This is the Privacy Policy of Mailtumble Pty. Ltd, ACN 643 443 298 (“we”, “us”, “our” or “MailTumble”). We give our clients software and tools to mask and relay email addresses to better secure and program compliance on how email addresses are used. We have adopted this Privacy Policy to ensure that we have standards in place to protect the information that we collect in the following two categories:

1. Information we receive in connection with our relationship with our clients, such as the email addresses and other information their customers (“End Users”)supply when signing up for the systems or services we offer (“MailTumble”), as well as certain information collected in connection with the transmission of data through our servers; and
2. The normal day-to-day operations of our business and the information collected from visitors to MailTumble’s own website, mailtumble.com.

This PrivacyPolicy follows the standards of the Australian Privacy Principles set by theAustralian Government for the handling of Personal Information under thePrivacy Act 1988 (Cth) (Privacy Act). Each of those two categories has its own section below. Following those sections is a third section containing general information about our privacy practices,GDPR, as well as your opt-out options and details about exercising your rights.This Privacy Policy does not address our clients’ own privacy practices or the privacy practices of any third-party integrations that our clients connect with our platform.

By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

1. Privacy Practices for Information We Receive in Connection with Our Relationship with Our Clients

Information Collected

From an expanding number of clients, we are passed over data to ingest and manage through our MailTumble software and systems. We collect data and allow communications through our platforms and products, but do not govern the use of the data. Our customer’s remain solely responsible for how your data is used. Any additional data we collect around technical deliverability and sending as a function of our systems that we provide to our customers. We also collect statistical data to measure the operations of our systems and dispose of this data within 90 days.

Cookies and Other Technologies:

We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the products and services we provide. You can choose to accept or decline certain cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline certain cookies if you prefer.

Online Analytics:

We may use third-party web analytics services, such as those of Google Analytics. These service providers use cookies and other technologies described in this PrivacyPolicy to help us analyze how users use our website and the PoweredLocal WiFi.The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-OutBrowser Add-ons. A popular option may be found here, however we cannot warrant a third party’s tools, we recommend you do your own research here.

Uses of Information

We use the information described above (sometimes in combination with other information we obtain) for the following purposes:

• For system performance analysis
• For compliance with law, fraud prevention, risk mitigation, resolution of disputes, enforcement of legal terms, and similar purposes
• To otherwise analyze, improve and provide products and services
• For other similar purposes requested or authorized by our clients

Disclosures of Information

We disclose information as described below:

To OurClients. When we collect information for or on behalf of a client, we may share certain information with that client to help our clients learn more about their current customers, and to assist them (or others) in identifying trends ,inferences, affinities or patterns among customers (whether those customers are identified, de-identified or aggregated). We also share anonymized data (e.g.when coffee shops are the busiest) among our clients to assist them in communications and marketing activities (such as to provide content recommendations and optimization, ad targeting, and other promotional activities to you).

Affiliates. We may share information with our affiliates who provide services to us.

To Agents & Contractors. We may share information with third parties that help us operate our business and provide our services, such as contractors that provide us with technology, services, data or content (e.g., a hosting provider).

For Legal Reasons. We may share information when we believe that doing so is appropriate to comply with the law; enforce or apply our agreements; or protect the rights, property, or safety of PoweredLocal, our clients, our employees, or others. This may include exchanging information with other companies and organizations for fraud protection and risk reduction.

Changes in the Structure or Ownership of the Company or its Assets. We may transfer the information we hold in the event we sell or transfer all or a portion of our business or assets (such as in connection with a merger, acquisition, reorganization, dissolution or liquidation) or take steps in anticipation of such a transaction.

Direct Collection by Third Parties. In some cases, we may arrange for a third party to collect information directly from individuals, such as if we help a client install embedded content or tools on their website or app (or when we do this on our own website), such as embedded forms. These third parties may collect information directly. Such providers’ handling of the information is subject to their own privacy policies, terms and practices and is not covered by this Privacy Policy.

Aggregated or De-identified Informations. We may share aggregated or de-identified data without restriction.

At a Client’s Requests. At the request of a client, we may also make additional disclosures of information we hold for that client.

Consent or Legal Permission. We may engage in additional sharing of information with the consent of the individual to whom it pertains or when otherwise permitted by law.

OUR LEGAL BASIS FOR USE OF YOUR INFORMATION

Under applicable laws, we are considered the “data controller” of the personal data we collect through our website. We are a data processor of personal data of end-users provided directly to us by our clients. We are a data controller of all other personal data we obtain in the course of our relationship with our clients, including: (1) information you provide through your use of thePoweredLocal WiFi, including automatically-collected information; and (2)contact or point-of-sale data provided by you directly to us or through our business partners. This means that we are responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears at the end of this Privacy Policy.

The laws of some jurisdictions such as the laws of the European Union require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments: We may use, share, or disclose information to honour our contractual commitments to you. For example, to comply with our Terms of Use.
• With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
• Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, and managing legal issues.
• Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

Opt-out and Privacy Rights

To opt-out of MailTumble please complete the form reach out to us at privacy@mailtumble.app.

For information about opt-out options relating to data collected using cookies and other automated technologies (e.g., for analytics and advertising), please review the hyperlinks in the “Information Collected” part of Section 1 of thisPrivacy Policy, above.

Your LegalRights Under Local Law:

Your local laws (e.g., laws of the E.U.) may permit you to request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct-marketing purposes; (including any direct marketing processing based on profiling)
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation.We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, please contact us as described in the “Contacting Us”section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

How long we keep information

We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.

California Do-Not-Track Disclosure

We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.

California Privacy Rights

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you would like to make such are quest, please contact us using the information provided below.

Updates to this Privacy Policy

We may modify this Privacy Policy from time to time as our business practices and legal requirements evolve. In the event this Privacy Policy is modified, we will provide notice of the change by posting the updated Privacy Policy to mailtubmle.com, and we will include the effective date of the update.

Contacting us

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer at privacy@mailtumble.app.

You also may write to our Privacy Officer at:
Mailtumble Pty. Ltd.
PO Box 83, Prahran, VIC, Australia, 3181