PRIVACY POLICY

The purpose of this document ("Privacy Policy") is to inform you of how PEXX manages Personal Data (as defined below).

Please take a moment to read this Privacy Policy so that you know and understand the purposes for which, and the circumstances in which, we collect, use and disclose your Personal Data.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us, or may in future provide to us, in respect of your Personal Data, and those consents are additional to any rights which PEXX may have at law to collect, use or disclose your Personal Data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

PEXX may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends, information handling practices and/or any changes in legal or regulatory requirements. You can view the current version of this Privacy Policy on our website at https://pexx.com/privacy-policy. Please check back regularly for updated information on the handling of your Personal Data.

DEFINITIONS

Applicable Data Protection Laws means the Australian Privacy Act 1988 (Cth) and any applicable law related to the protection, privacy, security, collection, use or disclosure of data relating to identifiable individuals.

Personal Data means all data that falls within the definition of personal information, personal data, personally identifiable information, or similar language, under Applicable Data Protection Laws.

PEXX, we, us or our means PEXX Technology Pty Ltd (ABN 79 672 375 030).

Privacy Policy means this privacy policy.

Personal Data we Collect

first and middle name, last name; contact details such as telephone and or mobile number(s), residential address and email address; identity information such as government issued ID details (e.g. driver’s licence passport), date of birth, identity photo and video and security credentials; demographic information such as gender;

source of funds and source of wealth; records and details of communications and interactions with us and relevant to us including feedback, opinions, and messages you share through our website and online services; information about your use of our websites and services, including cookies, information about your domain name, IP addresses, device and browser information (including identifiers), subscription account details and membership details; disputes and investigations information, such as records of disputes, complaints, claims, investigations and their investigation and resolution; your payment related information, such as your bank account; in addition, for job candidates –information relating to assessing your suitability for the position, including experience, qualifications, work eligibility (e.g. visa, citizenship) and background checks (including referee checks and criminal record); in addition, for our personnel and vendor, contractor and service provider representatives – experience, qualifications, work eligibility (e.g. visa, citizenship), personnel records, due diligence and background checks (including referee checks and criminal record), and use of our IT resources; and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you.

Collection of Personal Data

when you submit forms (online or otherwise) relating to any of our products or services, or submit any online queries; when you enter into any agreement or provide other documentation or information in respect of your interactions with us; when you register for and/or use any of our services, including on websites owned or operated by us;

when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails; when you request that we contact you or request that you be included in an email or other mailing list; when you respond to our promotions, initiatives or to any request for additional Personal Data; when we receive references from business partners and third parties, for example, where you have been referred by them; when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events; when you are contacted by, and respond to, our marketing representatives and customer service officers; when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries, relevant authorities and other third parties such as those described in Clause 5; when it is publicly available, including through social media, online sources and public registers; by creating new Personal Data through analysis, review and interpretation of existing data; through cookies, web beacons and similar technologies as described in Clause 8; and/or when you submit your Personal Data to us for any other reason.
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Purposes for the Collection, Use and Disclosure of Personal Data

In general, we collect, store, use and disclose your Personal Data for the following purposes: to provide you with the products or services that you have requested;

to help us review, develop, improve, manage the delivery of and, to the extent this requires the use of Personal Data, enhance our products and services, including analysing customer behaviour and future customer needs, conducting market research, list processing and data analytics (including by requesting feedback from you or your participation in surveys); for authentication and verification purposes; to communicate with you and respond to your queries, requests and complaints; to handle disputes and conduct and facilitate investigations and proceedings; to protect and enforce our contractual and legal rights and obligations; to prevent, detect and investigate crime and misconduct, including fraud and money-laundering, and to analyse and manage other commercial risks; to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances); to maintain and update our records; to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures; to recruit, train and manage our workforce; to organise, facilitate, and administer roadshows, tours, promotional events, contests and/or competitions; to comply with any contractual terms and conditions to which PEXX is bound by; to commence, respond to, or act in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution); to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes; to match any Personal Data held which relates to you for any of the purposes listed herein;

to facilitate business asset and corporate transactions (which may extend to any merger, acquisition or asset sales), including any related transitional arrangements;

to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

other purposes which are permitted by applicable law; and/or purposes which are reasonably related to the aforesaid.

In addition, we may collect, store, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

If you have an account with us:

to process your application for the account and to maintain your account with us;

to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you; providing customer service and support (including but not limited to customer relationship management and processing and settlement of invoices and bills); administering and processing your requests including creating and maintaining profiles of our members in our system database for administrative purposes (including but not limited to tracking your use of the website);

personalising your experience on the website and conducting market research, understanding and analysing customer behaviour, location, preferences and demographics in order to improve and communicate our service offerings; if you use the website, sending you notifications and facilitating the provision of our services to you;

administering debt recovery and debt management; and/or for purposes which are reasonably related to the aforesaid.

If you are an employee, officer or owner of a vendor, contractor or other external service provider, or prospective vendor, prospective contractor, or other prospective external service provider of PEXX:

to conduct appropriate due diligence checks; to evaluate your organisation’s suitability as a vendor, contractor, and external service provider for PEXX and to conduct background checks on you; to create and maintain profiles of our vendors, contractors, and external service providers in our system databases; to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider; to process and facilitate payment of invoices and bills; to respond to emergencies; to communicate with you changes and development to our policies, terms and conditions and other administrative information;

for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance); to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and for purposes which are reasonably related to the aforesaid.

If you are a candidate for a position with PEXX:

to determine and evaluate your suitability for the position and to conduct background checks on you; to create and maintain profiles of our candidates in our system databases; to communicate with you in relation to the position you are a candidate for;

for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance); and for purposes which are reasonably related to the aforesaid.

If you hold a position working with PEXX, in addition to the items in (c) above:

to process and facilitate necessary actions and processes for the purposes of your work or engagement; to enroll you as our employee/worker and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards, and building access passes); for training and development;

to review your conduct and performance; to manage payroll and staff benefits;

to support you with tools, facilities, equipment and advice to enable you to perform your role; and for purposes which are reasonably related to the aforesaid.

Furthermore, where permitted under the Data Protection Laws, PEXX may also collect, use and disclose your Personal Data for the following additional purposes:

taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials; providing or marketing services and benefits to you, including promotions and reward programs; organising roadshows, tours, campaigns and promotional or events and administering contests and competitions; matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services; sending you details of services, services updates and rewards, either to our customers generally, or which we have identified may be of interest to you; conducting research, analysis, and development activities (including data analytics, surveys, product and service development and/or profiling), understanding and analysing customer behaviour, location, preferences and demographics for us to offer you our services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or purposes which are reasonably related to the aforesaid.

In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us using the contact details below.

Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days (unless a shorter period is required by applicable law) for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.

Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the services that you have requested or purchased from PEXX.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce or protect our legal rights, such as under a contract with you).

We are required to comply with Applicable Data Protection Laws in our handling of Personal Data and are also required or authorised to collect personal information under other laws.

Disclosure of Personal Data

Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or otherwise:

amongst PEXX and its related corporations or affiliates (including their respective staff);

vendors, third party service providers, agents and other organisations we have engaged to perform any of the functions in connection with any of the purposes listed above in this Privacy Policy; relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; amongst our subsidiaries, affiliates and related corporations (including their respective staff); contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; our corporate clients; any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

external banks, credit card companies, other financial institutions and their respective service providers; our professional advisers such as consultants, auditors, and lawyers;

in addition, for current, prospective and former staff and employees, officers and owners of a vendor, contractor or other external service provider – referees, background check providers, education/training providers and professional and trade associations; and/or any other party to whom you authorise us to disclose your Personal Data to.

Some of these parties may be located in different countries to you, including but not limited to Singapore, United Kingdom and United States of America.

We may share information about you in aggregate or anonymised form, for example, we may want to know how long the average reader spends on our website, or which pages or features get the most attention.

Storing and Protecting Your Personal Data

Keeping Your Personal Data Accurate and Up-To-Date

Use of Cookies, Web Beacons, and Similar Technologies

When you visit or interact with our sites, services, we or our authorised service providers may use cookies, web beacons, and other similar technologies for collecting and storing information as described further below.

The information collected by us or our authorised service providers may recognise a visitor as a unique user and may collect information such as how a visitor arrives at our sites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

The use of cookies, web beacons and similar technologies by us on our website has different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off our sites.

Our website and certain site features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits.

Third-Party Sites

Contacting Us – Complaints, Withdrawal of Consent, Access and Correction of your Personal Data

If you:

have any questions, feedback or complaints relating to your Personal Data, how we handle your Personal Data, or about this Privacy Policy; would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or

would like to obtain access and make correction to your Personal Data records, please contact us as follows:
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If you are seeking access to or correction of your Personal Data, please provide as much detail as you can about the Personal Data required, to help us retrieve it. We may need to verify your identity. In some cases, we may choose to provide your Personal Data even if we are not required to do so by law. If we do decline your request, we will usually need to tell you why (e.g. where a lawful exception applies).

We take your privacy complaints seriously. On receipt of a complaint, we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will respond to your complaint in a reasonable period of time (usually within 30 days).

If you refuse to provide your Personal Data or withdraw your consent to any or all use of your Personal Data, depending on the nature of your request and relationship with PEXX, PEXX may not be in a position to continue to provide its products, services or employment/work to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with PEXX, and your being in breach of your contractual obligations or undertakings. PEXX's legal rights and remedies in such event are expressly reserved.