Privacy Policy

1. Definitions

   In this Privacy Policy, unless, the context otherwise requires:

   1. Personal Information has the meaning given to it in the Privacy Act;
   2. Permitted General Situation has the meaning given to it in the Privacy Act;
   3. Privacy Act means Privacy Act 1988 (Cth);
   4. We, us, our means AGDATA HOLDINGS PTY LTD ACN 147 923 724;
   5. You means a natural person.
2. Interpretation

   In this Privacy Policy, unless the context otherwise requires:

   1. A reference to:
      1. one gender includes the other genders;
      2. the singular includes the plural and the plural includes the singular;
      3. a person includes a natural person, partnership, body corporate, joint venture, association, government, authority, agency or other entity;
      4. a party includes that party’s executors, administrators, successors and permitted assigns;
      5. a document is to that document as amended, novated or replaced from time to time;
      6. “including” and similar expressions are not words of limitation;
      7. a statute, regulation or provision of a statute or regulation (“Statutory Provision”) includes:
         1. that Statutory Provision as amended or re-enacted from time to time; and
         2. a statute, regulation or provision enacted in replacement of that Statutory Provision, or if relevant, the predecessor to that statute, regulation or provision;
   2. where a word or expression is given a particular meaning, other parts of speech and grammatical forms of that word or expression have a corresponding meaning;
   3. if a party consists of more than one person, this Privacy Policy applies to them jointly and each of them severally;
   4. headings are for convenience only and do not affect the interpretation or form part of this Privacy policy;
   5. words defined in the Privacy Act have the same meaning in this Privacy Policy.

1. We may collect, hold and use different types of Personal Information about you. In addition to the types of information we may collect from you listed below, we may collect and hold additional Personal Information about you which is reasonably necessary for one or more of our functions or activities.
2. The kinds of personal information that we may collect and hold about you includes:
   1. Identification information, including, your:
      1. name;
      2. date of birth;
      3. address;
      4. email address;
      5. telephone numbers;
      6. gender;
      7. occupation;
      8. current, prospective or former employers;
      9. your personal circumstances;
      10. entities you are involved in or associated with;
      11. sales, support and training history;
      12. photographs, film and/or recordings or any other digital representation;
      13. other information that we consider necessary for the provision and promotion of our products and services and the operation of our business;
      14. financial information;
      15. family information;
      16. application usage, location and diagnostics;
      17. device information, such as which browser you use, your operating system language and how you use your device; and
      18. your location or activity including IP address and geolocation data based on the GPS on your mobile device (when accessing our services), and whether you have accessed third party sites.

1. You consent to the collection of Personal Information that you provide to us (either directly or indirectly) for use and disclosure by us in accordance with this Privacy Policy.
2. How we collect personal information? We collect Personal Information in a number of ways. For example, we generally collect Personal Information directly from you such as through the completion of a form, when you place an order with us, register or activate a product or product trial with us, apply for or attend training programs with us, in a document, verbally, in a meeting or interview, by email, by a digital device and other electronic means. If you are a current or prospective client of ours, when you perform actions within your products or applications or if you are a member of our authorised partner programs. When you use our website or Phoenix systems, we may collect information about your IP address, location or activity.
3. How we hold personal information? We hold your Personal Information in our notes, records, documents, emails, electronic communications, digital devices, software including but not limited to our Phoenix system, cloud computing software, Phoenix Live, document management systems, servers, databases, premises and storage facilities.
4. Personal Information collected from third parties: In some circumstances we may collect Personal Information about you from a third party. For example, we may collect information about you from:
   1. a public register;
   2. a relative;
   3. an associate;
   4. an advisor, including:
      1. an accountant;
      2. a financial planner;
      3. an insurer;
      4. a broker;
      5. a lawyer;
   5. an expert;
   6. your current, prospective or former employer;
   7. a referee;
   8. a referrer;
   9. a person you authorise us to liaise with;
   10. an information match agent or intermediary.
5. We may combine Personal Information we collect from you with Personal Information we collect from third parties.

1. We collect, hold, use and may disclose Personal Information so we can:
   1. verify your identity;
   2. verify your location;
   3. assist you or an entity you are involved in or associated with;
   4. provide a service or product or manage products and services including initial set up and activation;
   5. liaise with your accountant or bookkeeper;
   6. provide information;
   7. process an application including but not limited to an employment application and manage employees of ours;
   8. if you are a prospective or current employee of ours, process payroll;
   9. use automated decision making (ADM) software to assist or replace judgment of human decision makers that could reasonably be expected to significantly affect the rights or interests of an individual;
   10. use Artificial Intelligence (AI) to train our systems or tools;
   11. respond to your enquiry, request or complaint;
   12. conduct market research;
   13. take any required legal action;
   14. run our business and perform administrative, legal and operational tasks;
   15. conduct marketing and business development;
   16. chase a payment you owe us and if we think it is appropriate, report you to a credit reporting body;
   17. comply with our obligations under applicable laws, regulations and codes;
   18. cooperate and liaise with an information match agent or intermediary in relation to verification of identity and administration of a document verification service;
   19. liaise with a related entity of ours including our parent company Arcadea AG Holdings Pty Ltd ACN 684 061 916 and Arcadea Group LLC (Parent Company) and any subsidiaries of the Parent Company and their officers and employees; and
   20. create reports including a State of the Industry Report.

If you are a client or prospective client of ours, we may use Personal Information for the purposes of developing and training AI tools for use within our business. This excludes information contained in datasets, unless provided by you as our client or prospective client for the purposes of providing support to you.

We may use ADM software to record file notes or summarise meeting notes. We may use ADM software to:

1. assist us in making decisions about recruitment, employee management, dispute resolution and our general business operations;
2. solely make a decision in relation to recruitment where we may screen prospective employees through a third-party recruitment website;
3. review and respond to customer support request;
4. enable a customer or a person authorised by a customer to upload a document to our system which may then extract information and use it in that customer’s data structure to create a transaction in their software.

We may use the following types of personal information when using ADM or AI:

1. identification information, including, your:
   1. name;
   2. address;
   3. email address;
   4. telephone numbers;
   5. date of birth;
   6. occupation;
   7. current or former employers;
2. your personal circumstances;
3. entities you are involved in or associated with;
4. other information that we consider necessary for the provision and promotion of our products and services and the operation of our business;
5. financial information;
6. photographs, film and/or recordings or any other digital representation;
7. relationship information;
8. family information; and
9. employment information for an employee whether previous, current and prospective.

Our website uses technology called cookies. We may also use web server log files to collect information about website usage or advertise online. Cookies are text files with small pieces of data used to identify your computer when using a network. There are various types of cookies including:

1. first party cookies which is a cookie that is sent from a website to your web browser when you visit the site;
2. temporary cookie that only lasts for one browsing session;
3. persistent cookie that remains on your computer after you close your browser and is sent back to the website each time you visit it;
4. third party cookie sent by an organisation that supplies content like advertising on websites that you may visit; and
5. flash cookie if you have Adobe Flash Player plugin installed in your browser.

Browsers are usually set to accept cookies, however, if you would prefer not to receive cookies, you may alter the configuration of your browser to refuse cookies.

If you refuse cookies, our website may not function effectively. We may use cookies and server logs to determine how many people use our website and other general information like which part of our website is the most visited.

We may request information via surveys or competitions. Where we do, you consent to your personal information being collected, used, held and stored in accordance with this privacy policy.

How we use and disclose your personal information for direct marketing: You consent to us using or disclosing your personal information for the purpose of direct marketing. We may send you direct marketing communication about our products, services, opportunities or events. For example:

1. advertising on social media that you are logged into, using personal information, including data collected by cookies relating to websites that you have viewed;
2. sending you emails of new software, sale opportunities or other advertising material relating to our products or services, using personal information provided by you as a client or prospective client, in the course of signing up for our products or services; or
3. sending you an SMS message, advertising products, services, training opportunities or information seminars.

We may send direct marketing communication through a variety of channels including telephone, SMS, mail, email and online advertising. You consent to us sending the direct marketing via any of those methods.

Opting Out: You may opt-out of receiving direct marketing communications or information from us at any time by:

1. clicking the ‘unsubscribe’ link at the bottom of any of our direct marketing communications;
2. clicking the ‘opt out’ link in any SMS messages, or by replying ‘STOP’ to the SMS message received;
3. by contacting us at privacyofficer@agdata.com.au to opt out of any or all marketing.

1. Set-up and configure your email
   For email purposes, Phoenix stores only the minimum personal information needed to enable you to send your Phoenix financial information, production information, reports, documents, and Phoenix data backups via email. This personal information (if any) is stored only within your Phoenix data, and your Phoenix data is owned exclusively by you. The information is not sent to us. Phoenix cannot receive emails.
2. “Email Client” option (Phoenix Desktop only)
   The Email Client option configures Phoenix to use a separate email client application (Microsoft Outlook, Mozilla Thunderbird, etc) which you have installed on your local computer. Phoenix collects no additional information when the Email Client option is selected. Emails are processed only by the separate email application on your local computer and are not processed or stored on our servers.
3. “Email account” option (Phoenix Desktop and Phoenix Live)
   The email account option configures Phoenix to use Google Gmail, BigPond Webmail, Telstra Mail, or another email provider account you specify. Phoenix stores the company or other name you specify, your email address and your email password (if required). The password is securely encrypted before being stored. The name, password and email address are stored in your Phoenix data and are not sent to us. When using the “Sign In With Google” option for Gmail, Phoenix stores only the name you specify and your email address; your password is not stored in this case. Emails are sent directly from the Phoenix application and the emails are not processed or stored on our servers.
4. “Phoenix Live Email” option (Phoenix Live only)
   Phoenix stores the company or other name you specify and the email address. The name and email address are stored in your Phoenix data and are not sent to us. Emails are sent directly from the Phoenix application and are not processed or stored on our servers.
5. Sent Items Log (Not applicable to “Email Client” option)
   Phoenix stores some information about each sent email. Phoenix stores the destination email address, subject line of the email, the date sent, the username of the signed in user of the Phoenix data, and the name of the Phoenix module from which the email was sent. This information is stored in your Phoenix data and is not sent to us. Phoenix stores the information only for your viewing and reference via the Sent Items Log of the Phoenix application.

1. You can request access to any Personal Information which we hold about you and request us to correct any inaccuracies in Personal Information we hold about you by making a request in writing to our privacy officer (see details below).
2. We will require you to verify your identity and specify what Personal Information you require. We cannot give you information about anyone else.
3. Making a request is free, however, we may charge a reasonable fee to cover the cost of verifying your identity requesting and locating, retrieving, reviewing and copying any material requested. The fee will not be excessive, and we will endeavour to advise the likely cost in advance.
4. We will endeavour to allow access or make the changes requested by you to your Personal or Sensitive Information, unless, we consider the Privacy Act or another relevant law requires us to withhold the information, or not make the changes. If we cannot provide you with access to that information, we will endeavour to provide you with written notice explaining the reasons for refusal. If we refuse you access or to correct your Personal Information, you can make a complaint about this, by following the complaint procedures in this Privacy Policy (see details below).
5. The Privacy Act permits an organisation to deny access to Personal Information in certain circumstances, including where giving access would have an unreasonable impact on the privacy of other individuals.
6. Please contact us if your contact details change or if you believe we hold incorrect information about you.

1. If you would like further information about the way we manage the Personal Information we hold, or if you have a concern that you believe we have breached the Australian Privacy Principles please contact:

   Privacy Officer AGDATA Holdings
   122 Russell Street
   Toowoomba QLD 4350
   privacyofficer@agdata.com.au

2. We will endeavour to investigate any complaint, and respond to you as promptly as is reasonably practicable after receiving your complaint.
3. You may complain to:

   Office of the Australian Information Commissioner (OAIC)
   GPO Box 5218, Sydney NSW 2001
   1300 363 992
   enquiries@oaic.gov.au

1. Sending information overseas: we are likely to disclose Personal Information about you to overseas recipients, for instance, when storing Personal Information with technology service providers which are situated outside Australia.
2. The countries in which these overseas service providers are likely to be located is:
   1. Africa;
   2. Asia Pacific;
   3. Canada;
   4. Germany;
   5. Japan;
   6. United Kingdom;
   7. Philippines;
   8. Sri Lanka; and
   9. United States of America.

Our website may contain links or references to other websites to which this Privacy Policy may not apply. You should review the Privacy Policy of each of those websites and assess whether those policies are acceptable to you before using those websites.

1. We may, from time to time, review and update this Privacy Policy to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate.
2. Any changes to our Privacy Policy will be published on our website.
3. This Privacy Policy was last updated on 1 June 2026.