Privacy Policy

What does Prozile do?

How does this Privacy Notice apply to me?

• visitors to our Platform ("Platform Visitors");
• individuals, representatives of individuals, or companies that sign up to use our Prozile Services via a paid plan ("Paid Plan Users") or free plan ("Free Plan Users"), together our "Prozile Users";
• individuals that sign up to subscribe to and/or follow User Profiles ("Subscribers");
• individuals that visit and interact with User Profiles ("Profile Visitors");
• developers that sign up to our Developer Portal in order to build functionality that interacts with the Prozile Services (“Prozile Developers”); and
• individuals who respond to our surveys, marketing materials or participate in trade promotions or competitions that we may run from time to time.

What personal information do we collect?

• Information you provide voluntarily
  When you sign up to become a Prozile User, a Subscriber, use or interact with our Prozile Services or staff, visit our Platform, visit a User Profile, sign up to our Developer Portal, respond to a survey or participate in a trade promotion we may ask you to provide personal information voluntarily. For example, if you are a Free Plan User we will ask you to provide your email address, name, username, hashed password, vertical (industry to which your account relates) and marketing preferences. If you are a Paid Plan User we will also ask for your full name, billing email address, billing address and payment method in order to facilitate billing. If you are a Subscriber, we will ask you to provide your email address or SMS number.
  
  
  
  To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails or SMS we may send you or completing our Data Request Form.
  
  
  
  You may also provide us with your personal data when you submit queries or make a report to us (such as an Intellectual Property Report or Counter Notice). For example, we may ask you to provide your name and email address so that we can respond to your queries. If you are making an Intellectual Property Report or Counter Notice, we ask you to provide your name, address, email address, phone number and details regarding the intellectual property rights concerned.
  
  
  If you are a Profile Visitor, a User might request that you provide your email address, mobile number, date of birth or age, or other personal information in order to access elements of a User Profile (such as locked content). We may use the results of such access (i.e. successful or unsuccessful access attempts) to produce aggregated statistics for our own internal purposes and to improve the Prozile Services.
  
  
  You may also provide personal information voluntarily if you respond to our surveys, marketing materials, or through your participation in trade promotions and competitions we may run from time to time.
  
  
  
• Information that we collect automatically
  When you visit our Platform, use our Prozile Services, interact with a User Profile, respond to a survey or participate in a trade promotion we collect certain information automatically from your device. In some countries, including countries in the European Economic Area and UK, this information may be considered personal information under applicable data protection laws.
  
  Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), time zone, usage data, diagnostic data and other technical information. We may also collect information about how your device has interacted with our Platform, Prozile Service or User Profiles, including the pages accessed and links clicked.
  
  Collecting this information enables us to better understand you, where you come from, and what content is of interest to you. We use this information for our internal analytics purposes, to improve the quality and relevance of our Platform and Prozile Services, to provide hints and tips to our Prozile Users and to make recommendations of Prozile Profiles you might be interested in viewing.
  
  Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “How do we use cookies and similar tracking technology” below.
  
  Further, we may undertake automatic scanning of User Profiles and links to determine whether mandatory or default sensitive content warnings should be applied and presented to Profile Visitors who wish to access the relevant User Profile or linked content, and to determine if any content should be removed or any User Profiles should be suspended in line with our Community Standards and/or Terms of Service. Where a User changes their User Profile, we will also notify relevant Subscribers to that User Profile that updates have been made.
  
  
  
• Information that we obtain from third party sources
  From time to time, we may receive personal information about you from third party sources (including from service providers that help us run marketing campaigns or competitions and our partners who help us provide our Prozile Services). In all cases, we will only receive such data where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
  
  
  
• Children’s data
  Our services are not intended for use by children under the age of 18 (the “Age Limit”). If you are under the Age Limit, please do not use the Prozile Services and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to erase or destroy any personal information that may have been collected or stored by us about that individual.

Why do we collect your personal information?

• To provide and deliver the Prozile Services and to assess, maintain and improve the performance and functionality of the Prozile Services.
• To ensure the Prozile Services are relevant to you and your device, to notify you about changes to the Prozile Services, and to deliver targeted and/or localised content based on your user data, location and preferences.
• For consumer research and to allow you to participate in surveys or interactive features of the Prozile Services when you choose to do so.
• To provide customer support and to process and respond to a request, complaint or Intellectual Property Report or Counter Notice that you may have made.
• To monitor the usage of the Prozile Services and to detect, prevent and address technical issues.
• To process payments for Paid Plan Users.
• To conduct business planning, reporting, and forecasting.
• To deliver promotional materials, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted out of receiving such information.
• For the administration of our business including for fulfilling and exercising our obligations and rights, exercising or defending legal claims, to comply with our legal obligations and law enforcement requests, and managing the relationship with you.
• To verify your identity and to detect fraud and potential fraud, including fraudulent payments and fraudulent use of the Prozile Services.
• To include Prozile User content as part of our advertising and marketing campaigns to promote Prozile.
• To inform our algorithms so we can deliver the most relevant recommendations to you, including of User Profiles that you may be interested in.

Legal basis for processing personal information

Who may we disclose your personal information to?

• to our group companies, third party services providers (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Platform or Prozile Services), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current group companies is available here and a list of our current service providers and partners is available here. We also facilitate third party payment providers and this is set out in more detail below;
• to the extent we introduce social media log-ins in the future, we may provide personal data to the relevant social media provider to facilitate such log-in;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and
• to any other person with your consent to the disclosure.

• Stripe (their privacy policy can be viewed at https://stripe.com/us/privacy);
• PayPal (their privacy policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full); and
• Square (their privacy policy can be viewed at https://squareup.com/au/en/legal/general/privacy).

Disclosure of personal information to other countries

How do we use cookies and similar tracking technology?

How long do we retain your personal information?

How do we secure your personal information?

What are your rights in relation to personal information?

• If you wish to access, correct or update your personal information, you can do so at any time by completing our Data Request Form.

• To request deletion of your personal information. You can do so at any time by completing our Data Request Form.
• To object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by completing our Data Request Form.
• To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you or completing our Data Request Form.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here and the UK here.)

Complaints

Changes to This Privacy Notice

Contact Us

• By email using: [email protected]

Supplemental Information for California Residents

1. Collection and Use of Personal Information

• Identifiers such as name, alias, postal address, online identifier (e.g. cookies) and other similar identifiers;
• Personal records such as payment information;
• Characteristics such as age, gender and other demographic data;
• Customer Accounts / Commercial information such as the User Profile, records of products or services purchased, obtained, or considered;
• Online usage information such as Internet and other network activity information, such as, but not limited to, browsing history, search history and information on interactions with the Prozile Services;
  Geolocation data such as country and zip code;
• Sensory information such as recordings of customer service calls; and
• Inferences derived from personal information such as purchase preferences, interests and characteristics.
  
  
  There may be additional information that we collect that meets the definition of personal information under California law but is not reflected in a category, in which case we will treat it as personal information as required under California law, but will not include it when we are required to describe our practices by category of personal information.

• Directly from you. For example, when you create an account, make a purchase, browse our Platform, or use the Prozile Services.
• Directly and indirectly from activity on the Platform and/or using the Prozile Services.
• Social networks (to the extent we introduce social media log-ins in the future).
• Service Providers who provide services on our behalf such as those used to fulfill orders, process your payments and requests, verify your information, monitor activity on the Platform and/or using the Prozile Services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, administer and send mobile messages, serve ads on this and other services, and provide consulting services.

2. Categories of Personal Information Disclosed

We may disclose the following categories of personal information to service providers for a business purpose, or, at your direction, with third parties such as sponsors of promotions, sweepstakes, or contests. We have disclosed the following:

Category of Personal Information Disclosed for a Business Purpose

• Identifiers;
• Personal records;
• Characteristics;
• Customer Accounts / Commercial information;
• Online usage information;
• Geolocation data;
• Sensory information; and
• Inferences derived from personal information.

• Service Providers
• Group companies
• Governmental authorities and agencies

We do not sell personal information and we do not believe that our sharing of information would qualify as a sale under California law.

For the avoidance of doubt, we also do not sell personal information of individuals under 16 years of age.

3. California Privacy Rights

(a) Right to Know

You have the right to request that we disclose to you the following information about personal information we collect from you:

• categories of personal information collected;
• categories of sources of personal information collected;
• the business or commercial purpose for collecting or selling personal information;
• the categories of third parties with whom we share personal information; and
• the specific pieces of personal information we have collected about you over the past 12 months.

(b) Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions permitted by law.

(c) Right to Opt-Out of Sale of Personal Information

As mentioned above, we do not sell personal information and we do not believe that our sharing of information would qualify as a sale under California law. Nonetheless, if you are a California resident who has purchased products or services from us, you may submit a request to record your preference to opt out by emailing us at [email protected].

(d) Right to Non-Discrimination

You have the right to not be treated in a discriminatory manner for exercising your privacy rights. We do not use the fact that you have exercised or requested to exercise any privacy rights for any purpose other than facilitating a response to your request.

4. Exercising Your California Privacy Rights

To exercise your rights, you can contact us:

• By email at [email protected]

Once we receive your request, we are required to verify that you are the person that is the subject of the request. This verification process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you will be asked to provide your name, email address, and request details. A confirmation email will be sent to the email address you provide to begin the process to verify your identity. If we cannot verify your identity, we will not be able to respond to your request.

You may designate an authorized agent to exercise any of the above privacy rights on your behalf, subject to the agent request requirements under California law.

Please note, for your safety and security, we will require authorized agents to provide proof of consent and designation of the authorized agent for the purpose of making the request, and will require authorized agents to provide information necessary to verify the identity of the individual who is the subject of the request. We may also require that an individual verify his/her own identity directly with us before we respond to an authorized agent's request.

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

5. Do Not Track

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn't an industry standard for recognizing or honoring DNT signals, we do not respond to them at this time.

6. California’s Shine the Light law

We do not share personal information with third parties for their direct marketing purposes absent your consent as defined by California Civil Code Section 1798.83 (“Shine the Light law”). To opt-out of future sharing with third parties for their direct marking purposes, contact us at [email protected]. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

7. Changes

We reserve the right to change this Supplemental Information for California Residents from time to time. Changes shall become effective on the date they are posted.

Prozile Group Companies

Prozile International Holdings Pty Ltd

Prozile, Inc.