When you use our services, you trust us with your information. We respect your privacy. This Privacy Policy is designed to ensure your personal information is protected and to help you understand what data we collect, why we collect it, and what we do with it. This Privacy Policy applies to the services, products, websites and applications (collectively, “Services”) of Hullabaloo (B2B) Solutions Pty Ltd A.B.N. 44 124 045 334 (“we”, “our” or “us”). We are bound by the Privacy Act 1988, including the Australian Privacy Principles, and any relevant privacy code registered under the Privacy Act.

1. Purpose of This Policy

The purpose of this policy is to generally inform you of:

(a)  how and when we collect personal information and personal data;

(b)  how we use and disclose personal information and personal data;

(c)  how we keep personal information and personal data secure, accurate and up-to-date;

(d)  how an individual can access and correct their personal information and personal data; and

(e)  how we will facilitate or resolve a privacy complaint.

2. Compliance, Incorporation by Reference and Updates

This Privacy Policy is a compliance document prescribed by law. Certain contracts between you and us may incorporate all, or part, of the Privacy Policy into them.

By using the Services you agree to the Privacy Policy in force from time to time. If you do not accept the Privacy Policy in force from time to time, do not access, use, register with, submit information to, upload, download from or engage with our Services.

Please note that information about companies is not personal information. However, the principles will apply to an individual who is carrying on a business as a sole trader. All Hullabaloo offices in Australia are subject to policies and procedures that seek to ensure Hullabaloo complies with the Australian Privacy Principles.

We may modify this Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information due to the changes in our policy, please cease providing us with your personal information and contact us via the details set out in paragraph 22 of this document.

3. How We Collect and Receive Personal Information

We collect and receive personal information about users of the Services. This information is either collected or received by us or submitted or shared by users of the Services.

The information includes data of a personal nature you supply to us, and data on the pages you access, your device’s IP address, device identifiers, the type of operating system you’re using, your location, mobile network information, and standard web log data. Standard web log data includes the browser type you’re using and traffic to and from our Services.

When you use the Services, we may receive information about your location and your device, including a unique identifier for your device. We may use this information to provide you with location-based services and other personalised content.

In addition, we may collect and store any information you provide us when you use the Services or related services, including when you correspond with us, add information on a web form, add or update your account information, or participate in discussions, chats, or resolution of disputes.

We may also obtain information about you from third parties such as credit reporting agencies and identity verification services.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (eg LinkedIn, Facebook and Twitter). The information we may receive varies by site and is controlled by such sites. By associating an account managed by a third party with your account with us and authorising us to have access to this information, you agree that we may collect, store, and use this information in accordance with this Privacy Policy.

4. Types of Personal Information

We Collect, Receive and Hold We may collect the following types of personal information from you:

(a) contact information, such as your name, business name, address, email address, phone numbers, tax ID or registration numbers, social media handles, and similar information;

(b) personal information, such as date of birth, gender and educational qualifications; and

(c) financial information, such as bank account details and credit card information.

5. How We Use Personal Information

The lawful basis and primary purpose for collecting and processing your personal information and data is to provide you with a secure, smooth, efficient, and customised experience. We comply with the European General Data Protection Regulation which governs the protection of personal data of EU residents. In addition to law in Australia, we will afford UK-based users with all rights available to EU users, regardless of the UK’s EU member status. We may use your personal information to:

(a) provide you as a contractual obligation under our contract with you as our customer – customer support and information on our products, services, events, programs, newsletters, email updates, and other services; Privacy Policy 3 of 7

(b) verify your identity, including during account creation and password reset processes and to pursue other activities within our legitimate interests as part of running our business and doing so in ways which do not hurt your interests and rights, for example obtaining identity, device and location information to prevent fraud and abuse and to keep the Services secure and obtaining and retaining data which tax laws require us to retain for payments made or received by us;

(c) customise, measure, and improve the content, layout, and operation of the Services;

(d) contact you at any telephone number, or by placing a voice call or through text (SMS), messaging services or email messaging;

(e) manage and protect our information technology infrastructure, which is necessary to provide the services and features you request and serve the legitimate interests of ourselves and third party processors;

(f) share minimal personal information and data with third party processors in order for us to provide services under our contract with you, including service providers of hosting, storage and infrastructure, security, insurance, analytics, communications and support, and payment processing;

(g) perform creditworthiness and solvency checks, compare information for accuracy and verify it with third parties;

(h) design products and services;

(i) provide to you targeted marketing about our services and promotional offers and the services of our contractors unless and until you opt-out;

(j) include you in our databases, directories, and listings to communicate with you;

(k) process any transactions by you and send notices about your transactions;

(l) confirm your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and assess applications or creditworthiness for premier or business accounts or products and services offered to premier or business accounts with third parties;

(m) resolve disputes, collect fees, and troubleshoot problems;

(n) detect, prevent or resolve violations of policies or applicable user agreements; and

(o) manage our risks and help detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities.

If you are located in the European Union or other regions with laws governing data collection and use that may differ from Australian law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take steps reasonably necessary to ensure that any personal data is treated securely and in accordance with this Privacy Policy.

We provide services in conjunction with payment processors which may include processors such as financial or merchant facility providers such as PayPal. When you delete your account with us, we delete your personal data retained by us, except to the extent we are prevented by law from deleting your personal information or data. However, to delete any payment or billing information, you will need to do so with your payment provider, as we only have minimal secure access to those records as needed to provide the services.

6. To Communicate with You

We may send you emails, text messages, and push notifications to your devices if you have them enabled, to verify your account and for informational and operational purposes, such as account management, providing instructions, alerts, reminders, customer service, system maintenance, and other purposes related to the Services.

7. Protection of Personal Information

We use technological, legal and training means to provide high levels of security and privacy for personal information.

Despite our security and privacy measures, personal information we collect is at your risk. Please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your pages and information. Even after removal, copies of user-generated content may remain viewable in cached and archived pages elsewhere or files stored by others. Any improper collection or misuse of information should be reported to us.

You are responsible for taking reasonable precautions to protect your user ID, password and other account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify us if you know of or suspect any unauthorised use or disclosure of your user ID, password, and/or other user account Information, or any other security concern.

8. Privacy of Email Addresses

The Services provide users the opportunity to opt-out of receiving communications, usually at the point where we request information about the user.

9. Aggregated Browser Information

We analyse Services logs to constantly improve service. We use the log information to record various information regarding different sections of the Services. This helps make the Services more useful.

10. Cookies and Analytics Technologies

We may use cookies and similar technologies. Cookies are pieces of data that a website or email transfers to your device’s hard disk. Cookies can make your use of the web faster and beneficial by storing information about your preferences. Many major sites use cookies to provide useful features for their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s device. Most browsers are initially set up to accept cookies. If you’d prefer you can set yours to refuse cookies. However, you may not be able to take full advantage of a website if you do so.

11. Permitted Disclosure

If you become a registered user of any of the Services, you will be taken to consent to:

(a) your personal data being transferred to and processed in countries where our hosting servers are located;

(b) us using your personal information to check your identity, including to check your status (eg as a member of a defined user group) and for any merchant facility arrangement we have with bankers, their respective related bodies corporate, and their respective officers, employees and agents;

(c) use of your personal information by us and our authorised personnel and service provider contractors; for example, to improve service we may provide your personal information as statistical data to others for research and analysis purposes; and as another example we may use Google Analytics and give you notice of its operation on the webpage titled “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/).

(d) us disclosing your personal information in situations where we reasonably believe it is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering with our rights, either intentionally or unintentionally; and

(e) us disclosing your personal information to law enforcement agencies and others if we in good faith believe we are legally obligated to do so.

12. Links

The Services may contain links to sites and applications published by others. We have no control over their privacy practices.

13. Right of Access and Correction

Generally speaking, you may access the personal information the Services hold about you by sending an email giving full details to our Privacy and Data Protection Officer set out in paragraph 22. Generally, if any of that information is incorrect, you can have that information corrected by sending an email giving full details to that Privacy and Data Protection Officer. If you provide us with your personal information and you later decided that you would no longer like to receive information from us, follow the “unsubscribe” directions at the end of any email or other communication you receive from us. You may withdraw consent by deleting your account at any time.

14. Disclosure of Personal Information Abroad

The nature of our business activities may on occasion require that personal information be disclosed to overseas recipients in order to provide the services contemplated under the terms of our engagement or prospective engagement. The location of any overseas recipients of this information will depend upon the nature of the client assignment being conducted or contemplated.

We are likely to disclose your personal information to the following countries:

(a) Australia;

(b) New Zealand;

(c) United States;

(d) United Kingdom;

(e) member states of the European Union;

(f) Canada

(g) India;

(h) other states in which we or you have business activities.

In providing the Services we may use overseas recipients or IT providers and their subcontractors (including of software, platforms and infrastructure) such as of data storage facilities or other IT infrastructure. In such cases, we may own or control or subscribe (eg under contracts) to such overseas IT providers. We take reasonable steps to ensure that personal information is used by overseas IT providers securely and in accordance with this Privacy Policy. However, countries outside Australia do not always have the same or comparable levels of privacy protection obligations as Australia. Further, with the use of internet connections for information transport and storage it is not always practicable to know where personal information may be held.

By submitting your personal information to us, you expressly agree and consent to the disclosure, use, transfer, storing, processing, destruction or de-identification of your personal information outside of Australia in the circumstances as noted above and with potential issues to be contractually and otherwise managed by us as outlined above. Accordingly, as regards the protection of personal information abroad, by accepting this Privacy Policy, you consent to exclusion of us from accountability under Australian Privacy Principle 8.1. Consequences of this include that in some cases an overseas IT provider or recipient may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles and that we or you may not be able to seek redress against them in the overseas country or jurisdiction.

15. Third Party Use of Personal Information

We are not responsible for the practices or content of other services or sites that are operated by third parties but which are linked to our Services. If we are linked to third party services or sites, it does not necessarily constitute sponsorship, endorsement or approval by the Services of the content, policies or practices of those services or sites. If you leave our Services via such a link, you should check the privacy policy of the third party site.

We may use third parties to manage the Services and activities from time to time, including, but not limited to, promotions and statistical analysis. These parties may have access to and store the personal information of users of the Services. Similarly, we may contract with third parties to handle requests for information submitted to us.

16. Disclosure or Sale

Unless and until you opt-out, you consent and request for us to provide to you targeted marketing about our services and promotional offers and to use and disclose your personal information for provision of information by our contractors and others. Except as specified in this Privacy Policy, we will not sell your personal information.

17. Data Retention and Deletion

We store your personal information for as long as you maintain an account and for as long as any regulation require after the account is closed. On expiry of that period we may remove your personal information from our databases and may request that our business partners remove your personal information from their databases. When we delete any information, it will be deleted from the active database, but may remain in our archives. However, once we disclose your personal information to third parties, we may not be able to access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. We retain anonymised data indefinitely.

18. Business Transfer

If the ownership changes of all or a substantial part of our business, or individual business units, your personal information (including your profile with the Services) may be transferred to the new owner so the service or the transferred part of it can continue operations. In any such transfer of information, your personal information would remain subject to this Privacy Policy at the time of the transfer and then to the privacy policy of the new owner.

19. 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. You also have the right to contact the relevant authority in the country in which you are based.

20. Privacy Policy Continuity

This Privacy Policy may change, so we encourage you to check it from time to time. If we develop a revised privacy policy then on its publication on the Services it will supersede the one before it.

21. Objections and Complaints about Our Privacy Practices

You have a right to object to our use of your personal data. For any complaint about our privacy practices, please provide details to the Privacy and Data Protection Officer, whose contact details are in paragraph 22. We will then respond.

22. Contact Details

For any questions regarding the above Privacy Policy please contact or if you have any questions concerning this Privacy Policy or if you have any questions or concerns about our access, use, or disclosure of your personal information, please contact:

Privacy and Data Protection Officer

Hullabaloo (B2B) Solutions Pty Ltd

Web: hullabaloosolutions.com.au

Phone: (+61 2) 9220 1727

Email: services@hullabloosolutions.com.au

Last updated: 01 May 2024