Privacy Policy

Last modified:25 October 2020

1.                
Preliminary

1.1              
General

LUPARG Pty Ltd ACN 625 479
530 (“we”, “us”, “our”) are committed to protecting your privacy. We
understand that users of our services and software products are concerned about
their privacy and the confidentiality and security of any data that is
provided.

This Privacy Policy sets out
how we collect, use, store and disclose (Process) all personal data,
whether received through on of our websites (Website), our software
products and solutions (Software) or through our general interactions
with you.

We will only Process personal
data in accordance with this Privacy Policy, and the laws applicable in the
jurisdiction in which we are Processing that data. If there is any
inconsistency between this Privacy Policy and an applicable law, the applicable
law will prevail to the extent of any inconsistency.

1.2              
Contact               

Our contact details are:

www.continusys.com

Telephone: +617 3184 4441

Post: LUPARG PTY LTD

Lobby 1, Level 2

76 Skyring Terrace

Newstead QLD 4006

Australia

Privacy Issues Email: support@continusys.com

2.                
Nature of Personal Data

In this policy when we talk
about "personal data" we are referring to any information which can,
directly or indirectly, be used to identify you. For example, names, addresses,
personal identification numbers, location data and other online identifiers
(such as email addresses).

2.1Anonymised Data

Whenever you visit our
Website, our servers automatically record information for statistical purposes
about your usage of the Website such as:

(a)                
the type of browser used;

(b)               
the referring URL;

(c)                
the IP address;

(d)               
the number and type of pages viewed;

(e)                
the date and time of visits; and

(f)                 
the exit URL.

This information we collect
about you is not personal data and, in any event, remains anonymous. We do not
link the anonymous information to any other personal data and we will not link
a record of your usage of our Website to you personally.

2.2Personal Data

When using our Software we
ask you for certain personal data to provide you with the products or services
that you request from us. This may include, for example, when you create a user
account in order to enable you to access our Software services. We may also
collect personal data when you have made an enquiry or request from us, or when
you otherwise interact with us generally (such as by telephone, in person or by
email).

The nature of the personal
data that we collect includes:

(a)                
your contact details (full name, email,
telephone number and delivery and billing address);

(b)               
the name of your employer or place of business;

(c)                
login and account information; and

(d)               
banking information (if this is being provided
by your personally and not by an employer or organisation).

3.                 
Cookies and other
tracking technologies

To improve your experience on
our Website, we may use cookies and other tracking technologies, such as pixel
tags, web beacons, device IDs, or advertising IDs.

You may refuse the use of cookies
by selecting the appropriate settings on your browser, however please note that
if you do this, you may not be able to use the full functionality of our
Website.

Our Website may use Google
Analytics, a service which transmits website traffic data to Google servers in
the United States. Google Analytics does not identify individual users or
associate your IP address with any other data held by Google. We use reports
provided by Google Analytics to help us understand website traffic and web page
usage.

You can customise or opt out
of Google Analytics for display advertising using the Ads Settings for your
Google account.

Our Website uses cookies and
other tracking technologies to support Google Analytics for:

(a)                
Google Marketing Platform integrations;

(b)               
Demographic and Interest Reporting;

(c)                
Display Advertising including Remarketing and
Google Display Network Impression Reporting to advertise our services online;

(d)               
Optimizing and personalizing ad services based
on your past visits to our Website; and

(e)                
Reporting the use of ad services and
interactions with ad impressions and how they are related to visits to our
Website.

Cookies and other tracking
technologies may also be used to support analytics by other third parties.

4.                
Purposes of collecting
, holding, using and disclosing Personal Data

4.1              
Collect from you only

Where it is reasonable or
practical to do so we will only collect personal data about you from you
directly.

If we collect personal data
which we have not sought or requested about you, and if we determine we are
legally permitted to collect that information, we will deal with that
information in accordance with the terms of this Privacy Policy. In all other
circumstances, we will destroy or de-identify the relevant personal data as
soon as practicable, where it is lawful and reasonable to do so.

4.2              
Purposes of collecting Personal Data

We will only Process your
personal data for the purposes of:

(a)                
enabling us to provide you with our Software or
any other products or services that you have requested;

(b)               
creating user accounts within our Software;

(c)                
providing technical support or responding to
your general queries and enquires;

(d)               
our internal research and statistical purposes;

(e)                
marketing our Software and related products and
services to you;

(f)                 
enabling us to forward to you other information
or material which we genuinely believe may be of interest to you;

(g)               
verifying and authenticating the payments to us, or enabling a payment processor to process payments that you make to
us;

(h)               
enabling us to defend or prosecute a legal
proceeding, or to comply with the order of any court or regulatory authority; and

(i)                 
any other purpose specified in an agreement that
we enter into with you.

If we Process your personal
data for any other purpose other than that specified above, such use will
relate to the above purposes, and will be within what you would reasonably
expect us to use that personal data for at the time of collection.

We do not sell
personal data to any third parties or provide personal data to third parties
for any business purpose (unless that business purpose has been specifically
referred to in this Privacy Policy).

4.3Direct marketing

From time to time we may use
your personal data to provide you with current information about special offers
you may find of interest, changes to our organisation, or new products or
services being offered by us or any company we are associated with.

You consent to
us using your personal data to contact you on an ongoing basis for the purpose
of us marketing our Software and related products and services to you, howsoever
such advertising may occur.

4.4Withdrawing Consent

You may withdraw your consent
to our use of your personal data at any time by contacting us using the contact
information contained in this Privacy Policy. However, this may affect or limit
your ability to access our Website or the services available through our
Software.

If you do not
wish to receive marketing information, you may at any time decline to receive
such information. We will take all reasonable steps to meet your request at the
earliest possible opportunity.

4.5 Holding of Personal Data

We will endeavour to use industry
best practice processes and take all reasonable steps to protect personal data
that we hold from:

(a)misuse, interference and loss; and

(b)unauthorized access, modification or disclosure.

In the unlikely event that
there is a serious data breach that is likely to result in a risk to your
rights and freedoms, we will without undue delay notify the appropriate
supervisory authority in your jurisdiction. Where there is a high risk that a
serious data breach will impact upon your rights and freedoms, we will also
notify you of that breach.

4.6International Data Transfers

Typically, all personal data
that you provide to us will be processed within Australia.

However, in order to provide customer support, perform back office functions, deliver
Software products and services to you, perform fraud prevention tasks we may
need to allow our staff or third party service providers (who may be located in
a location other than your country of residence) access to your personal data
and, in particular, your name, delivery address and billing information.

We will always ensure that
the recipient of your personal data offers an adequate level of protection, for
instance by entering into the appropriate back-to-back agreements and, if
required, containing the standard contractual clauses for the transfer of personal
data as approved by the European Commission. Such transfers are necessary for
us to perform our obligations and provide our products and services to you.

Despite the
above, by providing your personal data you are explicitly consenting to the
international transfer and Processing of such data in accordance with this
Privacy Policy, in full and informed knowledge of the risks associated with
such transfers and Processing.

4.7Unsolicited information

You may withdraw your consent
to the international transfer of your personal data at any time by contacting
us using the contact information contained in this Privacy Policy. However,
this may affect or limit our ability to provide you with our Software and
associated products or services.

5.                 
Destruction of Personal Data

We will keep your personal
data only for as long as we need it to fulfill our contractual obligations to
you, for our legitimate business purposes or as required by applicable law. We
will take reasonable steps to erase any personal data that we hold about you
where:

(a)we no longer need the personal data for the purposes for which it was
collected and we are not otherwise entitled to retain such data; and

(b)we are not required or obligated by law, regulation or court order to
retain the information.

If certain information has
been provided to third parties in accordance with this Privacy Policy,
retention of that information will be subject to the policies of the relevant
third party.

6.                
Access, correction and portability

6.1Access to Personal Data

We will provide you with access upon request to the personal
data held by us in relation to you except to the extent that:

(a)giving access would be unlawful; or

(b)denying access is required or authorized by or under a relevant law,
regulation or court order.

To request access to your personal
data, please contact us using the details provided in this Privacy Policy.

Following your request, we
will contact you within one (1) month from the date of receipt of your request
and provide you with the personal data requested, unless we have determined
that some reason or obligation exists requiring us to withhold access to the personal
data.

6.2             
Third party disclosure

We do not sell your personal
data to any third parties. Unless specifically referred to in this Privacy
Policy, we also do not disclose your personal data to any third parties for
other business purposes.

However, notwithstanding the
above, you may at any time request that we provide confirmation that your personal
data has not been sold to a third party, or to request details of any third
party to which information has been sold or disclosed for business purposes.

We may in the event of a sale
or a restructure of your business disclose your personal data as part of
facilitating any transaction or restructure that we are undertaking that
involved a third party.

6.3Data portability

Insofar as it does not
adversely affect the rights and freedoms of others and where you have
communicated a request to us:

(a)                
where we have employed an automated means to Process
your personal data, we will
provide you with a copy of
such personal data in a structured, commonly used and machine-readable format;
and

(b)               
after receiving your
request, where technically feasible, we will transmit your personal data
directly to another data holder.

6.4Commercially sensitive information

Where providing you access to
your personal data would reveal commercially sensitive information, we are
unable to give you access to that information. However, we will provide you
with the reasoning behind our determination.

6.5Use of intermediaries

Where we cannot directly
provide you with access to your personal data we may, if it is reasonable,
engage the services of an intermediary to do so.

6.6Correction and erasure of Personal Data

It is your responsibility to
ensure that the information you provide to us is accurate, and to update your personal
data as necessary.

If for any reason you are
unable to correct any personal data held by us through your user account in our
Software, please contact us using the details provided in this Privacy Policy.

If after receiving your
request we choose not to correct your information, we will notify you within
one month of the reason of our refusal and the mechanisms available to you to
object to our refusal.

If you wish to have your personal
data erased, please communicate your request to us using the contact
information provided above. The only circumstances in which we will not take
reasonable steps to erase your personal data are where we need to keep it in
accordance with another provision of this Privacy Policy, an applicable law, or
the order of a court or regulatory authority.

If we correct or erase personal
data about you that we previously disclosed to a third party, we will take
reasonable steps to notify the third party of the correction or erasure and to
request that they do the same.

6.7Refusal to correct or erase

If at any time we refuse or
deny you access to your personal data, or refuse to correct or erase your personal
data, we will provide you with reasons we are unable to satisfy your request.

6.8Restriction of processing

You may request that we limit
or restrict the manner in which we Process  your personal data, in which case
we will only Process your personal data: with your consent; for the
establishment, exercise or defence of legal claims against us; or for the
protection of the rights of another person.

6.9Costs

Access to, erasure and
rectification of your personal data, including any communications related
thereto, will generally be provided free of charge.

Where your requests are
manifestly unfounded or excessive in nature (particularly due to
repetitiveness) we may charge you a reasonable fee for providing the
information or communication, or taking the action requested. Where your
requests are manifestly unfounded or excessive in nature we may also refuse
your request.

6.10Specific objection rights

If it becomes necessary for
us to Process your personal data without your consent for reasons of:

(a)performing a task in the public interest;

(b)the exercise of an official authority that has been vested in us; or

(c)where it is in our legitimate interests or the legitimate interests of a
third party to do so;

you will have the right to
object to such use.

We will notify you of such
instances. If you object to our use of your personal data we will refrain from
using your personal data unless compelling legitimate grounds exist for us to
use that personal data, or for the establishment, exercise or defence of legal
claims.

If we have collected your personal
data in accordance with this Privacy Policy and elect to use such personal data
for the purposes of direct marketing (to which you consent), you have the right
to object at any time to such use. Upon receiving an objection we will, as soon
as is reasonably practical, cease using your personal data for the purposes of
direct marketing.

7.                 
Complaints

7.1Making a complaint

If you believe that we have
used or disclosed your personal data in a manner which is contrary to this
Privacy Policy or that otherwise breaches an applicable law, then you should email
us at
support@continusys.com

You also have the right to
lodge a complaint with the relevant supervisory authority in your jurisdiction.
If you are unsure who your relevant supervisory authority may be, please
contact us so that we may provide you with assistance.

7.2Our response

Within 30 days of receipt of
your complaint we will notify you in writing as to what action we propose to
take in relation to your complaint and will provide you with details of what
further action you can take if you are not satisfied with our response.

8.                
Variations

We reserve the right to vary
this Policy from time to time. Any variations made will be updated on our
Website. It is your responsibility to check our Policy periodically to ensure
you are aware of any changes made to it.

9.                
Further information

For any further information
about this policy please contact us be
support@continusys.com


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