Privacy Policy

1. What information do we collect?

The kind of Personal Information that we collect from you will depend on how you use the website. The Personal Information which we collect and hold about you may include:

Email addresses submitted through the Brevo newsletter signup form for the purpose of sending newsletters about AI, Fintech and RegTech developments in Australia. This includes subscriber email addresses and any associated metadata such as subscription date and preferences.

2. Types of information

The Privacy Act 1988 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

• (a) whether the information or opinion is true or not; and
• (b) whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by us only:

• (a) for the primary purpose for which it was obtained;
• (b) for a secondary purpose that is directly related to the primary purpose; and
• (c) with your consent or where required or authorised by law.

3. How we collect your Personal Information

• (a) We may collect Personal Information from you whenever you input such information into the Website, related app or provide it to Us in any other way.
• (b) We may also collect cookies from your computer which enable us to tell when you use the Website and also to help customise your Website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
• (c) We generally don't collect Sensitive Information, but when we do, we will comply with the preceding paragraph.
• (d) Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party, in cases like this we will take steps to make you aware of the information that was provided by a third party.

4. Purpose of collection

• (a) We collect Personal Information to provide you with the best service experience possible on the Website and keep in touch with you about developments in our business.
• (b) We customarily only disclose Personal Information to our service providers who assist us in operating the Website. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
• (c) By subscribing to our newsletter, you consent to receiving electronic direct marketing material from us. We comply strictly with the Spam Act 2003 (Cth) and do not send unsolicited commercial electronic messages. We only send marketing materials where you have explicitly opted in. Our direct marketing materials will always contain a clear, functional opt-out (unsubscribe) mechanism, and we commit to processing any opt-out requests within five (5) business days. We do not use sensitive Personal Information in direct marketing activities.

5. Security, Access and correction

• (a) We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained in, we will take reasonable steps to destroy and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for a maximum of 7 years to fulfill our record keeping obligations.
• (b) The Australian Privacy Principles:
  • (i) permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
  • (ii) allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
• (c) Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.

6. Complaint procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by Haris Habib and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

7. Overseas transfer

We use Brevo (Sendinblue), a service provider located in France (European Union), to operate our newsletter. Accordingly, your Personal Information may be transferred to and stored on servers located in France and other European Union member states.

We also use third-party analytics and website tracking services, including Google Tag Manager and Microsoft Clarity, which may transfer and store website usage data (such as cookies, IP addresses, and device metadata) on servers located in the United States of America (US).

The European Union and the United States of America have data protection frameworks which protect Personal Information in a way which is at least substantially similar to the Australian Privacy Principles, and there are mechanisms available to you to enforce protection of your Personal Information under those overseas laws. In these circumstances, we do not require the overseas recipients to comply with the Australian Privacy Principles, and we will not be liable under the Australian Privacy Principles for any mishandling of your Personal Information by those overseas recipients.

8. GDPR

In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not specifically target customers located in the European Union and we do not monitor the behaviour of individuals in the European Union, and accordingly the GDPR does not apply.

9. How to contact us about privacy

If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through:

Haris Habib
Sydney, New South Wales, Australia
[email protected]

10. Automated Decision-Making

We do not use your Personal Information in connection with any automated decision-making processes (including profiling or AI-driven evaluations) that produce legal effects concerning you or otherwise significantly affect your rights, interests, or options.