Privacy Policy

Privacy Policy

Effective: 25 May 2018
(view previous versions: 23/01/2016)

Our Privacy Policy explains how Ozecom collects, uses, and discloses information about you. The
terms “Ozecom,” “we,” “us,” and “our” include Ozecom Pty Ltd and our affiliates (Kudos Knowledge
Pty Ltd, Startech Solution Pty Ltd and Imaginative Technology Solutions Pty Ltd. We use the terms
“member,” “you,” and “your” to mean any person using our Platform or attending related events,
including any organization or person using the Platform on an organization’s behalf. This Privacy
Policy applies to the processing of information about members and other individuals that we collect
when you use our “Platform,” which means any website, application, or services we offer, or when you
communicate with us. For information about choices that we offer under this policy, please see “Your
Choices” below. This Privacy Policy does not apply to the information that you may provide to third
parties, such as members, and others with whom you may share information about yourself. For more
information about the scope of our Privacy Policy, please see Section 4.5.

To make this Privacy Policy easier to understand, we have provided summaries in these gray boxes.
These summaries are not part of the official policy. Even though we have provided summaries, it is
important for you to read the entire policy carefully.

1. Collection of Information
2. Use of Information
3. Sharing of Information
4. Additional Details
5. Your Choices
6. Data Rights
7. Contact Us

1. Collection Of Information

Summary: We collect information about you when you:

1. Create an account;
2. Use the Platform;
3. Attend an event;
4. Visit our website; and
5. Communicate with us.

We also collect information, such as usage statistics, by using cookies, server logs, and similar
technologies.

If you elect to use certain features, we also collect information through other sources, such as social
media services, invitations, and imported contacts.

1.1 Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information that you
provide when you create an account, choose interests or groups, fill out a form, or communicate with
us. The types of information that we may collect include your name, username, password, email
address, postal address, phone number, payment method data, photos, choices of interests and
groups, and any other information that you choose to provide. Information about your gender and
interests is optional. Your choice of groups is optional, but we are required to process this information
in order to administer your account, and to indicate that you are a member of the groups that you join.
See Section 2 to learn how we will use the information that you provide to personalize our
recommendations and other content to you.

On occasion, the information that you give us when you join a group may imply information about your
beliefs, political views, health conditions; or your sexual identity. This, and other kinds of sensitive
information, is given special protection.

1.2 Information We Collect Automatically When You Use the Platform

When you use our Platform, we automatically collect information about you, including:

1. Log Information: We collect log information about your use of the Platform, including the type
of browser that you use; the time, duration and frequency of your access; Platform pages
viewed; your IP address; and the page you visited before visiting our Platform.
2. Device Information: We collect information about the computer or mobile device that you use
to access our Platform, including the hardware model, operating system and version, unique
device identifiers, and mobile network information.
3. Location Information: We may collect information about the location of your device each time
you use our Platform based on your consent to the collection of this information. For further
information see Section 5.2.
4. Information Collected by Cookies and Other Tracking Technologies: We and our service
providers collect information using various technologies, including cookies and pixel tags
(which are also called clear GIFs, web beacons, or pixels). Cookies are small data files stored
on your hard drive or in device memory that help us improve our Platform and your
experience, and track usage of our Platform. Pixel tags are electronic images that may be
used in our Platform or emails, and track usage of our Platform and effectiveness of
communications. You can learn more about the types of cookies we and our service providers
use by reading our Cookie Policy.
5. Other Information: With your permission, we may collect other information from your device,
such as photos from your camera roll, contacts of individuals you wish to find or connect with,
or calendar information you want to manage via the Platform.

1.3 Information We Collect From Other Sources

We may collect information about you from other sources, such as through certain features on the
Platform you elect to use, but only where these third parties either have your consent or are otherwise
legally permitted or required to disclose your information to us. Examples include:

1. Social Media Services. If you register or log into your account through a third-party social
media service, we will have access to some of your third-party account information from that
service, such as your name and other information in that account, and used for purposes
such as improving your Ozecom recommendations. We may also have access to third-party
account information if you use the Platform feature to share a link.
2. Invitations. If another member sends you an invitation through our Platform, we may receive
certain personal information, such as your name, email address, or phone number. If you are
an invited guest, we will automatically send you an invitation to our Platform, and, if
unanswered, a one-time follow-up invitation. Ozecom stores this contact information only to
send these invitations and evaluate their success. You may unsubscribe from future
invitations using the instructions in those messages. You may also contact us at
privacyenq@ozecom.com to request that we remove this information from our database.
3. Member Content. We may receive information about you when you or another member
uploads photos or posts other content to the Platform. For further details about the rights over
this information available to individuals, see Section 6.
4. Information From Other Third-Party Sources. In order to provide you with more tailored
recommendations, we may obtain information about you from publicly and commercially
available sources and other third parties as permitted by law. For more information about the
data that we obtain from these providers, please contact us at privacyenq@ozecom.com.

2. Use Of Information

Summary: We use information about you to:

1. Operate, improve, promote, and protect Ozecom and our Platform;
2. Communicate with you; and
3. Personalize content.

2.1 Operating our Platform

We may use information about you for various purposes related to operating our Platform, including
to:
1. Provide, maintain, and improve our Platform, including to process transactions, develop new
products and services, and manage the performance of our Platform;
2. Display information about you, for instance, your list of interests, which will be visible on your
profile;
3. Personalize the Platform, for example, to suggest content in which we think you may be
interested (including content given special protection under EU law or that relates to sensitive
topics such as health, political opinions, religion, and sexual identity);
4. Allow you to share information about your use of the Platform through a third-party social
media service, if you connect your account through that service (which you can turn off at any
time) and to provide you with better recommendations;
5. Monitor and analyze trends, usage, and activities in connection with our Platform; and
6. Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to
protect the rights, property, or safety of Ozecom and others; to enforce compliance with our
policies; and to comply with applicable law and government requests.
7. Perform accounting and administrative tasks, and enforce or manage legal claims.

2.2 Communicating With You

We may use information about you for various purposes related to communicating with you, including
to:

1. Respond to your comments, questions, and requests, and provide customer service;
2. Communicate with you, in accordance with your account settings, about products, services,
and events offered by us and others, to provide news and information that we think will be of
interest to you, to conduct online surveys, to contact you about events on our Platform that
are being held near your location, and to otherwise communicate with you in accordance with
Section 2.3;
3. Notify you about communications of other members, in accordance with the communication
preferences that you indicate in your account; and
4. Send you technical notices, updates, security alerts and support, and administrative
messages.

2.3 Advertising And Other Uses

We may use information about you for various other purposes, including to:
1. Provide content, features, or sponsorships that match member profiles or interests;
2. Facilitate contests and other promotions;
3. Combine with information that we collect for the purposes described in this Privacy Policy;
and
4. Carry out any other purposes described to you at the time that we collected the information.

2.4 Legal Basis for Processing

Our legal basis for collecting and using the information described above will depend on the type of
information and the specific context in which we collect it.
1. We process information about you in order to provide our services in accordance with our
Terms of Service, for example to allow you to join groups and to allow us to send you
important service updates.

2. We also process information about you where it is in our legitimate interests to do so and not
overridden by your rights (for example, in some cases for direct marketing, fraud prevention,
network and information systems security, responding to your communications, the operation
of networks of groups by the network administrators, and improving our Platform).
3. Sometimes you provide us with sensitive information about you; for instance, the mere fact of
joining a certain group may indicate information about your health, religion, political views, or
sexual identity. Joining such groups, or posting information on the Platform about these topics
is entirely voluntarily and done with your explicit consent.
4. In some cases, we may also have a legal obligation to collect information about you, or may
otherwise need the information to protect your vital interests or those of another person.
5. We may also process information to comply with a legal requirement or to perform a contract.

3. Sharing Of Information

Summary: We do not share information about you in any way other than as described in this Privacy
Policy.

We may disclose information about you:
1. to members or social media services, subject to the choices you may make via the Platform;
2. to our third-party service providers who help us to operate or improve our Platform;and
3. to authorities to comply with legal obligations and to protect and defend our rights and
property.

We may also share de-identified or aggregated information.

3.1 Through Our Platform
We share some of the information that we collect by displaying it on our Platform according to your
member profile and account settings. Some information, such as user name, is always public. Some
information, such as interests, is public by default, but can be hidden on our Platform. Some
information, such as group memberships, will always be visible to other members of that Ozecom
group, and may be public, depending on the settings of that group. We recommend that you check
the group settings and what information will be available before joining the group to ensure that you
are happy with the information that is visible to others..

3.2 With Our Service Providers

We may use service providers in connection with operating and improving the Platform to assist with
certain functions, such as payment processing, email transmission, conducting surveys or contests,
data hosting, managing our ads, and some aspects of our technical and customer support. We take
measures to ensure that these service providers access, process, and store information about you
only for the purposes we authorize, subject to confidentiality obligations.

3.3 Following The Law And Protecting Ozecom

We may access, preserve, and disclose information about you to third parties, including the content of
messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation,
legal process, or audits. We may also disclose information about you if we believe that your actions
are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect
the rights, property, or safety of, or prevent fraud or abuse of, Ozecom or others.

3.4 Social Sharing And Other Tools

The Platform may offer social sharing features and other integrated tools which let you share actions
that you take on our Platform with third-party services, and vice versa. Such features let you share
information with your friends or the public, depending on the settings you have chosen with the
service. The third-party services' use of the information will be governed by the third-parties’ privacy
policies, and we do not control the third-parties’ use of the shared data. For more information about

the purpose and scope of data collection and processing in connection with social sharing features,
please review the privacy policies of the services that provide these features.

3.5 Other Situations

We may de-identify or aggregate information about you and share it freely, so that you can no longer
be identified. We may also share information about you with your consent or at your direction or
where we are legally entitled to do so.

4. Additional Details

Summary:
1. With your permission, we may allow others to use technologies that collect information about
you to provide analytic services, and to serve ads for Ozecom. You may be able to disable
the collection or use of this information.
2. We may transfer data to other countries and in this case we ensure appropriate safeguards
are employed.
3. We use commercially reasonable efforts to protect your personal information and have
implemented technical and organizational measures in line with industry best practices. We
cannot guarantee these controls will provide absolute security.
? This Privacy Policy is periodically updated, and does not apply to third parties.

4.1 Analytics and Advertising Services Provided by Others
With your permission, we may allow others to use cookies, web beacons, device identifiers, and other
technologies to collect information about your use of the Platform and other websites and online
services. See our Cookie Policy for details about these technologies and the information that they
collect, use, or share, including how you may be able to control or disable these services.

4.2 Transfer Of Information To Other Countries
Information about you may will be transferred to, and processed in, other than the country in which
you are resident. These countries may have data protection laws that are different to the laws of your
country and, in some cases, may not be as protective. We have taken appropriate safeguards to
require that your information will remain protected in accordance with this Privacy Policy.

4.3 Data Security
We store the personal information you provide and we employ technical and organizational measures
designed to appropriately protect your information that is under our control and that we process on
your behalf from unauthorized access collection, use, disclosure, copying, modification or disposal,
both during transmission and once we receive it. We store all information that you provide to us in
secure computer systems which can only be accessed by authorised officers. We use industry
standard encryption technologies when transferring and receiving data. All data is stored on dedicated
servers. We use firewalls designed to protect against intruders and test for network vulnerabilities.
However, no method of transmission over the internet or method of electronic storage is completely
secure

We train employees regarding our data privacy policies and procedures, and permit authorized
employees to access information on a need to know basis, as required for their role.

We take a number of steps to protect personal information from misuse, loss, unauthorised access,
modification or improper disclosure. This includes instructing staff who handle personal information to
respect the confidentiality of Customer’s personal information and the privacy of individuals.

Where you have a password, which enables you to use our services, you are responsible for keeping
this password complex, secure, and confidential. If you would like to update or change your

password, you may select the “Forgot your password?” link on the login page. You will be sent an
email that allows you to reset your password.

4.4 Data Retention

We retain certain information that we collect from you while you are a member of the Platform, and in
certain cases where you have deleted your account, for the following reasons:
1. So you can use our Platform;
2. So ensure that we do not communicate with you if you have asked us not to;
3. To provide you with a refund, if entitled;
4. To provide accurate accounting information to other members about the groups that they
organize or administer, and associated memberships;
5. To better understand the traffic to our Platform so that we can provide all members with the
best possible experience;
6. To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of
Service; and
7. To comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete
or anonymize it.

4.5 Policy Scope

This Privacy Policy does not apply to information that you provide to third parties, such as other
members, including group organizers and network administrators, and others with whom you may
share information about you. Our Platform may direct you to a third-party service, such as social
media services, or a portion of our Platform may be controlled by a third party (typically through the
use of a frame or pop-up window separate from other content on our Platform). Disclosure of
information to these third parties is subject to the relevant third party’s privacy policy. We are not
responsible for the third-party privacy policy or content, even if we link to those services from our
Platform or if we share information with these third parties.

Ozecom is a data controller. Members, including group organizers and network administrators, are
directly responsible for complying with all requirements of applicable EU privacy laws in connection
with the information that they obtain and process for the purposes of managing their contacts, or
organizing groups, or administering networks

4.6 Revisions To This Policy

We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by
publishing the most current version and revising the date at the top of this page. If we make any
material change to this policy, we will provide additional notice to you, such as by sending you an
email or displaying a prominent notice on our Platform.

5. Your Choices

Summary:
1. You can review and change information about you or deactivate your account in your account
settings, but we may retain certain information.
2. You can remove photo tags if you wish.
3. With your consent, we will use information about your location. You can deactivate this
feature at any time.
4. You have the right to opt out of receiving Ozecom’s promotional messages, but you may still
receive other non-promotional communications.

5.1 Your Choices: Account Information

You may update or correct your account information by editing your account settings or by sending a
request to privacyenq@ozecom.com as described in Section 6. You may deactivate your account by
editing your account settings or by sending an email to privacyenq@ozecom.com. You will also be
able to choose what information others see about you and who may contact you by using the Privacy
Settings section in your Account.

5.2 Your Choices: Location Information

When you first access the Platform, we will collect information about your location, which we use to
make better recommendations for groups and events in your area, and to improve our Platform. If you
do not want us to collect information about your location, then you can prevent this:
1. If using a mobile app, by changing the settings on your device.
2. If using our website, your location data will be obtained via a cookie. Please refer to our
Cookie Policy for additional information on how to manage our use of cookies.

Note that our Platform or its features may no longer function properly if you do.

Your mobile device settings may also give you the option to choose whether to allow us to view your
location on a continuous basis, when only using the app, or never. Allowing us to view your location
when you are not using the app allows us to provide you with recommendations on a regular basis.
Please refer to your device’s guide for additional information on how to adjust location services.

5.3 Your Choices: Promotional Communications

You can control messages that you receive from Ozecom, other members, and third parties by
selecting the unsubscribe link in the message that you receive, or by adjusting the communication
preferences in your account settings. We will also send you a link to these settings when you first sign
up and in subsequent messages. If you opt out, we may still send you non-promotional messages,
such as those about your account or our ongoing business relations.

5.4 Your Choices: Photo Tagging

You can tag photos of yourself and others. When a photo has been tagged it means that the name of
that person will appear alongside the photo, and the tagged photo will appear on the tagged
member’s group profile.

We will notify you when another member has tagged your account in a photo or when additional
comments are added to such photos. You can also report inappropriate content to Ozecom. Please
inform guests who are not members of this Privacy Policy and their rights regarding their personal
information should a photograph be posted on the Platform.

6. Data Rights

Summary:
1. You may have the right to exercise your data protection rights, including to request that
Ozecom deletes, amends, or provides you access to your information.
2. You have the right to opt out of receiving Ozecom’s promotional messages, but you may still
receive other communications.
3. You can complain to your local data protection authority about the use of your information.

We respond to all requests that we receive from individuals who wish to exercise their data protection
rights in accordance with applicable data protection laws. You can contact us by sending an email to
privacyenq@ozecom.com.

Rights that you may have, depending on the country in which you live, include:
1. Accessing, correcting, updating, or requesting deletion of your information.

2.Objecting to processing of your information, asking us to restrict processing of your
information, or requesting the portability of your information.
3. Opting out from receiving marketing communications that we send you at any time. You can
exercise this right by selecting the “unsubscribe” or “opt-out” link in the marketing emails we
send you. Additionally, you may update your email preferences by changing the settings in
your account.
4. Withdrawing your consent at any time if we have collected and processed your information
with your consent. Withdrawing your consent will not affect the lawfulness of any processing
that we conducted prior to your withdrawal, nor will it affect processing of your information
conducted in reliance on lawful processing grounds other than consent.
5. Complaining to a data protection authority about our collection and use of your information.
For more information, please contact your local data protection authority. Contact details for
data protection authorities in the European Union are available at
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

8. Contact Us

Summary:
If you have any questions, you can contact us at privacyenq@ozecom.com.

Under European data protection law, the controller of your information is Ozecom Pty Ltd.

If you have any questions or complaints about this Privacy Policy or how we use your information,
please contact privacyenq@ozecom.com.