Privacy Policy and Collection Notice

1. ABOUT
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This Privacy Policy applies to the collection and handling of your personal information by Enhance Labs Pty Ltd ("Enhance Labs", "we", or "us"). Enhance Labs aims to operate in accordance with the Privacy Act 1988 (Cth) (the "Privacy Act") and the Australian Privacy Principles ("APPs") in the ways in which Enhance Labs collects, uses, discloses, stores, secures, and disposes of Personal information.

In this policy, personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.

This Privacy Policy sets out how Enhance Labs manages Personal Information and other information that our customers, employees and partners may provide to us, including via our websites and platform (e.g., www.enhancelabs.ai and any other websites that we own or operate), any software we make available, and any related offerings (the “Services”).

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our website or Services. It also outlines how complaints to the Office of the Australian Information Commissioner ("OAIC").

For more information on the APPs, you can visit the website of the OAIC via the following link: https://www.oaic.gov.au/privacy/australian-privacy-principles/.

For specific enquiries, you can contact the OAIC using the following email address: enquiries@oaic.gov.au.

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2. THE KINDS OF PERSONAL INFORMATION ENHANCE LABS COLLECTS AND HOLDS

We may collect Personal Information if you are a:

• visitor to our webpages or user of our Services;
• former, current, or future employee (including job applicants), customer, or supplier.

We may collect and hold personal information that you provide to us, whether by use of the Enhance Labs Services, by means of a form on our website, by email, in a letter, or otherwise, such as:

• account information provided including your name, age or date of birth, address, email address, company information, and phone number;
• customer provided content uploaded or input into the Enhance Labs Services or platform, including any sensitive information provided;
• payment information used to process your payments for the Services including your name, email address, mailing address, payment card information, and any other billing information necessary to process the payment;
• communication information when you communicate with us, including feedback, email address, phone number, mailing address, and marketing preferences;
• candidate and employee information including any candidacy or employment information provided in the course of job applications;
• automatically collected personal information including usage data relating to your access to and use of the Enhance Labs Services, including the performance of the Services such as metadata, logs, Internet protocol address, telemetry data, user settings, cookie identifiers, and other unique identifiers.

If we are unable to collect the information needed for the provision of our Services or to otherwise respond to your request, we may not be able to provide those Services or action your request.

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3. HOW ENHANCE LABS COLLECTS YOUR PERSONAL DATA

We may collect Personal Information in a number of ways, including:

• directly from you automatically or manually, for example, when you use our Services, provide information by email, by phone, in application forms, including suspended or saved application forms, or other agreements;
• when you visit our website;
• from our agents, commercial partners and other third parties;
• from the organisations and entities identified under "Who we disclose your Personal Information to" section below, including our related entities; and
• when legally required or authorised to do so.

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4. WHO WE DISCLOSE YOUR PERSONAL INFORMATION TO

Your information may be disclosed to persons or companies within our group of companies. We may also disclose your Personal Information to people or organisations outside of our group of companies for the purposes noted in the "Purposes for which Enhance Labs collects, holds, uses and discloses Personal Information" section below and any other purposes specified below.

This may include:

• organisations who manage some of our business activities and functions, including payroll handling, marketing, corporate administration and strategies;
• service providers, including contractors, consultants, IT service providers and sponsors and/or promoters;
• our related entities outside our group of companies (e.g. partnerships, joint venture entities, agents, contractors, or external service providers for the operation of their business);
• our business partners;
• the police or other relevant authorities or enforcement bodies where necessary;
• government and regulatory authorities or organisations (such as ASIC, as required or authorised by law); and/or
• internet service providers or network administrators (including, if we have reason to suspect you have committed a breach of our terms and conditions or have otherwise been engaged in any unlawful activity and we reasonably believe such disclosure is necessary).

You expressly consent to us providing your information to the persons or organisations above for purposes specified in the "Purposes for which Enhance Labs collects, holds, uses and discloses Personal Information" section below and any other purposes specified in this section .

We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.

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5. PURPOSES FOR WHICH ENHANCE LABS COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

We collect, hold, use and disclose your Personal Information for the following purposes:

• to perform and manage our business activities and functions, including providing our products and services to you;
• to manage our relationship with you;
• to review, process and assess your requests and applications;
• to assist you to gain provision of a product or service;
• to research, design, develop, manage, provide and improve our products and services;
• to improve the products and services provided to you and your experience with us;
• to conduct market research;
• to contact you; and
• to comply with applicable laws, and assist government or law enforcement agencies.

We may also collect, hold, use and disclose your Personal Information for other reasons where required or permitted by applicable law.

The use of your Personal Information for direct marketing is also regulated by the Spam Act 2003 (Cth), and we will not use or disclose your Personal Information for the purposes of direct marketing to you unless you have provided your consent to receive direct marketing materials.

Where you have consented, your Personal Information is also collected, held, used and disclosed so that we, and our related entities, can promote and market services to you (including by way of direct marketing through mail, telephone, email, SMS and MMS messages, instant message and any other electronic means, and through third party channels such as social networking sites) ("Marketing Services"). This is to keep you informed of products, services and special offers and where permitted by law we may continue these Marketing Services after you cease holding an active product or using an active service provided by us. If you do not wish to receive these Marketing Services, please see the ‘Opt-out’ section below.

If we do not collect your Personal Information for the purposes detailed in this policy we may not be able to provide you with our products or services.

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6. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

We take all reasonable precautions to ensure that the Personal Information we collect, hold, use and disclose is accurate, complete, and up-to-date. We will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete. You have the right to seek correction of your personal information, or seek access to your personal information, as detailed below.

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7. CORRECTION

If you wish to correct your Personal Information that we hold and/or if we have given your Personal Information to another party and you would like us to let that party know it is not correct, please contact us by via the contact details below. We will respond to your request within a reasonable period and will not charge you for the making of the request or the correcting of your Personal Information. If we do not consider that your Personal Information needs correcting, we will provide reasons for the refusal and information about how you can complain about the refusal.

To make a request for correction, see the contact details at section 10 below.

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8. ACCESS

You may request access to the Personal Information we hold about you by contacting us via the contact details below. We will respond to your request within a reasonable period. We will give access in the manner you have requested if it is reasonable to do so. We may charge you a fee to access the information. The fee will not be excessive and will not apply to the making of the request. We may deny you access to your Personal Information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or it would be likely to prejudice enforcement related activities by an enforcement body, if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If we decide not to give you access, we will provide reasons for the refusal and information on how you can complain about the refusal.

To make a request for access, see the contact details at section 10 below.

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9. TRANSFER OF PERSONAL INFORMATION OVERSEAS

As part of our normal business processes and to provide our products and services, we may transfer Personal Information we have collected about you to a person or organisation in an overseas country including:

• to our related entities located outside Australia;
• to service providers or third parties who store data or operate outside Australia; and
• as required or authorised by law.

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10. MAKING A PRIVACY COMPLAINT AND HOW TO CONTACT US

If you wish to make a complaint about the way in which Enhance Labs collects or handles your Personal Information or our adherence to the APPs, please contact us at the following contact point:

Contact Details:

engineering@enhancelabs.ai

If we receive a complaint, whether in writing or verbally, we will commence an investigation of the relevant complaint. Through the investigation, we will endeavor to determine the nature of the complaint and how it occurred. We may contact you during the process to seek any further clarification if necessary. If a complaint is substantiated, we will escalate the matter internally to seek resolution of the matter, and will contact you to inform you of the outcome of the investigation. We will endeavor to resolve all investigations within a reasonable time.

By giving us as much information as possible, you will help us resolve complaints faster. If you have any supporting documentation, please have it to hand when you raise your concern(s). Where there has been a delay to our response to your complaint, we will send you an email or letter advising of the reasons for any delay, and your right to complain to the OAIC.

If you are dissatisfied with our response, you may make a complaint to the OAIC about the way we handle your Personal Information. The OAIC can be contacted at either http://www.oaic.gov.au or by calling 1300 363 992 Monday to Thursday 10 am to 4 pm (AEST/AEDT).

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