Privacy policy (last updated 1 Oct 2022)

The purpose of this document is to explain what data or information we may hold about you and why.

Zerophase is 100% committed to protection and privacy of your data. Our services and practices meet the requirements and guidelines set in the Australian Privacy Act (1983), the General Data Protection Regulation (GDPR), as required by the European Union, and in the California Consumer Privacy Act (CCPA).

1. Your personal information at Zerophase

1.1. Who should read this notice?

You, the User of the Zerophase service

1.2. What do we need your data for?

• To provide you the Zerophase service

• To deliver your Zerophase activities including feedback, coaching, quizzes, reminders and messages

• To process payments safely

• To contact and inform you of relevant matters concerning the service

• To monitor the safety of the Zerophase service and prevent misuse

• To give us insights into user behavior so we can improve our communications and products

• To help us measure the effectiveness of ads and web searches

1.3. Who is handling your data?

Zerophase Technologies Proprietary Limited

ABN: 66 609 549 448

c/o Ademus

PO Box A27 Enfield South NSW 2133,

Australia

Contact:

Peter O’Hanlon

CEO

peter.ohanlon@zerophase.ai

1.4. How long can we keep your data?

We will delete your contact details and other info after 6 years at latest when you have last used Zerophase service.

1.5. What information do we hold about you?

• Your contact details

• Communications between You and Us

• Your name, teams and preferences

• Payment information (we don’t ever receive credit card numbers - they go directly, and exclusively, to our payment operator)

• Activity data including but not limited to feedback, quizzes, polls, coaching activities, check-ins, and goals created while using the service

• Direct messages to the Zerophase service and indirect messages to channels in which the Zerophase service is participating in

• Other data that you enter into Zerophase

1.6. Where do we get your data?

• We get your information from you. The information is either provided by you (such as your profile information), or information we have gained from your visits to and interactions with the service (such as your user log information).

• We get your contact details and other information when you either use the Zerophase service, or when an account is created on your behalf by your employer.

• We store any communication securely at the time of communication.

1.7. Who else gets (some of) your data?

The partners we use:

• Infrastructure: Google Cloud Platform

• Payments: Stripe

• Communications: SendGrid

• Analytics: Google Analytics

• LinkedIn Insights

Some of the above partners may use cookies.

1.8.  Who’s responsible for your data?

Zerophase Technologies Proprietary Limited is the company behind the Zerophase service.

In order to keep Zerophase running for you, we need some information about you. This information is called ‘personal data’ (for example an email address) as it can be used to identify you.

Here’s a breakdown of the different data processing related roles in the service:

• As a single user or when participating in an activity such as answering or being the subject of a feedback request, You are a data subject.

• As a single user or when answering a feedback request, Zerophase is the so-called controller of your information.

• If you are using Zerophase on your employer’s or organization’s account, we are a processor of your personal data for your employer, who in turn is the controller of the data regarding the messaging and activities performed by you and your colleagues.

This means, for example, that we and your employer are responsible for keeping your personal data safe. Please turn to your employer to gain knowledge of how your employer processes personal data.

Below we explain in a bit more detail how, why and for how long exactly we have your personal data.

2. Needed data types, legal bases and storage times

2.1. Contact Details and communications

First and foremost, we need your contact details. This is important because that’s how we’ll deliver to you the Zerophase activities and messages. Also, every now and then we may need to contact you and inform you about new features on the service or other relevant matters. We also store these communications between you and us so that we can review them later if necessary.

Legal basis: Legitimate interest*, legal obligation

Storage time: Up to 6 years in connection with our accounting obligations if required.

2.2. Payment info

In order to process payments on Zerophase we need your payment info. Although this info is collected and processed for our purposes - to provide the service - we don’t actually even hold this info ourselves. It is processed solely by our payments operator. What we do hold is the history of transactions. We may store this information for up to 6 years in connection with our accounting obligations if required.

Legal basis: Contract, legal obligation

Storage time: Up to 6 years

2.3. Information collected from activities and messaging

In order to use Zerophase effectively, your messaging to the Zerophase service (questions and answers), and activity data is stored along with your user contact details. If activities are defined as ‘anonymous’ by your employers administrator then that data is stored anonymously. Your activity data are combined with other data you provide to the service to create reports for you, your teams and your organization.

Legal basis: Legitimate interest

Storage time: Up to 6 years

2.4. IP address

IP Addresses may be saved in automated error reports or logs. IP addresses are not used for identifying individual users.

Legal basis: Legitimate interest

Storage time: Up to 1 year

2.5. User logs

User log information is collected to help find, analyze, and resolve defects or issues in the Service.

Legal basis: Legitimate interest

Storage time: Up to 1 year

2.6. Other information regarding users of the service

This includes your name and email address, role, skills and other demographic information which you may optionally fill in on your profile.

Legal basis: Legitimate interest

Storage time: Up to 1 year

* What is a legitimate interest?

Data controller’s (that is: our) processing of data must be based on one of six so-called legal bases. At least one of the six legal bases is required in order for us to lawfully collect, use, and store your data.

We base some of our processing to a legal base of legitimate interest. This means that our interest in processing your data must outweigh your interest for us not to process your data.

Our legitimate interest is to make Zerophase service and our contractual relationships work with you and your employer, which is why we need to process data. The data we process based on legitimate interest include your contact details and communications. Without these our provision and your use of Zerophase would become very difficult. Without these we couldn’t, for example, deliver you the Zerophase Q&A messaging or deliver activities such as quizzes, feedback, and coaching activities that you have requested. That is why we believe our processing of your data is reasonable and justified.

You can, however, object to our processing of your data that we base on legitimate interest if you think it’s not necessary or justified. Please let us know if this is the case at privacy@zerophase.ai and we will consider your request.

3. Your rights and options

You have the following rights on the info that we hold on you or that any third party we've shared your data with holds on you. You may request that:

• we send you a copy of all the data

• we delete of all your data.

• we correct any incorrect data.

• we transfer your data directly to another company or entity*

• we cease some processing of your data (right to object)

• we restrict the processing of data e.g. if you need the data kept as evidence for a legal claim.

• You may object to processing for direct marketing purposes.

• You may revoke your consent at any time, in which case we will seize any further processing of your data and erase it, unless we have a justified reason or legal obligation to keep them.

*Which we will do if feasible with reasonable efforts. Please note, that this ‘right of portability’ applies only to the data you have provided to us yourself, and thus may not apply to all the data we have about you.

If you would like to exercise these rights or revoke your consent (if applicable), please send an e-mail to privacy@zerophase.ai. We aim to fulfill these requests within 30 days.

After a data deletion request has been fulfilled, your data may survive in backups for some time.

4. Transfers of Personal Data outside Australia

Even if you are located in Australia, your personal information may be processed outside of it. In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the Office of the Australian Privacy Commissioner. We have taken all necessary steps to ensure that your data is treated securely and in accordance with the full extent of your rights.