Privacy Policy

Last Updated: 8 August 2025

1. Our Privacy Commitment

Trade Safe Transfers Pty Ltd (ACN 681 376 045) and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)) ("We", "Us", "Our") recognise the importance of protecting your privacy. This Privacy Policy describes how We handle the personal information We collect when you access and use Our website and services. We respect your privacy rights under the Privacy Act 1988 (Cth) and comply with the Australian Privacy Principles in how We collect, use, and handle your personal information. In this policy, "personal information" means any information that can be used to identify you, such as your name, user account, address, or email.

2. The Information We Collect

We may collect the following information to provide Our escrow and related services including a specific Project. A “Project” means the trade job, task, or scope of work agreed upon between a Client and a Tradesperson for which Our services are used.

2.1 Personal and Business Information

• Your name, mailing, registered or residential address, email address, and telephone number.
• Your age or date of birth and gender.
• Business details including ABN, ACN, business name, trust name and company name.
• Your associations such as trusts, companies, shareholders and beneficial owners, beneficiaries and associated individuals.
• Your profession, occupation, or title.
• Information required for compliance and verification, such as insurance policies and licence numbers.

2.2 Transaction and Payment Information

• Credit card and bank account details for any payment made using Our escrow service.
• Information about the products and services you place in your cart and/or purchase, your billing and shipping information, and transaction details.

2.3 Device and Usage Information

• Information about the computers, phones, and other devices you use to interact with Our services, including IP address, device identifiers, cookie IDs, the browser you use, and your network connection. We may log your IP address to analyse trends and administer the site.
• Information regarding your use of or interactions with Our services, such as the projects you view, your search queries, and other activities.
• Information about your settings and preferences on Our platform.

2.4 Communications

• We receive information, including message and email content, when you communicate with Us for customer support, surveys, or research.
• Any other information you provide to Us through Our website, service centre, or customer surveys.

2.5 Social Network Accounts

If you choose to link or log in to Our services through a third-party online service, you direct that service to send Us certain profile information controlled by that service. This sharing is subject to the privacy notices and your privacy settings of that service.

2.6 Your Sensitive Information

We will only collect Sensitive Information about you with your consent, when it is reasonably necessary, or when required by law. If We do need to collect such information, we will notify you as soon as possible. “Sensitive Information” includes but is not limited to information or an opinion about an individual’s race or ethnic origin, political option, sexual orientation or practices, health information, criminal record, religious beliefs or affiliations or membership of a trade union.

If you do not provide Us with this information, We may not be able to provide Our services to you.

3. How and Why We Use Your Information

We use your personal information for the following purposes:

3.1 To Provide, Improve, and Customise Our Services

• To process your online registration and verify your identity.
• To create and manage your user account and the services you have requested.
• To facilitate and complete the escrow payment for a Project, which includes sharing relevant information between the Client and Tradesperson and the third party escrow agent.
• To manage your account, including billing and payment processing.
• To provide customised services to you, and to develop, test, and improve Our services by analysing your use of and interactions with Our platform.

3.2 For Communication and Marketing

• To communicate with you about Our services, your account, and changes to Our policies and terms. We also use your information to respond to you when you contact Us.
• To send you direct marketing communications about products and services We believe may interest you, in accordance with the Spam Act 2003 (Cth).
• You can opt-out of these marketing communications at any time.

3.3 For Security, Integrity, and Legal Compliance

• To authenticate your account, provide a secure payment experience, and to detect, investigate, and prevent malicious or fraudulent activity.
• To provide you with access to protected areas of Our Website.
• To comply with any law, regulation, or lawful direction from a regulator, including requests from law enforcement or government agencies. This includes Our obligations under the Anti-Money Laundering and Counter-Terrorism Act 2006 (Cth).
• To enforce or investigate potential violations of Our terms or policies.
• To assist, if request by you, in any dispute resolution process related to a Project.

We do not sell or rent your personal information under any circumstances.

4. Disclosure of Your Information

We may disclose your information to the following parties:

4.1 Service Providers and Related Parties

We may share information with Our related bodies corporate, contractors, or third-party service providers to provide, support, and improve Our services and technical infrastructure. This includes business services such as payment processing, marketing, and business analytics.

4.2 Parties to a Transaction

We disclose necessary information to the other party (Client or Tradesperson) and third-party escrow agent to assist with the completion of a transaction for a Project.

4.3 Marketing and Analytics Partners

We may use third-party marketing, advertising, and analytics partners to deliver personalised advertising and to help Us understand how people use Our services.

4.4 Change of Control

We may share personal information with actual or prospective acquirers or their representatives during negotiations of any sale, merger, or change in control involving all or a portion of Our business or assets.

4.5 Legal and Regulatory Requirements

We may share personal information as needed to comply with applicable law, respond to valid legal process, detect or prevent fraud or security concerns, protect Our rights and property, and resolve disputes.

4.6 Sharing at Your Direction

Where you provide consent, We share your personal information as described at the time of consent, including with persons you have authorised to receive information from your account.

4.7 Cross-Border Data Access

• Your personal information is stored on cloud servers located exclusively within Australia. However, when you, as a customer (whether as a Client or Tradesperson), access our services and your data through the app from a location outside of Australia, this constitutes a cross-border disclosure of your personal information. This is because your access from an international location involves the transmission of data across borders to your device, even though the data itself remains stored in Australia. While we take reasonable steps to ensure the security of your data during transmission, once it reaches your device, its subsequent handling and security are subject to the laws and practices of your local jurisdiction.
• We may disclose your personal information to entities located outside of Australia, including our authorised representatives. These disclosures are made to facilitate processing activities as described in this Privacy Policy, which are necessary to provide you with our services.
• We may also send your personal information overseas if the disclosure is directly to you, to one of your authorised representatives, or with your express consent.

5. Cookies and Tracking Technology

We may send a "cookie" (a small summary file) to your computer. This enables Us to recognise your computer when you visit Our Website. We use this data to research user habits and improve Our online services and platform. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser to not accept them.

6. Data Security and Retention

6.1 Security

We take reasonable steps to protect the personal information We hold from misuse, loss, and unauthorised access or disclosure. This information may be held in either electronic or hard copy form. However, as Our Website is linked to the internet, which is inherently insecure, We cannot provide any assurance regarding the security of information you transmit to Us, and you do so at your own risk.

6.2 Retention

We retain personal information for as long as We have an ongoing business need to do so. The criteria used to determine Our retention periods include:

• The length of time We have an ongoing relationship with you and provide Our services.
• Whether We have a legal obligation to keep the data (for example, certain laws require Us to keep records of your transactions for a specified period).
• Whether retention is advisable in light of Our legal position (such as in regard to enforcing Our agreements, resolving disputes, or regulatory investigations).
• We destroy or de-identify personal information when it is no longer needed for the purposes for which it was collected.

7. Data Breach Notification

In the event of a data breach that is likely to result in serious harm, We are committed to complying with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth). Our process involves:

• Contain: Taking immediate steps to contain the breach.
• Assess: Quickly assessing the nature and scope of the incident.
• Notify: Notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) if the breach is likely to result in serious harm.
• Review: Undertaking a post-breach review to prevent future incidents.

8. Your Rights and Choices

Under the Privacy Act 1988 (Cth), you have the right to manage your personal information. This includes the following rights, subject to certain exceptions permitted at law:

8.1 Access to your personal information

You have the right to request access to the personal information We hold about you under the Privacy Act 1988 (Cth). If you would like to access your personal information, please contact us using the details set out in the "Contacting Us" section of this Privacy Policy. We will take reasonable steps to verify your identity before granting access.

We will respond to your request within a reasonable time, typically within 30 days. We will also endeavour to provide access in the manner you request, if it is reasonable and practicable for us to do so. If access is refused, we will provide written reasons for the refusal and information on how you can lodge a complaint.

In limited circumstances, We may refuse access if:

• providing access would pose a serious threat to the life, health or safety of any individual;
• providing access would have an unreasonable impact on the privacy of others;
• the request is frivolous or vexatious;
• the information relates to anticipated or ongoing legal proceedings between Us and you, and would not ordinarily be accessible by the process of discovery in those proceedings;
• denying access is otherwise required or authorised by law; or
• giving access would reveal Our intentions in relation to negotiations with you in such a way as to prejudice those negotiations.

8.2 Portability to your personal information

While there is currently no general legal right to data portability under Australian law, we may, upon request and where technically feasible, provide you with a copy of your personal information in a structured, commonly used and machine-readable format. This may assist if you wish to transfer your information to another service provider. Please contact us here to submit any such request in writing. We will endeavour to respond to your request within a reasonable time.

8.3 Correction

If you believe the information We hold is incorrect, incomplete, or inaccurate, you may request that We amend it. If We do not agree with the amendment, We will notify you in writing stating the reasons for Our refusal and outline the mechanism available to you to complain about Our refusal and any other matter required to be provided to you at law.

8.4 Deletion

You have the right to request the deletion of your personal information. To process your request, We may require proof of identity. We reserve the right to deny your request, or retain certain personal information, if it would be unreasonable to delete it, or if retention is necessary to resolve disputes, for auditing purposes, to comply with Our data security procedures, or as otherwise required by law.

8.5 Objection and Restriction of Processing

You have the right to object to the processing of your personal information for certain purposes and to request that We restrict processing.

8.6 Withdrawal of Consent

Where processing of your personal information is based on consent, you have the right to withdraw that consent. This will not affect the lawfulness of any processing based on your consent before its withdrawal.

8.7 Opt-Out of Marketing

You may opt-out of receiving marketing communications from Us at any time by using the opt-out facilities provided in the communication.

9. Third-Party Links

Our Website may contain links to websites operated by third parties. We are not responsible for the privacy practices of these third-party sites. They are responsible for informing you of their own privacy practices.

10. Updates to This Policy

We may change this Privacy Policy from time to time. All changes will be posted in an updated version of the Policy on this Website.

11. Contacting Us

If you have questions about this policy, or a concern or complaint regarding your privacy, please contact Us via the "Contact Us" page on this Website. Your complaint will be treated confidentially. Our representative will contact you within a reasonable time to discuss your concerns and outline options for resolution. We will aim to resolve your complaint in an appropriate and satisfactory manner. If your complaint cannot be resolved, you may refer your complaint to the OAIC for assistance.

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