Retention Track - Privacy Policy

The Retention Track website and platform (collectively referred to as the Platformthroughout this document) are owned and operated by Retention Track Pty Ltd ABN 28 682 975 373 of Unit 15 / 5 Murphy Street, O’Connor (Retention Track). In this document, ‘we,’ ‘us’ and ‘our’ refers to Retention Track.

The Platform is a workflow management tool intended to assist businesses in managing their claims for retention payments.

This Privacy Policy sets out our policy for protecting the privacy of your personal information provided to us, or otherwise collected by us, offline or online, in connection with the Platform.

By accessing or using the Platform you consent to us using your personal information as set out in this Privacy Policy. If you access the Platform through a subscription, you also agree to be bound by the Access Terms available at www.retentiontrack.com/access-terms.

• name;
• images;
• contact details;
• age and/or date of birth;
• payment information, including banking details and other information necessary to process purchases or subscriptions;
• preferences and opinions (eg, preferences about communications with us);
• browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information about visitors’ access and use of the Platform, including through the use of internet cookies, communication with the Platform, browser type, operating system and the domain name of the visitor’s internet service provider; and
• additional personal information that individuals provide to us, directly or indirectly, including through use of the Platform and associated social media platforms and/or accounts.

We may collect these types of personal information directly from you or:

• from your authorised representatives;
• from other third parties, such as those listed under ‘Disclosure of personal information to third parties’;
• from records of activities and communications, including use of our website and IT resources;
• from publicly available sources and databases; and
• by creating new information such as analysis, commentary, reports and reviews.

If you provide personal information to us about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us, based on this Privacy Policy.

We collect, hold, use and disclose personal information to manage our services and operations, employ and manage staff and better understand and interact with the individuals we deal with. These purposes include:

• to enable you to access and use the Platform, associated applications and associated social media platforms;
• to contact and communicate with you, for example, in relation to a customer service enquiry, a complaint or your use of the Platform;
• to verify the identity of individuals and the information we collect;
• for internal records management and administrative purposes;
• for analytics, market research and business development, including to operate and improve the Platform, associated applications and associated social media platforms;
• to manage safety and security in relation to our sites, systems and assets;
• to comply with our legal obligations and resolve any disputes that we may have.

We may disclose personal information to third parties, including:

• third party service providers, IT service providers, data storage, web-hosting and server providers, maintenance or problem-solving providers and professional advisors;
• our related entities;
• your and our representatives;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred; and
• courts, tribunals, regulatory authorities and law enforcement officers, in accordance with applicable law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights.

We may disclose personal information to:

• our third party service providers for the purposes of providing the Platform and any services provided through the Platform; and
• third parties to collect and process data, such as Google Analytics, to locations outside Australia.

We will ensure that any such disclosure overseas is made only where our third party service providers are required to comply with how we handle personal information under this policy or, in the case of Google Analytics, in accordance with Google’s privacy policy, available at www.google.com/policies/privacy/partners/.

Subject to certain limitations and restrictions (e.g. depending on circumstances such as where you reside) you may have the right to exercise certain rights in relation to your personal information, including the following:

• The right of access to personal information we hold about you.
• The right to know what personal information we collect about you, and how it is used and shared.
• The right of rectification to update your personal information if it is inaccurate or incomplete.
• The right to erasure/deletion (‘right to be forgotten’) of your personal information.
• The right to object to our use and handling of your personal information.
• The right to restrict our handling of your personal information.
• The right of data portability for transfer of your personal information to another party.
• The right to withdraw consent you have previously provided to our handling of personal information.

Please note that in order to verify your request or the applicability of any of these rights to your circumstances, we may ask you for further information and to verify your identity before responding to such requests.

Where a request relating to any of the above rights has been made and information has been shared with third parties, we will take all reasonable steps to notify third parties of the request.

If you have any questions about these privacy rights, or how to exercise them, please contact us using the contact details at the bottom of this Privacy Policy. We will confirm receipt of your request and provide information on how we intend to respond. Further, we will respond to your request in accordance with permitted or required timeframes set out in applicable laws.

Please contact us as set out in clause 16 below if you wish to make any of these requests.

These provisions apply if our use of your personal information is subject to the European General Data Protection Regulation (Regulation (EU) 2016/679) and its UK equivalent (the GDPR). We process your personal information as a controller for the purposes of the GDPR and for the following purposes:

Where processing your personal information is necessary for us to provide the Platform or for our legitimate interests

• We may process certain personal information about you in order to provide you with the Platform and any services we agree to provide you.
• We may process your personal information for the purposes of our legitimate interests, for example, in order to: enforce the terms of our website, analyse log data/user statistics to improve the Platform for all users, communicate with you about your access to the Platform, ensure that the Platform runs smoothly and to respond to any of your questions, feedback, claims or disputes.

We do not think that any of our data processing activities prejudice individuals in any way. However, you do have the right to object to us processing your personal information on this basis. Please refer to clause 7 for more details about exercising your rights.

Where you give us your consent to process your personal information

We will obtain your opt-in consent prior to sharing your personal information with third party applications and carrying out certain marketing activities.

As and when we introduce these particular processing activities, we will provide you with more information so that you can decide whether you want to opt-in.

You have the right to withdraw your consent to these activities. Please refer to clause 7 for more details about exercising your rights.

Where processing your personal information is necessary for our compliance with a legal obligation

In certain circumstances, we may disclose your personal information for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation or compulsory legal request).

International transfers

If you are based within the UK/EU we will only process and/or transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with the GDPR and the means of transfer provides adequate safeguards in relation to your personal information or where you have otherwise consented to the data transfer.

These provisions apply if our use of your personal information is subject to the California Consumer Privacy Act 2018 (the CCPA).

In the past 12 months, we have collected and disclosed (but not sold) personal information in the following categories (from the CCPA): identifiers; customer records; characteristics of protected classifications under California or federal law (e.g. race, religion, sexual orientation, gender, age); commercial information; biometric information; internet/electronic network activity information; geolocation data; audio, electronic, visual, thermal, olfactory or similar information; professional or employment-related information; education information; inferences drawn to create a profile.

You have the right not to be discriminated against for exercising your privacy rights under the CCPA.

We do not knowingly collect personal information from children under 16 through the Platform. If we become aware that a child under 16 has provided us with personal information in connection with the Platform, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact the Retention Track support team.

We implement a variety of security measures to maintain the safety of your personal information, including building security, access restrictions, network firewalls and contractual protections where our service providers store this information on our behalf. We hold information in hard copy and electronic form.

We use cookies. A cookie is a piece of information that allows our system to identify and interact more effectively with your browser. The cookie helps us to maintain the continuity of your browsing session and remember your details and preferences when you return. You can configure your web browser software to reject cookies however some parts of the Platform may not have full functionality in that case.

We may use web beacons on the Platform from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

The Platform may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on the Platform. If we decide to change our Privacy Policy, we will update the Privacy Policy modification date below.

This policy was last modified on 4 April 2025.

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details set out at the bottom of this Privacy Policy. We will confirm receipt of your complaint and, where appropriate, open an investigation into your complaint.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result of that complaint as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you have the right to lodge a complaint with the relevant privacy data protection authority in your jurisdiction. For reference, we set out below the identity of some of the relevant authorities:

• If you reside in the EU and you are unsure of who the data protection authority is in your country, please refer to this link: https://edpb.europa.eu/about-edpb/board/members_en
• If you reside in Australia, your data protection authority is the Office of the Australian Information Commissioner (OAIC): https://www.oaic.gov.au/
• If you reside in the United Kingdom, your data protection authority is the Information Commissioner’s Office (ICO): https://ico.org.uk/
• If you reside in the United States, data protection regulations are developing, and privacy is handled on a state-by-state basis – in these instances, refer to your state’s Attorney General’s website. The US Department of Commerce also has a dedicated contact to liaison with EU data protection authorities in the event of enquiries or referrals: https://www.privacyshield.gov/article?id=DPA-Liaison-at-Department-of-Commerce

For any questions or notices, please contact us at:

Email: privacy@retentiontrack.com

Mailing Address:
Retentions Track
Unit 15, 5 Murphy Street
O’Connor 6163
Western Australia