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Privacy Policy

Last updated: 9 August 2023 

This policy explains how and why we collect, use, hold and disclose your Personal Information.
We”, “us” and “our” means frntlne Pty Ltd (ACN 630 578 004) of Level 19, 15 William Street, Melbourne VIC 3000,

You consent to us collecting, holding, using, and disclosing your Personal Information in accordance with this policy.

What is personal information?

Personal Information is any information or an opinion about an identified individual or an individual who can be
reasonably identified from the information or opinion. Information or an opinion may be Personal Information
regardless of whether it is true.

What personal information do we collect and hold?

We collect information about you and your interactions with us, for example, when you complete our sign up
forms via our website, email or other platform. We may also collect Personal Information from you when you call
us, interact with us on social media platforms, interact with our electronic advertisements or otherwise visit our
website. The information we collect from you may include your identity and contact details, you bank account
details, your opinion about our products and details of enquiries or complaints you make.

If you interact with us via a social media platform you agree to allow us to receive information about you from the
social media platform, which may include your Personal Information (if you directly communicate with us via the
social media platform), information about your visits and interaction with our website.

We use cookies on our website, web applications and mobile applications. A cookie is a small text file that the
website may place on your device to store information. We may use persistent cookies (which remain on your
computer even after you close your browser) to store information that may speed up your use of our website for
any of your future visits to the website. We may also use session cookies (which no longer remain after you end
your browsing session) to help manage the display and presentation of information on the website. You may refuse
to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you
may not be able to use the full functionality of the website.

We may collect information about how you access, use, and interact with the website. We also use a range of other
tools such as Google Analytics and Segment to collect information about how you use, access, and interact with
our website, web application and mobile application. This information may include (a) the location from which you
have come to the site and the pages you have visited; and (b) technical data, which may include IP address, the
types of devices you are using to access the website, device attributes, browser type, language, and operating

Why do we collect, hold and use your personal information?

We collect, hold, and use your Personal Information so that we can (a) provide you with products and access to our
platform, and manage our relationship with you; (b) contact you, for example, to respond to your queries or
complaints, or if we need to tell you something important; (c) comply with our legal obligations and assist
government and law enforcement agencies or regulators; or (d) identify and tell you about other products or services
that we think may be of interest to you.

If you do not provide us with your Personal Information, we may not be able to provide you with our products,
communicate with you or respond to your enquiries.


How do we store and hold personal information?

We store most information about you in computer systems and databases (including cloud service providers)
operated by either us or our external service providers. Some information about you is recorded in paper files that
we store securely.

We implement and maintain processes and security measures to protect Personal Information which we hold from
misuse, interference, or loss, and from unauthorised access, modification, or disclosure.

These processes and systems include:

  a) the use of identity and access management technologies to control access to systems on which
information is processed and stored;
  b) requiring all employees to comply with internal information security policies and keep information secure;
  c) requiring all employees to complete training about information security; and
  d) monitoring and regularly reviewing our practise against our own policies and against industry best

We will also take reasonable steps to destroy or de-identify Personal Information once we no longer require it for
the purposes for which it was collected or for any secondary purpose.

Who do we disclose your personal information to and why?

We may disclose Personal Information to external service providers so that they may perform services for us or on
our behalf.

We may also disclose your Personal Information to others where:
  a) we are required or authorised by law to do so;
  b) you have expressly consented to the disclosure, or the consent may be reasonably inferred from the
circumstances; or
  c) we need to share it with data processors to operate our business and provide products to you.

If the ownership or control of all or part of our business changes, we may transfer your Personal Information to the
new owner.

Do we disclose personal information to overseas recipients?

We may disclose your Personal Information to recipients which are located outside Australia.

Do we disclose your personal information for marketing?

We will use your Personal Information to offer you products we believe may interest you, but we will not do so if you
tell us not to. These products may be offered by us, our related companies, our other business partners or our
service providers.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing
communications by following the opt-out instructions provided in the communication.

Your rights under the EU GDPR

Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject (if you are a citizen
or resident of the EU) you have the right to:
  a) access your data;
  b) have your data deleted or corrected where it is inaccurate;
  c) object to your data being processed and to restrict processing;
  d) withdraw consent to having your data processed;
  e) have your data provided in a standard format so that it can be transferred elsewhere; and
  f) not be subject to a decision based solely on automated processing.

Your rights under the Singapore PDPA

Under Singapore’s Personal Data Protection Act (PDPA), if you are a resident of Singapore and certain
requirements are fulfilled you have the right to:
  a) request access to your personal data that is in our possession or control;
  b) request access to information about how your personal data was used or disclosed in the preceding 12
  c) request your personal data to be transmitted directly to another entity;
  d) request the correction or rectification of your personal data as soon as practicable;
  e) withdraw your consent for communication from us; and
  f) with reasonable notice, withdraw consent to having your personal data collected, used and disclosed;


If you have a complaint about the way in which we have handled any privacy issue, including your request for
access or correction of your Personal Information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the
outcome of this investigation and any subsequent internal investigation.

Contact details

If you have any questions, comments, requests, or concerns, please contact us at:

Privacy Officer
Level 19, 15 William Street
Melbourne VIC 3000, Australia

Changes to this policy

From time to time, we may change our policy on how we handle Personal Information or the types of Personal
Information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of
our current policy from our website or by contacting us at the contact details above.

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