Platform or as well as other communications you request from us. You may not opt out of receiving these communications but you may be able to adjust the media and format through which you receive these notices.

9. Not identifying yourself

9.1 It may be impracticable to deal with you on an anonymous basis or using a pseudonym.

9.2 We may be able to provide you with limited information in the absence of your identifying yourself but generally we will be unable to provide you with any information, goods and/or services unless you have identified yourself.

10. How to access or correct your Personal Information or make an enquiry or complaint

10.1 If you have any queries in relation to this policy, you wish to access or correct the Personal Information we hold about you, or make a complaint, please contact us in writing at:

Email: sales@qoipr.com; or

Mail: Privacy Officer

E-Volve Innovation Pty Ltd

Level 35, 100 Barangaroo Avenue, Sydney NSW 2000

10.2 We aim to acknowledge receipt of all privacy complaints from you within 5 working days and resolve all complaints within 30 business days. Where we cannot resolve a complaint within that period, we will notify you of the reason for the delay as well as advising the time by which we expect to resolve the complaint.

10.3 In order to disclose information to you in response to a request for access we may require you to provide us with certain information to verify your identity. There are exceptions under the Privacy Law which may affect your right to access your Personal Information – these exceptions include where (amongst other things):

(a) access would pose a serious threat to the life, health or safety of any individual;

(b) access would have an unreasonable impact on the privacy of others;

(d) the information relates to existing or anticipated legal proceedings between you and us and the information would not otherwise be accessible by the process of discovery;

(e) giving access would reveal our intentions in relation to negotiations with you;

(f) giving access would be unlawful;

(g) denying access is required or authorised by or under an Australia law or a court/tribunal;

(h) the information relates to commercial sensitive decision-making process; or

(i) giving access would prejudice enforcement related action.

10.4 We may (depending on the request) charge you a fee to access the Personal Information. We will inform you of any fees payable in respect of accessing your Personal Information prior to actioning your request. All requests for Personal Information will be handled in a reasonable period of time (within 14 days if possible but otherwise within 30 calendar days after the request is made).

10.5 If you wish to have your Personal Information deleted, please contact us using the details above and we will take reasonable steps to delete the information (unless we are obliged to keep it for legal or auditing purposes). To the extent that any Personal Information is stored on a blockchain it may be impracticable, unfeasible or impossible to delete.

10.6 In the event that you believe that there has been a breach of the Privacy Law, we invite you to contact us as soon as possible.

10.7 If you are not satisfied with our handling of a complaint or the outcome of a complaint you may make an application to:

(a) the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing enquiries@oaic.gov.au; or writing to GPO Box 5218 Sydney NSW 2001;

(b) the Privacy Commissioner in your State or Territory.

10.8 You may also view, access, edit or delete (to the extent possible) your Personal Information through a user dashboard on the Platform. There may be certain data or information that may not be edited or deleted for you to be able to access the Platform.

11. Notifiable Data Breach

11.1 We are bound by the Privacy Act and are committed to complying with the Notifiable Data Breaches Scheme (NDB) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017.

11.2 The NDB requires that where a data breach is likely to result in serious harm to any individuals to whom the information relates, we are required to notify those individuals and the Office of the Australian Information Commissioner.

11.3 The NDB provides greater protection to the personal information of consumers, greater transparency in the way organisations like us respond to data breaches and give you the opportunity to minimise the damage caused by any unauthorised use of your Personal Information.

12. Changes to this Privacy Policy

12.1 We may amend this privacy policy from time to time at our sole discretion, particularly where we need to take into account and cater for any:

(a) business developments; or

(b) legal or regulatory developments.

12.2 If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, may provide you with additional notice (such as adding a statement to the Platform homepage or sending you a notification). We recommend you review the Privacy Policy whenever you access the Services or otherwise interacts with us to stay informed about our information practices and the ways you can help us to protect your privacy.

13. Disclosure to credit reporting bodies

13.1 We may disclose certain information about you to credit reporting bodies (CRBs). This information may include credit information and credit eligibility information such as your repayment information or default information. For example, if you fail to meet payment obligations we may disclose this default information about you to a CRB. The CRB may include such information in reports provided to credit providers to assist them in assessing your credit worthiness.

13.2 We disclose information to, and may collect information from, the following CRBs:

Equifax Illion Experian

Website: www.equifax.com.au www.illion.com.au www.experian.com.au

Phone number: 13 83 32 1300 734 806 1300 783 684

13.3 You have the right to request that the above CRBs do not:

(a) Use credit reporting information for the purposes of pre-screening of direct marketing:

(b) by a credit provider; or

(c) Use or disclose credit reporting information if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.

13.4 If you would like more information about how the above CRBs manage credit related information you can contact them directly.

13.5 If you would like to access or change credit information that we hold about you or have any complaints please contact us in the same way that you would access, change or make a complaint about the other personal information that we hold about you.

14. Definitions used in this policy

(a) Analytics Services means any third party website analytics provider which we may use.

(b) Australian Privacy Principles or APPs means the principles set out in Schedule 1 to the Privacy Act.

(c) Credit Information means credit related personal information being credit information, credit reporting information, credit eligibility information or regulated information as applicable in the context as defined by the Privacy (Credit Reporting) Code 2014 (Version 2.1);

(d) IP Address means a number automatically assigned to your computer which is required when you are using the internet and which may be able to be used to identify you.

(e) Licensor means the owner of the underlying Intellectual Property in the Platform who has issued a valid and ongoing license to the Licensee to use the Platform.

(f) Licensee means a party using the Platform under a valid and ongoing license.

(g) Overseas means any place or country other than Australia and includes the following countries: United States of America, United Kingdom, European Union, Philippines, India, Canada, Singapore and New Zealand.

(h) Personal Information has the meaning set out in the Privacy Act.

(i) Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time.

(j) Privacy Law means such laws as may place requirements on the handling of Personal Information under the Privacy Act and the Australian Privacy Principles.

(k) Platform means the software known as the Platform which may be used under licence by a Licensee.

(l) Third Party Sites means online websites or services that we do not own or control, including websites of our partners

(m) you, your and similar terms means, as the context requires (1) you, when you use the Platform; and/or (2) you, during your dealings with us as a customer; and/or (3) any agent providing your Personal information to us; and/or (4) any agent dealing with us on your behalf.

Privacy and Cookies Policy