PRIVACY POLICY

PRIVACY POLICY of Salestrekker Trading Pty Ltd (ABN 19 659 282 827)

Salestrekker Trading Pty Ltd (“we”, “us”, “our”, “Salestrekker”) respects and protects the privacy of individuals. We are committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other equivalent privacy and data protection laws and regulations as applicable.

This Privacy Policy outlines our practices with respect to collection, handling, use and disclosure of personal information, including sensitive information, and applies to your use of our services, products, website https://salestrekker.com/ , subscriptions, mobile applications, social media, online services, off-line services, in-person interactions and communications with you.

OUR ROLE AS A PLATFORM PROVIDER

We provide the Salestrekker customer relationship management platform and associated tools, including our Client Portal, to mortgage and finance brokers, advisers and other businesses (Users).

Users use our platform to collect, store and manage personal information about their own customers, including loan applicants, guarantors and other individuals named in an application (Clients). Users collect that information from Clients, enter it on our platform or invite Clients to enter it through the Client Portal, and decide how it is used. Users are responsible for complying with their own privacy obligations, including telling their Clients how their information will be handled and obtaining any consents required.

We hold and process Client information on behalf of, and on the instructions of, Users. We do not use Client information for our own marketing. We use it only to provide, maintain, secure and improve our platform and services for Users and to comply with the law. If you are a Client and have a question about information a User holds about you on our platform, please contact the User in the first instance. We will assist the User to respond to you, and you may also contact us directly using the details in the ‘Contact us’ section below.

This Privacy Policy applies to personal information we handle in that capacity, as well as to personal information we collect about Users, prospective customers, website visitors, suppliers and job applicants.

WHAT PERSONAL INFORMATION WE COLLECT

We collect, hold, use and share personal information to facilitate the supply of goods and provision of services which we offer. This enables us to identify and interact with individuals that we are dealing with, distinguish those individuals from others, keep appropriate records, analyse the market and demand for the goods we offer and customise our offering according to your preferences and interests. At all times we try to limit the collection of personal information only to the information we reasonably need for the particular function or activity we are carrying out.

This will ordinarily involve the collection of the following personal information from you:

  • Your name and contact details, such as residential and postal addresses, email address, mobile and/or phone number, social media handle;
  • Date of birth;
  • Payment and billing information (as necessary to set up direct debit or process payments)
  • Account information, such as account login credentials, usernames and passwords, password hints and similar security information;
  • Employment details, including your job position, educational and professional background and qualifications;
  • Your photo and video recordings;
  • Browsing history;
  • Product preferences and interests;
  • IP address and technical information (such as operating system, browser information);
  • Information about your device, computer or network, referring domain and out link, search terms and pages visited on our website, date and time of access and browsing;
  • Geolocation if it is enabled on your device;
  • Comments, feedback and other information you provide to us and any interactions with us.

Information we hold about Clients on behalf of Users

If you are a Client of a User, the personal information held about you on our platform will depend on what the User collects from you but will ordinarily include:

  • identity information and copies of identity documents, such as your driver’s licence, passport or Medicare card;
  • contact details, date of birth, residency and citizenship status and marital status;
  • employment and income details;
  • details of your assets, liabilities and living expenses and other financial information;
  • bank and account statements and other supporting documents;
  • credit reports and other credit-related information obtained with your consent;
  • details of your dependants (see ‘Children’s privacy’ below);
  • details of the loan or other finance applied for, the lender’s response and the progress of your application;
  • recordings and transcripts of your meetings with a User (where you have consented to the recording), and file notes the User dictates about you or your application; and
  • notes, communications and documents recorded by the User about you and your application.

Users do not ordinarily collect sensitive information (such as health information) about Clients through our platform. If sensitive information is included in documents a User uploads, we handle it only on the User’s instructions and in accordance with this Privacy Policy.

If you apply for a job vacancy with us, we will collect and use the following information, including sensitive information:

  • Contact details (eg name, address, telephone number or personal email address);
  • Date of birth;
  • Copies of driver’s licence, passports or other photo ID;
  • Employment history (eg job application, employment references or secondary employment);
  • Education history (eg professional background and qualifications);
  • Right to work information and any visa details;
  • Details of any criminal convictions;
  • Security clearance details if necessary for your position;
  • Bank account details;
  • Tax File Number;
  • Superannuation details;
  • Family and emergency contact information;
  • Health information and medical history, including Medicare details;
  • Racial or ethnic origin;
  • Professional association memberships

We will not use government related identifiers as our identifiers of an individual, except where the Privacy Act permits.

HOW WE COLLECT PERSONAL INFORMATION

1. You provide it to us.

The main way we collect personal information about you is when you give it to us. We collect your personal information directly from you when you:

  • interact with us over the phone, in person or online;
  • subscribe to our services;
  • create an online account on our website;
  • use our Client Portal or other online tools at the invitation of a User
  • purchase our products or services;
  • participate in surveys or questionnaires;
  • attend our promotional event;
  • subscribe to our mailing list;
  • apply for a position with us as an employee, contractor or volunteer;
  • lodge a complaint with us;
  • provide your feedback or interact with us in some other manner.

2. We collect it using IT resources.

We will also collect your personal information when you access our website, mobile application, social media, emails, online promotions and advertisements or browse for our products, register and use your online account with us. We will use web analytics, cookies or similar technology, such as pixels, ad tags and tracking technologies. The collection of information will occur automatically and collected information will include:

  • Computer, device, IP address and technical information to identify you and log your use, browser type and version, operating system and other software installed on your device;
  • Usage data, features and settings you used, URL stream data, purchase information and history;
  • Location information, geolocation;
  • Information recorded on our surveillance cameras if you are on or around our premises or facilities.

3. We receive it from third parties.

We may receive or collect your personal information from third parties, such as our distributors, affiliates, IT service providers, advertising and marketing agents, data providers, third party websites and applications, such as social media platforms and networks, or through publicly available resources such as Google and other search engines. Information that we may receive include:

  • Your contact and personal identification information;
  • Job title, employment and education history;
  • Information about the products and website content which you have accessed, browsed or enquired about, your preferences, product choice, purchase history, location, device and other technical information.

4. We receive it from Users.

If you are a Client of a User, most of the personal information we hold about you is entered on our platform by the User, or uploaded by the User from documents you have given them. The User, not Salestrekker, decides what information to collect from you and is responsible for telling you how it will be handled.

USE OF COOKIES

We use cookies and similar technologies, such as pixels, ad tags and tracking technologies, web beacons and resettable device identifiers on our website https://salestrekker.com/

What are cookies?

Cookies are small data files that contain an alphanumeric identifier. They are stored directly on your device when you browse and use websites and online services. The identifier in a cookie helps us manage and report on your interaction with our websites, services and products.

Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. A pixel is a tiny image that may be found within webpages and emails. We use pixels to learn more about your interactions with the web or email content, including access and use to ads and links. Pixels also enable us and third parties to place cookies on your browser.

Similar technologies are other tracking technologies, such as mobile advertising IDs and ad tags used for similar purposes as cookies described above.

What do we use them for?

We use cookies and other similar types of technologies for various reasons, such as keeping count of your visits to our websites, dates and times of visits and your current IP address; authenticating your login information and making it easy to access our services by remembering you when you return; enhancing the use of our services; monitoring or managing multiple usage of our website on your browser; collecting information about websites that redirected or referred you to our website; improving website performance, monitoring visitor traffic and activity on our websites; delivering and customising our marketing or advertising; analysing your use of our website, your browsing preferences; collecting and report on statistical information; security reasons, support and fraud prevention.

What types of cookies do we use?

We use essential cookies, analytical/performance cookies, functionality cookies which originate from third party service providers and other types of cookies.

How can you manage cookies?

You can set your browser not to accept cookies and use the settings on your browser to remove cookies from your browser and to refuse the setting of all or some cookies. Many popular browsers provide the ability to clear browser storage, commonly in the settings or preferences area.

Declining cookies may limit the functionality of the websites and availability of certain features as it will impair the effectiveness of web beacons associated with those cookies. You may not be able to access all or parts of our websites if you choose not to accept cookies or if you use your browser settings to block all cookies.

ONLINE ACTIVITY

Analytics. Our website uses Google analytics and other analytics service to help us better understand visitor traffic, so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.

Direct marketing. We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Australian Spam Act 2003 (Cth).

You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe' set out in the relevant communication and/or contacting us using the details set out in the “Contact us” section below. In addition, we may also use your personal information or disclose your personal information to third parties for the purposes of advertising, including online behavioural advertising, website personalisation, and to provide targeted or retargeted advertising content to you (including through third party websites).

PURPOSES OF COLLECTION AND USE OF PERSONAL INFORMATION

The primary purpose of our collection of personal information is to facilitate our work as a provider of “Salestrekker” customer relationship management platform and associated services, including the storage and processing of Client information on behalf of Users, and the management of our business relationships with distributors, customers and suppliers.

We collect and use your data so that we can:

  • provide our platform and associated services to Users, including storing, processing, analysing and transmitting Client information on Users’ instructions (for example, to prepare and submit loan applications to lenders and to generate the calculations, notes, audit results and documents described under ‘Artificial Intelligence and Automated Decision-Making’ below);
  • facilitate the creation of and manage your account with us, including registration on our website/mobile application;
  • supply, provide, maintain and improve our products, services, website/mobile application/social media and other information about us and our products;
  • send you emails about special offers about our products, related products and services we think you might be interested in;
  • promote our products, services, website and social media;
  • develop or conduct a research on development of new products and services;
  • customise and personalise your experience, preferences and interests when you access our website or mobile application, advertising and other content about us and our products;
  • contact you and provide information that you have requested or agreed to receive or may be interested in receiving;
  • alert you to the latest developments in the industry and to notify you of new products;
  • fulfill your requests for products and services, such as functionality of existing products, launching new products, distributing electronic newsletters and enabling you to participate in surveys and public forums;
  • analyse, maintain and improve performance, effectiveness, security, and safety of our products and website;
  • communicate and manage our relationship with you, including addressing any service and administrative issues;
  • respond to your enquiries, service requests, questions on products, website, services, promotions and events we may organise;
  • manage claims and provide product support and service information;
  • analyse data about the use of and preferences about products and products features;
  • assess your application for employment with us;
  • make use of your information consistent with the context in which the information was collected or with your consent for other internal business purposes in compliance with applicable laws and regulations.

In general, we will keep and use the information we collect from individuals to supply our products, communicate, fulfil our contractual and warranty obligations and to provide information about our products, meet our legal obligations as an employer and comply with legal requirements. We will also use the information for internal administrative purposes, marketing and research and for the payment and collection of accounts.

In all cases where personal information relates to a business transaction, we may keep the information also for legal purposes (for example, evidence of information or advice we have given) and for tax purposes.

STORAGE AND PROTECTION OF PERSONAL INFORMATION

We may retain personal information we collect and keep in hard copy and/or electronically in our database. Information will be retained, backed up and may be stored via “cloud”–based technology or on a hard drive. Our platform and the personal information held on it are hosted by our cloud service provider in data centres located in Australia.

We will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure.

With regard to information kept electronically, we securely store your personal information on our cloud servers and use up-to-date virus software and prevention technology, password security and firewalls for our computer systems and websites. We implement IT and administrative internal policies and protocols and keep our IT service providers accountable.

With regard to information stored in hard copies, we keep your information safe by using physical measures, including barriers, locks, doors and security alarms at the premises where our business is located and putting in place company policies relating to behavior and security.

We take measures to restrict access to only personnel who need that personal information to effectively provide services to you.

We regularly assess the risk of misuse, interference, loss of and unauthorised access to personal information we hold. We take measures to address those risks by tracking and keeping records of access, changes to and deletion of personal information, and ensuring that personal information is only accessed when it is needed. We conduct regular internal and external audits to assess whether we have adequately complied with or implemented these measures.

RETENTION OF PERSONAL INFORMATION

We will keep your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and will not keep your personal information for longer than we need to. In most cases, this means that we will only retain your personal information for the duration of your relationship with us unless we are required to retain your personal information to comply with applicable laws, for example record-keeping obligations.

Once we no longer need to or are required to retain your personal information, we will destroy it by securely erasing all personal information held digitally or in hard copies. Client information held on our platform on behalf of a User is retained in accordance with our agreement with that User and any legal requirements that apply to the User or to us, and is securely deleted or de-identified when no longer required.

DATA BREACHES

If we become aware of a data breach involving personal information we hold, we will act promptly to contain the breach, assess the risk of harm to affected individuals and take reasonable steps to mitigate that harm.

Where the breach involves Client information we hold on behalf of a User, we will notify the User as soon as practicable so that the User can meet its own obligations, and we will cooperate with the User in responding to the breach.

We will notify the Office of the Australian Information Commissioner and affected individuals where the Privacy Act requires us to do so.

ACCOUNTABILITY

It is the responsibility of all our employees to comply with privacy laws and this Privacy Policy. This Privacy Policy is made available to all current staff and new staff on induction. Periodic training is also provided.

In addition, where commercially and legally practicable, we require external contractors to comply with privacy laws, the Privacy Act and our Privacy Policy.

DISCLOSURE TO THIRD PARTIES

We will disclose your personal information to persons and organisations external to Salestrekker if our dealings with you would reasonably require us to do so and where you would reasonably expect us to do so.

Disclosure to service providers

We use a number of service providers to whom we disclose personal information. These include providers that host our website servers and our platform, manage our IT systems and database, and manage our human resources information, and the artificial intelligence service providers described under ‘Artificial Intelligence and Automated Decision-Making’ below. We may also disclose your information to IT marketing and advertising agencies in order to tailor the content of our promotions and emails to your needs and interests.

To protect the personal information we disclose we:

  • require a service provider to enter into a contract with us which requires them to only use or disclose the information for the purposes of the contract and to be compliant with the Privacy Act;
  • include specific privacy compliance requirements in the contract, where necessary.

Disclosure on the instructions of Users

If you are a Client of a User, we disclose your personal information to the User and, on the User’s instructions, to the lenders, aggregators, insurers, valuers and other parties involved in your application or transaction. Those organisations handle your information in accordance with their own privacy policies.

Disclosure to our distributors

If you have enquired about our products, we may refer your personal information to our distributor to assist in providing information as to the availability and suitability of our products for your needs.

Links to third party websites

Our website and social media accounts may contain links to websites operated by third parties. If you access a third party website through our website/social media account, personal information may be collected by that third party website. We make no representations or warranties in relation to the privacy practices of any third party provider or website and we are not responsible for the privacy policies or the content of any third party provider or website. Third party providers and websites are responsible for informing you about their own privacy practices and we encourage you to read their privacy policies.

Disclosure of personal information overseas

Our platform and the personal information held on it are hosted in Australia.

Your personal information may be processed in and accessed from Serbia where some of our affiliates and the personnel who support and develop our platform are located.

We do not send personal information to artificial intelligence service providers outside Australia (see the ‘Artificial Intelligence and Automated Decision-Making’ section below).

We take measures, including through contracts, to protect your personal information wherever it is located in a manner consistent with the standards of protection required under applicable privacy and data protection laws.

Google Analytics collects web traffic information when you visit our website. Google stores such information across multiple countries.

When you use social network services such as Facebook and LinkedIn to communicate with us or to find our products and services, the social network provider and its partners may collect and hold your personal information overseas.

Disclosure to subcontractors

We may engage external contractors to:

  • clean our premises;
  • conduct clerical, mail-out, marketing and other tasks; and/or
  • provide temporary staff.

The use of such external contractors means that they may have access to the personal information stored in the database, or seen in our offices. We will, where practicable, require such contractors to agree to comply with the Privacy Act.

Disclosure of sensitive information

We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect or if you agree, for example, to handle a complaint or assess your employment application.

ANONYMITY

You do not have to provide us with your personal information. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our products and services or otherwise interact with you.

It is impracticable for us to allow distributors, customers and suppliers to remain anonymous. For professional, legal and confidentiality reasons, we need to know the identity of the people we are dealing with at all times.

If you are browsing our website, you may choose not to accept cookies and use settings to remove cookies from your browser. In this case, some features on our website may not function or be available and your use of our website will be limited as a result.

ARTIFICIAL INTELLIGENCE AND AUTOMATED DECISION-MAKING

Our platform includes tools that use computer programs, including artificial intelligence (AI) and rules-based automation, to help Users do their work. This section explains how those tools use personal information and the kinds of decisions they are involved in.

What our AI tools do

Our AI-based tools assist Users by:

  • Analysing loan application information to create loan commentary and notes;
  • Auditing loan application information to ensure improved compliance with relevant credit regulations;
  • Translating text to improve communication between Users and their Clients;
  • Analysing lender credit policy to provide Users with improved lender product insights;
  • Analysing systems, processes, events and other information stored in Salestrekker that is used for business planning and decision making;
  • Extracting information from documents provided by Clients and populating loan application information in application forms to reduce reliance on the manual data entry tasks.
  • Transcribing recordings of meetings with Clients and voice notes dictated by Users into file notes. Recordings are made by Users and not by us. Where a recording captures a conversation with a Client or anyone else, the User must obtain the consent of all participants before recording starts. Recordings, transcripts and file notes are held on behalf of the User and are processed only within our hosting environment in Australia.

What our rules-based tools do

We also provide rules-based automation and calculators that do not use AI, including tools that calculate borrowing capacity and serviceability, check eligibility against lender criteria and identify lender products that may match a Client’s requirements.

Decisions and the personal information used

The outputs of these tools are suggestions, calculations, summaries and draft documents for the User. Decisions that could significantly affect you, such as what credit assistance or recommendation a User gives you, and whether a lender approves your application and on what terms, are made by the User or the lender and not by our platform. We do not use computer programs to make any such decision without human involvement. Users are required to review the output of our AI tools before relying on it or sending it to a lender.

However, the serviceability, eligibility and lender-matching calculations produced by our rules-based tools and the audit results, commentary and summaries produced by our AI tools, may substantially and directly contribute to a User’s assessment of your application and to the recommendation the User makes to you.

The kinds of personal information used in the operation of these tools are the Client information described under ‘What personal information we collect’ above, including identity, contact, employment, income, asset, liability, expense and dependant information, documents provided in support of an application, lender responses, recordings, transcripts and User’s file notes about the application.

AI service providers

We use third-party service providers to operate some of our AI tools. We do not process personal information using AI tools located outside Australia. Where an AI service provider is located overseas, the information sent to it has names and other identifying details removed so that it does not identify any individual.

Where identifying details cannot be removed, for example where AI is used to read documents that a Client has provided, the personal information is processed only by our cloud service provider within our Australian hosting environment.

Our contracts with AI service providers require that information we send them is used only to provide the service to us, is not used to train AI models or for any other purpose, and is not retained once the service has been provided.

We may add further tools of these kinds from time to time and will update this section if the kinds of decisions or personal information involved change.

We might utilise AI generated guide and how-to videos, however we do not deploy interactive AI technologies that personify humans via voice or video.

CHILDREN’S PRIVACY

Our products and services are not directed at children. We do not knowingly collect personal information directly from anyone under the age of 18.

When a loan application is prepared on our platform, the applicant, or the User acting for them, may provide limited information about the applicant’s dependants, including children (their name and date of birth) because lenders require it to assess the application. We hold this information on behalf of the User, use it only for that purpose and protect it in the same way as all other personal information we hold.

QUALITY OF PERSONAL INFORMATION

We will take reasonable steps to ensure that the personal information we collect is accurate, up-to-date and complete.

Where you have an online account with us, as a user of the account you can directly access and review your account information and make corrections or updates at any time. Keeping such information up to date is your responsibility. You may also close your account at any time directly by contacting our customer support.

Our staff is responsible to record personal information accurately when it is provided by you directly to them. Where necessary, we confirm the accuracy of information we collect from a third party or a public source, update or add new personal information to existing records, audit our contact lists for accuracy.

We review the accuracy of personal information before we use or disclose it. We will periodically give individuals the opportunity to check certain details (particularly contact details) within the information we hold.

We encourage individuals to let us know if they become aware that the personal information we hold is inaccurate and we will respond promptly to any request for correction of data and will act quickly to correct any data that is found to be inaccurate.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You have the right to ask for access to the personal information we hold about you or ask that we correct that personal information. You can ask for access or correction by contacting us and we will respond within 30 days.

If you are a Client of a User, the User controls the information held about you on our platform. Please contact the User in the first instance; we will assist the User to respond to your request. You may also contact us directly.

If you make a request, we must give you access to your personal information, and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to. Please note that the access right is qualified. In some circumstances it may be lawful for us to refuse to give access to some or all the information we hold.

We may ask you provide addition information in order to verify your identity before we give you access to your information or correct it.

If we decide to refuse to give you access to, or correct, your personal information, we will notify you in writing and provide the reasons for our decision. If we refuse to correct your personal information, you can request that we attach a statement which sets out what information you believe to be incorrect and why.

If we have disclosed the incorrect information to third parties, you can ask us to notify them about the correction. We must do so unless there is a valid reason not to.

HOW TO MAKE A COMPLAINT

For complaints about how we handle, process or manage your personal information, please contact us:

  • by phone on +61 2 9037 7350; or
  • by mail to The Privacy Officer, Salestrekker Trading Pty Ltd, Suite 2101A, Level 21 (Tower 1), 520 Oxford Street Bondi Junction NSW 2022, Australia;

We may require proof of your identity and full details of your request before we can process your complaint.

We will acknowledge receipt of your complaint and will respond to it within 30 days.

Once we receive a complaint from you, we will determine what (if any) action we should take to resolve the complaint. We may need to seek further information from you if we are to respond in a meaningful way.

We encourage you to contact us with any concern regarding our use and handling of your personal information and we will use our best efforts to resolve such complaint to your satisfaction. It will not always be possible to resolve a complaint to everyone’s satisfaction. If you are not satisfied with our response you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/privacy/.

CONTACT US

For enquiries about our approach to privacy, requests for access to personal information we hold and process, and complaints, please contact our Privacy Officer by:

  • phone on +61 2 9037 7350; or
  • mail to The Privacy Officer, Salestrekker Trading Pty Ltd, Suite 2101A, Level 21 (Tower 1), 520 Oxford Street Bondi Junction NSW 2022, Australia.

NEW ZEALAND ADDENDUM

This addendum applies if you are in New Zealand or your personal information is collected in New Zealand. We do not direct our platform or services to New Zealand. However, some Users are located in New Zealand or hold information about individuals in New Zealand on our platform, and this addendum explains how we handle that information having regard to the Privacy Act 2020 (NZ), in addition to this Privacy Policy.

Information collected from Users

Most of the personal information we hold about Clients in New Zealand is collected from Users rather than from the Client directly. Where we collect your personal information from a User, we take reasonable steps (unless the User has already done so) to make you aware of the following:

  • your personal information has been collected by the User and is held on our platform by Salestrekker Trading Pty Ltd, Suite 2101A, Level 21 (Tower 1), 520 Oxford Street, Bondi Junction NSW 2022, Australia;
  • we hold it so that the User can prepare, assess and submit your application and manage its relationship with you, and so that we can provide our platform and services to the User;
  • it may be disclosed to your User, to lenders and other parties involved in your application on the User’s instructions, and to the service providers described in this Privacy Policy;
  • it is held in Australia and may be accessed from Serbia as described under ‘Disclosure of personal information overseas’; and
  • you have the right to request access to, and correction of, your personal information, as described under ‘Accessing and correcting your personal information’.

Complaints and breaches

If you are not satisfied with our response to a complaint, you may complain to the Office of the Privacy Commissioner at https://www.privacy.org.nz.

We will notify the Office of the Privacy Commissioner and affected individuals of a notifiable privacy breach where the Privacy Act 2020 (NZ) requires us to do so.

EUROPEAN REGION ADDENDUM – PROCESSING NOTICE

This addendum is set out for the purpose of our compliance with the European Data Protection Law and applies to you if you ordinarily live in Europe. This Addendum is supplementary to our Privacy Policy

For the purpose of this Notice:

Europe means the European Union, the European Economic Area and/or their member states, Switzerland and the United Kingdom.

Data means personal data that is subject to the protection of European Data Protection Laws as defined in such laws.

European Data Protection Law means data protection laws applicable in Europe, including:

(i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation);

(ii) EU Directive 95/46/EC;

(iii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector;

(iv) applicable national/member state implementations of the above;

(v) GDPR as it forms parts of the United Kingdom domestic law by virtue of Section 3 of the European Union (Withdrawal) Act 2018; and

(vi) Swiss Federal Data Protection Act and its Ordinance;

and as amended, replaced or superseded from time to time in each case.

DATA CONTROLLER

Salestrekker is the data controller of your Data as defined in the European Data Protection Law.

However, if you purchase our products and services from our authorised distributors, that distributor is the controller of your Data and not us and this Privacy Policy does not apply.

If you are a Client of a User, the User is the controller of your Data and we process it on the User’s behalf as a processor. The User’s privacy notice applies to you, and this Privacy Policy describes how we handle your Data in that capacity.

PROTECTING YOUR DATA OUTSIDE EUROPE

Salestrekker is an Australian company, and when you share your Data with us, we may transfer that Data for processing by our affiliates and services providers, in Australia and Serbia. When doing so, we apply the same protections described in this Privacy Notice and in compliance with the European Data Protection Law, and making sure appropriate safeguards are in place.

Where necessary, our data processors may share Data outside of Europe. When doing so, they comply with the European Data Protection Law, making sure appropriate safeguards are in place.

Where Data is transferred between our group of companies or to our service providers, this is done using the framework set out in the European Data Protection Law, such as standard contractual clauses that have been approved by the European Commission as well as supplementary measures necessary to ensure an adequate level of protection for your Data.

Please contact us for more information.

OUR LEGAL BASIS FOR PROCESSING YOUR DATA

To fulfil the purposes set out in the ‘Purposes of collection and use of personal information’ section above, we rely on certain legal grounds when collecting, processing and sharing your Data:

  • to enter into a contract and perform our contractual obligations to you;
  • to protect and give effect to our legitimate interests, provided those interests are not overridden by your interests or rights. Our legitimate interests include: offering employment to you; securing our website, social media and platform; responding to your requests received through the website; enforcing our legal terms; analysing how our website is being used; effectiveness of our marketing and promotional campaigns; improvement of our product offerings, website performance and user experience; monitoring the demand for our products; provide ongoing support to our customers; research, development and improvement of our products and services; protecting our intellectual and other intangible property, interests and rights; protecting us and others against error, fraud, damage and harmful or illegal activity; offering tailored content to you; complying with our legal obligations under laws outside Europe and responding to legal requests from governmental and law enforcement agencies; operating and expanding our business;
  • for compliance with applicable laws and regulation and our legal obligations;
  • as permitted by your consent, for example, where you opt-in to receive direct marketing communications about our products, or where you consent to the use of cookies on our website.

We may rely on more than one legal ground depending on the purpose for which we collect and process your Data. We only use Data for the purposes for which we collected it unless we believe that we need to use that Data for another reason that is compatible with the original purpose or as applicable law allows.

YOUR DATA PROTECTION RIGHTS AS DATA SUBJECT

Under the European Data Protection Law, you have rights including:

  • Right of access. You have the right to ask us for copies of your Data.
  • Right to rectification. You have the right to ask us to rectify your Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Right to erasure. You have the right to ask us to erase your Data in certain circumstances.
  • Right to restriction of processing. You have the right to ask us to restrict the processing of your Data in certain circumstances.
  • Right to object to processing. You have the right to object to the processing of your Data in certain circumstances.
  • Right to data portability. You have the right to ask that we transfer the Data you gave us to another organisation, or to you, in certain circumstances.
  • Right to withdraw consent. When we use consent as our lawful basis you have the right to withdraw your consent.

You do not usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a Data protection rights request, please contact us using the ‘Contact us’ section above.

HOW TO COMPLAIN

If you have any concerns about our use of your Data, you can make a complaint to us using the contact details at the ‘Contact us’ section above.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may access information on how to lodge your complaint on the website of The European Data Protection Supervisor at https://edps.europa.eu/ or to the Information Commissioner’s Office as applicable in your country in Europe.

Last updated: 9 October 2026