BCI AUSTRALIA PTY LTD – PRIVACY POLICY

BCI Australia Pty Ltd t/a Archify ABN 83 164 945 368 (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website, our Archify platform and consulting services (Services) or when otherwise interacting with you.

1) The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

As a customer of ours:

• your name;

• your contact details, including your email address and/or telephone number;

• credit card or other payment details; and

• information you voluntarily provide to us through your feedback and enquiries.

When you apply for employment with us:

• your name;

• your CV and pre-employment history; and

• your contact details, including your email address, emergency contact details, telephone number and /or other details pertaining to your application.

When you register as a user of the Archify platforms (Platforms):

• your name;

• your contact details, including your email address, address and/or telephone number;

• your device’s contact list and other information you choose to sync to the Platforms from your device; and

• information you voluntarily provide to us through your feedback and enquiries.

When you visit our website:

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;

• your name;

• your employer and job title;

• your date of birth;

• your credit card or other payment details;

• your preferences and/or opinions;

• information you provide to us, including through feedback, customer surveys or otherwise;

• details of products and services we have provided to you and/or that you have enquired about, and our response to you;

• support requests submitted to us and our response to you;

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;

• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;

• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and

• any other personal information requested by us and/or provided by you or a third party.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

2) How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including when you register an account on our Platforms, contact us in person, by email, telephone, or participate in any of our industry events, training, or promotional campaigns.

• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our Platforms, when you use our website, in emails, over the telephone and in your online enquiries.

• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

3) Why we collect, hold, use and disclose personal information

As a customer of ours and/or as a user of our Platforms:

• to enable you to access and use our software, including to provide you with a login;

• to contact and communicate with you about our Services, including in response to any support requests or complaints you lodge with us or other enquiries you make with us;

• for internal record keeping, administrative, invoicing and billing purposes;

• for analytics, market research and business development, including to operate and improve our Services and associated applications;

• to comply with our legal obligations and resolve any disputes that we may have; and/or

• if otherwise required or authorised by law.

If you are applying for employment with us:

• to contact and communicate with you about your application;

• to process your application;

• for internal record keeping and administrative purposes; and/or

• if otherwise required or authorised by law.

When you visit our website:

• to provide our website to you;

• to contact and communicate with you about any enquiries you make with us via our website;

• to comply with our legal obligations and resolve any disputes that we may have; and/or

• if otherwise required or authorised by law.

4) Our disclosures of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, email marketing providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;

• our employees, contractors and/or related entities including those located in the United Kingdom, New Zealand, Thailand, Malaysia Australia, Vietnam, Hong Kong and Singapore;

• if you are applying for a position with Archify, other persons that we need to deal with in connection with employment and engagement of staff (such as insurers, next-of-kin, referees), to our related entities and other BCI group companies located in the countries noted above, and to other companies or individuals who assist us in supplying our products and services or who perform functions on our behalf, such as payroll operators and technology hosting providers;

• our existing or potential agents or business partners;

• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

• third parties to collect and process data; and

• any other third parties as required or permitted by law, such as where we receive a subpoena.

5) Overseas disclosure

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, including our related entities, these third parties may store, transfer or access personal information outside of Australia, including but not limited to, in the United Kingdom, New Zealand, Thailand, Malaysia Australia, Vietnam, Hong Kong and Singapore.

6) Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.

7) Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

These procedures include:

• training and reminding our staff of their obligations with regard to your personal information;

• using software which encrypts information (where a lock symbol appears on the browser window);

• utilising passwords, firewalls and virus scanning tools, and protection in buildings where personal information is stored, to prevent against unauthorised access to our systems; and

• restricting staff and volunteers that have access to the databases that store user information and to personal files.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

8) Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

9) Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

10) Personal information from social network accounts

If you connect your account with us to a social network account, such as Facebook, Google, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.

We use the personal information we receive from the social network to create a profile for you on our Platforms.

If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

11) Use of Google API Services (this section applies to personal information accessed through Google API Services)

We may use Google’s Application Programming Interface (API) Service.

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements (set out in the Google API Services User Data Policy).

We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.

We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.

We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.

These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.

We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.

12) Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

BCI Australia Pty Ltd ABN 83 164 945 368

Mail	:	Suite 202, Level 2, 754 Pacific Highway, Chatswood NSW 2067
Phone	:	+611300224287
Fax	:	+61294324111
Email	:	[email protected]

Last update: 16 June 2022

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