The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access the Product or parts of the Product.

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Pension Pal.

• Country refers to: Australia

• Device means any device that can access the Product such as a computer, a mobile phone or a digital tablet.

• Personal Data is any information that relates to an identified or identifiable individual.

• Product refers to Pension Pal, the software program provided by the Company.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Product, or to assist the Company in analysing how the Product is used.

• Usage Data refers to data collected automatically, either generated by the use of the Product, or from the Product infrastructure itself (for example, the duration of a page or screen view visit).

• You means the individual accessing or using the Product, or the company, or other legal entity on behalf of which such an individual is accessing or using the Product, as applicable.

• When You use the Product, We may collect information from You through systems that automatically track usage of the Product. This includes, but is not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the pages or screen views of the Product that You visit, the time and date of Your visit, the time spent on those pages or screen views, and other diagnostic data.

• In addition, We may collect information that You volunteer to Us (such as information that You provide during a sign up process or at other times while using the Product).

• In order to access some specific features of the Product, You may be required to provide some Personal Information. During this process, We collect some of Your Personal Information. We will not collect information that identifies You personally, except when You specifically volunteer that information to Us using specific features of the Product. These specific Product features might include, but are not limited to:

* making purchases

• In addition to any Personal Information that You are required to provide in order to access these additional Product features, You may be required to provide more specific information. For example, in order to make purchases, You may need to provide credit card information, billing information and postal addresses.

The Company may use Personal Data for the following purposes:

• To provide and maintain the Product, including to monitor the usage of the Product.

• To manage Your Account: to manage Your registration as a user of the Product. The Personal Data You provide can give You access to different functionalities of the Product that are available to You as a registered user.

• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Product.

• To contact You: To contact You by email, telephone call, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications. Contact can be regarding updates, or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless You have opted not to receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale, or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about users of the Product is among the assets transferred.

• For marketing and advertising: We may use Your information to market and advertise to You, including both direct and indirect marketing and advertising and including marketing and advertising about products that may interest You based on Your personal preferences or demographics.

• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Product, services, and your experience.

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We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of the Product, or to contact You.

• With third parties for Advertising: We may allow third parties to advertise on the Product. These third parties may use cookies in connection with their advertisements (see the "Cookies" clause in this Privacy Policy).

• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

• With Your consent: We may disclose Your personal information for any other purpose only with Your consent.

• Cookies are small files stored on Your computer or mobile device which collect information about Your browsing behaviour.

• Cookies do not access information which is stored on Your Device.

• Cookies enable us to tailor our configurations to Your needs and preferences, in order to improve Your user experience.

• Most internet browsers accept cookies automatically, although You are able to change Your browser settings to control cookies, including whether or not You accept them, and how to remove them. You may also be able to set Your browser to advise You if You receive a cookie, or to block or delete cookies. However, if You do this, You may be prevented from taking full advantage of the Product.

• Third parties who advertise on the Product may use cookies in order to learn about Your browsing preferences and to present relevant advertisements to You. Cookies enable these advertisers to recognise Your computer each time You are sent an advertisement. It allows them to compile information about where You saw their advertisement, and to better target their advertisements. You may notice these targeted advertisements on the Product or on other websites that You visit. We do not control the cookies that may be used by these third party advertisers. This Privacy Policy only addresses Our use of cookies and does not address the use of cookies by any of these third party advertisers. For information about the use of cookies by these third party advertisers you will need to consult their privacy policies or cookies policies respectively.

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Product, or We are legally obligated to retain this data for longer time periods.

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

The Product may give You the ability to delete certain information about You from within the Product.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Product

• Protect the personal safety of Users of the Product or the public

• Protect against legal liability

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

The Product does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

The Product may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on the Product, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, You can contact us:

• By email: info@pensionpal.au

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