Privacy Policy

Introduction

We (Cradle Pay Pty Ltd ABN 91 626 294 237) take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.

By providing personal information to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your personal information. Capitalised words in this Privacy Policy have the same meaning as in the Terms of Use available on the Platform.

TYPES OF PERSONAL INFORMATION WE COLLECT

The personal information we collect may include the following:

- Registration information: this includes information that we collect when you register to use our Platform by creating an Account. The information we collect includes your name, mailing or street address, email address, social media information, telephone number and other contact details, age and any other information you directly give us at the registration stage.

- Platform use information: When you use our Platform, for example for quotes or for invoicing arrangements we collect information that enables the Platform to be able to run. This includes details contained in a quote such as customer details, milestone details, imagery, messages, payment amounts as well as information regarding the invoicing arrangements such as transaction details and funding instruments used to complete the transaction. This may also include any information given during a dispute.

- Participant information: When you use the Platform to send quotes or send requests for payment, or respond to any requests, we collect the details of each party to facilitate the transaction. If you are a Customer, we will also collect your details when a Contractor provides them to us.

- Surveys: information in connection with client surveys, questionnaires and promotions;

- Other information we collect related to your use of the Platform: your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information and any other information provided by you to us via our Platform or our online presence, or otherwise required by us or provided by you.

We do not intend to collect any sensitive information about you.

HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information either directly from you, or from third parties, including where you:

- register or sign up to the Platform;

- use the Platform to create quotes or invoices, or respond to them;

- where you are a party to a transaction;

- contact us through our website;

- submit any of our online sign up forms;

- communicate with us via email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise;

- interact with our website, social applications, services, content and advertising;

and

- invest in our business or enquire as to a potential purchase in our business.

Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party. We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, cookies'; or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.

USE OF YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

- to operate the Platform and provide services or information to you including to:

o enable us to send quotes you create and manage them;

o send or request payment of an invoice;

o enable you to communicate with other users;

o confirm your identity;

o communicate with you about your Account, or any transaction;

- for record keeping and administrative purposes;

- to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you;

- to improve and optimise our service offering and customer experience;

- to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;

- to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);

- to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and

- to consider an application of employment from you.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information to cloud-providers, contractors and other third parties located inside or outside of Australia. If we disclose personal information outside of Australia, we will take reasonable steps to ensure that any overseas recipient deals with such

personal information in adherence with the Australian Privacy Principles.

We may also disclose your personal information to those third parties involved in your use of the Platform. This includes:

- the other User you are transacting with;

- any payment agent of ours;

- any service providers.

STORAGE & SECURITY

We store your personal information on web servers in Australia. Please be aware that we may use third-party cloud providers that provide hosting, data storage and other services. We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measure to protect these systems.

However, we cannot guarantee the security of your personal information. We will retain your Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

LINKS

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION

Subject to the Privacy Act, you have a right to access and correct any personal information about you that we may hold. If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe. If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected. If we receive a request from you to access or correct Personal Information we will respond to you within a reasonable time after receiving your request and in the manner requested by you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for giving access to the information.

REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION

If you do not provide us with the personal information described above, some or all of the following may happen:

- we may not be able to provide the Platform to you, either to the same standard or at all;

- we may not be able to provide you with information about the Platform that you may want; or

- we may be unable to tailor the content of our Platform to your preferences and your experience of our websites may not be as enjoyable or useful.

NOTIFIABLE DATA BREACH

In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in Part IIIC of the Privacy Act or any other subsequent sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable data breach procedures in compliance with the Privacy Act and relevant laws.

UPDATES

This Privacy Policy is subject to occasional revision and we reserve the right, at our sole discretion, to modify or replace any part of this Privacy Policy. It is your responsibility to check this Privacy Policy periodically for changes. Continued use of our website or services shall indicate your acknowledgement of that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications. We may amend this Privacy Policy from

time to time. Not all changes to our Privacy Policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.

ENQUIRIES, REQUESTS & COMPLAINTS

Enquiries regarding this Privacy Policy or the personal information we may hold on you, should be addressed with the Privacy Officer, whose contact details are below. If you think your personal information, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with the Privacy Officer. We will ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances. If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission, whose contact details are below.

Office of the Australian information Commission

Telephone 1300 363 992

Email enquiries@oaic.gov.au

Office Address Level 3, 175 Pitt Street, Sydney NSW 2000

Postal Address GPO Box 5218, Sydney NSW 2001

Website www.oaic.gov.au

Contacting us

Entity Cradle Pay Pty Ltd

Telephone 0403 906 009

Email enquiries@cradlepay.com

Office Address 17 Raglan st, South Melbourne VIC 3205

Postal Address As above