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Socii Platform Privacy Policy

Last Updated: 27 January 2025

1. Introduction

1.1 Socii Book Pty Ltd (ACN 690 364 731) (trading as Socii) (we, us or our) operates a software platform accessible at sociibook.com and via the Socii application (together, the Platform).

1.2 We are committed to managing personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act).

1.3 This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

1.4 In this Privacy Policy, you and your refers to any individual about whom we collect personal information.

1.5 If you have any queries about this Privacy Policy or the way we handle your personal information, please contact us using the details set out in section 19.

2. About the Platform

2.1 The Platform provides infrastructure for storing, tracking and managing referral relationships and related agreements. The Platform enables users to create business profiles, connect with other users, record and track introductions, and store referral agreements.

2.2 We are not a party to any referral agreement or arrangement between users of the Platform.

3. Anonymity and Pseudonymity

3.1 The Platform requires users to register an account and provide accurate business and contact details in order to access and use the Platform.

3.2 It is not practicable for us to allow you to deal with us anonymously or using a pseudonym. This is because the Platform is designed to facilitate business-to-business referral relationships, which require users to identify themselves and their businesses to other users.

3.3 If you do not wish to provide personal information to us, you will be unable to use the Platform.

4. Information We Collect

4.1 The types of personal information we collect will depend on the circumstances of collection and your interaction with the Platform.

Account Registration

4.2 When you register for an account on the Platform, we collect:

  • your full name;
  • your email address;
  • your phone number (if provided); and
  • your password (stored securely using industry-standard encryption).

Business Profile

4.3 When you create and maintain a business profile, we collect:

  • your business name;
  • your Australian Business Number (ABN);
  • your business address;
  • services offered and areas of expertise;
  • your ideal client profile description; and
  • your logo and branding images.

Connection and Relationship Data

4.4 When you use the Platform to connect with other users, we collect information about:

  • connections made with other users;
  • connection requests sent and received; and
  • relationship status with connections.

Introduction and Lead Data

4.5 When you record introductions or leads on the Platform, we collect:

  • the contact name and business name of the introduced party;
  • the contact details (email and phone number) of the introduced party;
  • contextual notes about the introduction;
  • the desired outcome of the introduction; and
  • lead status and history.

Agreement Data

4.6 When you upload agreement documents to the Platform, we store those documents, which may contain personal information of the parties to the agreement.

Usage Data

4.7 When you use the Platform, we automatically collect:

  • login history and timestamps;
  • feature usage and interaction data;
  • device and browser information; and
  • IP address.

Communications

4.8 We collect information contained in support requests, feedback and other communications you send to us.

Sensitive Information

4.9 We do not intentionally collect sensitive information (as defined in the Privacy Act) through the Platform. Sensitive information includes information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation and health information.

4.10 If you upload documents to the Platform that contain sensitive information, you are responsible for ensuring you have appropriate consent or authorisation to do so.

5. How We Collect Information

5.1 We collect personal information:

  • directly from you, when you register for an account, create or update your business profile, record introductions, upload agreements, or communicate with us;
  • from other users of the Platform, when they record an introduction involving you or a third party;
  • automatically, through cookies, analytics tools and server logs when you access the Platform; and
  • from third parties, where we have integrations with third-party services.

6. Unsolicited Personal Information

6.1 From time to time, we may receive personal information that we have not requested or solicited. This may occur, for example, when a user uploads an agreement or records an introduction that contains personal information about a third party.

6.2 Where we receive unsolicited personal information, we will determine whether we could have collected the information under the APPs. If so, we will handle that information in accordance with this Privacy Policy. If not, we will destroy or de-identify the information (provided it is lawful and reasonable to do so).

7. Purposes of Collection

7.1 We collect and use personal information for the following purposes:

  • to provide and operate the Platform;
  • to create and manage user accounts;
  • to enable connections between users;
  • to record and track introductions and leads;
  • to store and display agreements;
  • to communicate with you about your account, the Platform and our services;
  • to send you marketing communications in accordance with section 8;
  • to improve the Platform and develop new features;
  • to comply with our legal obligations;
  • to enforce our terms of use; and
  • for security purposes and to prevent fraud.

8. Direct Marketing

8.1 We may use your personal information to send you marketing communications about our products, services, events and promotions that may be of interest to you.

8.2 You may opt out of receiving marketing communications from us at any time by:

  • clicking the unsubscribe link in any marketing email you receive from us;
  • updating your communication preferences in your account settings; or
  • contacting us using the details set out in section 19.

8.3 If you opt out of receiving marketing communications, we may still contact you in relation to your account, transactions, and other non-marketing matters relating to the Platform.

8.4 We do not sell your personal information to third parties for their marketing purposes.

9. Disclosure of Information

9.1 We may disclose your personal information to:

  • other users of the Platform, to the extent that your profile information is visible to your connections, and lead details are visible to relevant partners in accordance with the Platform functionality;
  • our service providers, including hosting providers, analytics providers and email delivery services, under appropriate contractual arrangements;
  • our professional advisers, including lawyers and accountants, who are bound by confidentiality obligations;
  • regulatory authorities or law enforcement agencies, where required or authorised by law or in response to a court order or lawful government request;
  • a third party in connection with a business transfer, if we sell, merge or transfer any part of our business; and
  • any other party where you have consented to such disclosure.

9.2 Lead contact details are not shared beyond the relevant partner relationship on the Platform.

10. Cross-Border Disclosure

10.1 Some of our service providers, including cloud hosting providers, may be located overseas or may store data on servers located overseas.

10.2 Where we disclose your personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information, or that an exception under the APPs applies.

11. Security

11.1 We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

11.2 Our security measures include:

  • encryption of data in transit and at rest;
  • access controls to limit access to personal information to authorised personnel; and
  • regular security reviews.

11.3 However, no data transmission over the internet or data storage system can be guaranteed to be completely secure. We cannot guarantee the absolute security of your personal information.

11.4 You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

12. Data Breaches

12.1 We have procedures in place to respond to suspected or actual data breaches.

12.2 If we experience a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will:

  • take reasonable steps to contain the breach and mitigate any resulting harm;
  • assess the breach to determine whether it is an eligible data breach under the Privacy Act;
  • if the breach is an eligible data breach, notify the Office of the Australian Information Commissioner and affected individuals as required under Part IIIC of the Privacy Act; and
  • take steps to prevent future breaches.

13. Data Retention

13.1 We retain your personal information for as long as your account is active or as needed to provide you with the Platform and our services.

13.2 Following closure of your account, we will retain your personal information for a period of 7 years for the purposes of complying with our legal obligations, resolving disputes and enforcing our agreements.

13.3 After the expiry of the retention period, we will delete or anonymise your personal information.

13.4 Agreement documents uploaded to the Platform will be retained in accordance with the same retention periods set out above.

14. Access and Correction

14.1 You may access and update certain personal information we hold about you through your account settings on the Platform.

14.2 You may request access to any personal information we hold about you by contacting us using the details set out in section 19.

14.3 We will respond to your request within 30 days. We may require verification of your identity before providing access to your personal information.

14.4 You will not be charged for making an access request, but we may charge a reasonable fee for the time and expense of providing access if your request requires substantial effort.

14.5 If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request that we correct that information. We will take reasonable steps to correct the information upon receiving such a request.

14.6 We may refuse a request for access or correction in circumstances permitted by the APPs. If we refuse a request, we will provide you with written reasons for the refusal.

15. Cookies and Analytics

15.1 The Platform uses cookies and similar technologies. A cookie is a small file stored on your device that assists in managing customised settings and delivering content.

15.2 We use the following types of cookies:

  • essential cookies, which are necessary for the Platform to function;
  • functional cookies, which enable enhanced functionality and personalisation; and
  • analytics cookies, which help us understand how users interact with the Platform.

15.3 We use third-party analytics services (such as Google Analytics) to collect information about your use of the Platform. This information is used to compile reports and help us improve the Platform.

15.4 You can manage your cookie preferences through your browser settings. However, disabling cookies may affect the functionality of the Platform.

16. Third-Party Links and Children’s Privacy

Third-Party Links

16.1 The Platform may contain links to third-party websites, applications or services.

16.2 We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party websites you visit.

Children’s Privacy

16.3 The Platform is not intended for persons under the age of 18.

16.4 We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information.

17. Changes to This Privacy Policy

17.1 We may update this Privacy Policy from time to time.

17.2 We will notify you of any material changes by email or through a notice on the Platform.

17.3 Your continued use of the Platform following notification of changes constitutes your acceptance of the updated Privacy Policy.

17.4 The date of the most recent update is displayed at the top of this Privacy Policy.

18. Complaints

18.1 If you have any concerns about this Privacy Policy or the way we have handled your personal information, you may lodge a complaint with us.

18.2 Complaints should be directed to our Privacy Officer using the contact details set out in section 19.

18.3 We will acknowledge receipt of your complaint within 5 business days.

18.4 We will investigate your complaint and will use reasonable efforts to respond within 30 days. If we require additional time to investigate your complaint, we will notify you.

18.5 If you are not satisfied with our response to your complaint, or you consider that we may have breached the APPs or the Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted:

  • by telephone on 1300 363 992; or
  • via the OAIC website at www.oaic.gov.au.

19. Contact

19.1 If you have any questions about this Privacy Policy or wish to make an access or correction request, please contact our Privacy Officer:

Socii
Socii Privacy Officer
Email: hello@sociibook.com
Website: sociibook.com