Privacy Policy

In this Privacy Policy,'us' 'we' or 'our' means Yellow Canary Operations Pty Ltd (ACN 644 016 802) and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from timeto time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

‘Personal information’ has the meaning given to it in the Privacy Act 1988 (Cth) (Privacy Act) but generally means any information about a person who is identified, or who isreasonably identifiable.

What personal information do we collect?

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• age or date of birth;
• credit card information;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
• information you provide to us through customer surveys; or
• any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:

• sign up for, access, or use our services, including any platforms, apps, products, and services owned or operated by us;
• communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
• interact with our sites, services, content and advertising; or
• invest in our business or enquire as to a potential purchase in our business.

Our customers may be required under their agreements with us to remove certain identifying information before providing data to us. However, information provided to us may nevertheless contain personal information, including where information has not been fully de-identified. Where this occurs, we handle that personal information in accordance with this Privacy Policy and our applicable privacy, security and data governance requirements.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

• to enable you to access and use our website, services, platform, products and apps;
• to operate, protect, improve and optimise our website, services, platform, products and apps, business and our users’ experience, such as to perform analytics, conduct research, develop and support our products and services, including approved artificial intelligence-enabled functionality, and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to use approved artificial intelligence systems and tools to support our internal operations, service delivery, product development and products and services, where the relevant use is authorised and appropriate for the information involved;
• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
• to consider your employment application.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

Artificial Intelligence

We use artificial intelligence (AI) in connection with our internal operations, service delivery, product development and certain features made available through our products and services. Depending on the relevant use, AI may assist with activities such as analysing information, supporting workflows, identifying patterns or anomalies, and generating content, insights or recommendations.

Where personal information is processed using AI, the relevant use must be approved for that purpose and information and is subject to our applicable privacy, information security, data governance and contractual requirements. We apply controls having regard to the nature and sensitivity of the information and the risks associated with the relevant AI use.

We may use third-party technology, cloud or AI service providers to support approved AI uses. Where this involves personal information, we assess the relevant privacy, security, data handling and contractual arrangements before approving the use.

We do not use personal information to train, fine-tune or improve an AI model unless that use has been specifically assessed and approved under our AI governance processes and is otherwise permitted by applicable law and contractual arrangements.

AI-generated outputs may be inaccurate, incomplete or inappropriate. We apply human oversight proportionate to the nature and potential impact of the relevant use. Where AI materially informs or influences a decision affecting an individual, the person responsible for the decision critically assesses the AI-generated output and, where appropriate, rejects, amends, overrides or escalates it.

If you have concerns about a material outcome involving AI, you may contact us using the details at the end of this Privacy Policy.

For more information about how we use and govern AI, including in our products and services and in relation to client data, you can request a copy of our AI Position Statement by contacting our Privacy Officer at info@yellowcanary.com.au.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this privacy policy to:

• our employees and related bodies corporate;
• third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you, such as cloud, technology and AI service providers);
• professional advisers, dealers and agents;
• payment systems operators (eg merchants receiving card payments);
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or businesses (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to third party service providers or contractors who help us conduct our business. Additionally, in respect of personnel or representatives of our customers, if a customer (or that customer’s corporate group) is based overseas, we may disclose your personal information to that relevant country. Given these disclosures occur and change from time to time, it is not practicable to list all such countries here.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.

For the avoidance of any doubt, we confirm that all of your Personal Information is stored in data centers located in Australia.

Using our website and cookies

We may collect personal information about you when you use and access our website, including information about your device, browser, IP address, the pages you access, the date and time of your visit and how you interact with our website.

Information collected through our website may not identify you on its own. However, if you subsequently provide us with identifying information, for example by completing a form, subscribing to communications or otherwise contacting us, we or our service providers may associate that information with information previously collected about your use of our website. Where information identifies you or makes you reasonably identifiable, we handle it as personal information in accordance with this Privacy Policy.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

The types of cookies and similar technologies we may use include:

• essential cookies, which are necessary to operate and secure our website and provide its core functionality;
• functional cookies, which remember preferences and settings and help improve your experience;
• analytics cookies, which help us understand how visitors use and interact with our website and improve its performance; and
• marketing cookies, which may help us measure the effectiveness of our marketing, understand engagement with our communications and deliver or measure relevant advertising.

You may manage non-essential cookies through any cookie controls we make available, your browser settings or other opt-out mechanisms made available by relevant service providers. Disabling certain cookies may affect the operation or functionality of our website.

You may also contact our Privacy Officer using the details below if you would like to request deletion of Personal Information we hold about your use of our website. We will consider your request in accordance with applicable law and may retain information where reasonably necessary or permitted or required by law.

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. This includes through physical, procedural and technical measures, including restricting access to your personal information to those individuals who need it to perform their job.

In addition, we have ISO/IEC 27001 and SOC 2 certifications. These frameworks guide our approach to access control, data encryption, monitoring, incident response, and third-party risk management of your data. We regularly review and update our security practices to address emerging threats and maintain the trust of our customers and partners.

Where AI is used, these controls are supplemented by our AI governance processes, including approval requirements, data classification controls, third-party and vendor assessment, testing and monitoring, and incident management requirements appropriate to the relevant use.

The above notwithstanding, you should be aware that no security measure is ever perfect or impenetrable, and we cannot guarantee the security of your personal information.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the information below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Contact us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact our Privacy Officer at info@yellowcanary.com.au.

Effective: September 2026

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