Privacy

Effective date: 1 October 2023

Kuggar Pty Ltd ("we", "our") is a technology company in Australia (Australian Company Number: 165 118 561) that provides software applications within the payments industry. We deliver technology services to businesses that require payments integrations within their procurement workflows and platforms. We operate https://kugg.ar/ and https://virtual.cards/ websites, which provide business information to corporate organisations about the products and services we provide, and the associated software platform which provides the payments technology services. We respect your right to privacy and we are committed to safeguarding the privacy of our website visitors and customers. This notice sets out how we collect and treat your personal data. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and, to the extent applicable, the EU General Data Protection Regulation (GDPR). Types Of Data We Collect and Process We collect and process data to respond to requests for information from website visitors and to deliver technology services to our customers. Personal Data We will receive and store personal data you submit to our website, provided to us directly or given to us in other forms. You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support. Website Data When you come to our websites, we may collect certain information such as time/date of the visit, browser type, operating system, website visited immediately before coming to our site, unique device identifiers and other diagnostic metadata. This information is retained and used in an aggregated manner to analyse how people use our sites, such that we can improve our service. We may from time to time use cookies on our website. Our software also uses session cookies, activity cookies and similar tracking technologies to track the activity on our platform and hold certain information that enable us to manage access to our software. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies, but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites and may prevent you from using our software. How We Collect Your Personal Data We collect personal data from you in a variety of ways, including when you interact with us electronically or in person, when you access our websites and when we engage in business activities with you. By providing us with personal data, you consent to the supply of that information subject to the terms of this Privacy Notice. We may receive personal data from our customers or from third parties, for the processing that data in the course of providing our technology services. If we do, we will protect it as set out in this Privacy Notice. Without the collection and processing of this personal data by us, our customers would be unable to use our services for payments processing. How We Use Your Personal Data We may use personal data collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you. We will use personal information only for the purposes that you consent to. This may include to: ◾ Provide you with products and services during the usual course of our business activities ◾ Administer our business activities ◾ Manage, research and develop our products and services ◾ Provide you with information about our products and services ◾ Communicate with you by a variety of methods including, but not limited to, by telephone, email, sms or mail ◾ Investigate any complaints If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website. The use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy notice. If we do disclose your personal information to a third party, we will request that the third party protects it in accordance with this privacy notice. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. General Data Protection Regulation (GDPR) For The European Union (EU) We will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use. For data we collect directly, we process your personal data as a Processor and/or to the extent that we are a Controller as defined in the GDPR. For data that is provided to us by our customers, we process your personal data as a Sub-Processor. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation. We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children. Your Rights Under The GDPR If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. We comply with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU. Except as otherwise provided in the GDPR, you have the following rights: ◾ To be informed how your personal information is being used ◾ To access your personal information (we will provide you with a free copy of it) ◾ To correct your personal information if it is inaccurate or incomplete ◾ To delete your personal information (also known as "the right to be forgotten") ◾ To restrict processing of your personal information ◾ To retain and reuse your personal information for your own purposes ◾ To object to your personal information being used ◾ To object against automated decision making and profiling Please contact us at any time to exercise your rights under the GDPR at the contact details in this privacy notice. We may ask you to verify your identity before acting on any of your requests. Hosting And International Data Transfers We have offices and facilities in Australia, and we also operate technology services and use suppliers and contractors in other locations. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in Australia, Singapore, United Kingdom, United States of America and/or countries of the European Union. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following: ◾ The use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website ◾ The use of binding corporate rules, a copy of which you can obtain from us Security Of Your Personal Data We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and management procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this privacy notice. Changes To This Privacy Notice Please be aware that we may change this privacy notice in the future. We may modify this notice at any time, in our sole discretion, and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our privacy notice. Complaints And Contacts About Privacy If you have any complaints about our privacy practices, please feel free to send in details of your complaints to us via our contact details below. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. By mail: PO Box 558, Randwick NSW 2031, Australia By email: privacy@kugg.ar Copyright © 2021 Kuggar Pty Ltd. All rights reserved. Privacy Notice.

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