Purpose and Scope

SetupMy Pty. Ltd., including its subsidiaries and affiliates (collectively, "SetupMy," "we," or "us") respects the privacy of its customer data.

This Privacy Policy covers our privacy practices with respect to the collection, use, and disclosure of information obtained in connection with the purchase and use of our mobile software applications (the "Subscription Service") and related support services ("Support Services"), as well as expert services, including professional services, training, and certification (the "Expert Services") that we provide to Customers (defined below). In this Privacy Policy, the Subscription Service, Support Services, and the Expert Services are collectively referred to as the "Service." This Privacy Policy also covers information processed by SetupMy for customer and partner account management purposes (for example, customer address and billing information collected for processing Customer’s purchase of SetupMy’s Service).

This Privacy Policy does not cover a Customer's use or disclosure of any information it stores in the Subscription Service. This Services Policy also does not cover any information or data collected by SetupMy for other purposes outside of the Service. This Privacy Policy also does not cover the use or disclosure of any information stored in the Subscription Service when hosted by the Customer. Please see our Website Privacy Statement for details on our privacy practices with respect to data collected on our websites.

For the purposes of this Privacy Policy:

• “Customer” means the entity that purchases our Service.

• "Customer Data" means the electronic data uploaded into the Subscription Service by or for Customer or its Users.

• “Mobile Applications” means applications downloaded by an authorized user of our hosted software applications to a mobile device.

• “User” means an individual authorized by the Customer to access and use the Subscription Service.

• “Partner” means an entity that sells SetupMy products and services or provides services or technology to SetupMy customers.

How We Obtain Information

As further described below, we collect several types of information from and about our Customers and Partners in the course of providing and supporting our Service. Customers process Customer Data in the normal course of using our Service. Our use and access of Customer Data processed is limited to providing and supporting the Service and in accordance with the definitive agreement between Customer and SetupMy pursuant to which the Customer purchased access to the Subscription Service (the “Customer Agreement”).

We host and process Customer Data at the direction of and pursuant to the instructions of our Customers.  We also collect several types of information from our Customers, including:

• Information and correspondence our Customers and Users submit to us in connection with Expert Services or other requests related to our Service.

• Information we receive from our business partners in connection with use of the Service or in connection with services provided by our business partners, including configuration of the Subscription Service.

• Server logs in support of the Subscription Service.

• Information collected via our Mobile Applications.

We also collect several types of information from about our Customers and partners as a data controller, including:

• General information, including a Customer or Partner’s company name and address, credit card information, and the Customer or Partner representative’s contact information (“General Information”).

• Quantitative data derived from our Customers and Users use of the Subscription Service, for example and without limitation, the number of active roles within a Customer’s instance.  All data collected, used, and disclosed will be in aggregate form only and will not identify Customer or its Users.

How We Use Information 

We may use Customer Data to provide and support the Service, including updating and maintaining the Subscription Service and providing Support and Expert Services. We will not use, disclose, review, share, distribute, transfer, or reference any Customer Data except as permitted in the Customer Agreement or as required by law.

We may use information we collect about our customers and partners for billing and contracting purposes.

How We Share Information Collected

We may disclose personal information that our Customers, Partners, and Users provide to us to the following categories of recipients:

• To our subsidiaries and affiliates (including those located outside the European Economic Area and Switzerland) as necessary to support provision of the Service to the Customer and operate our partner program.

• To our contractors, business partners and service providers we use to support our Service and business partners who provide services on behalf of our Customers.

• To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case personal information held by us about our Customers and Partners will be among the assets transferred to the buyer or acquirer.

• To any competent law enforcement body, regulatory, government agency, court or other third party to: (i) comply with any court order, a request from any competent law enforcement agency, or any other legal obligation; (ii) enforce or apply the terms of the Customer Agreement; (iii) enforce or apply the terms of the agreement for partnership with our Partners; and (iv) protect the rights, property, or safety of SetupMy, our Customers, Users, or others.

• In accordance with Customer instructions.

Security and Breach Notification 

We maintain an information security program designed to protect Customer Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. The Subscription Service allows Customers to implement and configure their use of the platform and enforce their security requirements, including user access controls and encryption. 
SetupMy has a team responsible for monitoring and responding to security incidents. SetupMy notifies Customers of security breaches in accordance with the Customer Agreement.

Retention 

We retain Customer Data according to the time frames set forth in the Customer Agreement. We retain General Information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

Mobile Applications 

We may obtain additional information through Mobile Applications that Customer or their Users download to their mobile device (“Device”). Mobile Applications we provide may obtain or collect information from a User’s Devices in connection with the User’s use of the Subscription Service, and are designed to interoperate with the Subscription Service; for instance, to provide a User with access to information within the Subscription Service or to provide information from a User’s Device to the Subscription Service. 
In order to provide and operate the Mobile Applications, we need certain information from the User, and without that information our Mobile Applications wouldn’t work (or wouldn’t work very well). For example, we ask Users to provide some personal information, such as login credentials to access and use the Subscription Service through the Mobile Applications. In addition to the personal information Users provide, we also collect certain other personal information through the use of our Mobile Applications. For instance, Mobile Applications may use a Device’s geolocation data to provide services available through the Mobile Applications, including to send Users notifications. If a User has geolocation turned on, the Mobile Applications will, from time to time, tell us about a User’s Device’s location even if a User is not directly interacting with the Mobile Application. It may also tell us about a User’s Device location while the User is interacting with the Mobile Application. We may only be able to collect some of this information if the Device settings allow it, so Users should always review our Mobile Applications settings under the Device settings menu to select what information Users are happy for apps like ours to access or not to access. 
Our Mobile Applications may also provide us with information related to a User’s use of the Mobile Applications, including information regarding a User’s Devices and OS identification, language, and time zone. Mobile Applications may also collect information regarding a User’s interaction with Mobile Applications, which SetupMy may use to provide and improve the Mobile Application and Services. We may also obtain information when Users report a problem with our Mobile Applications. In addition, we may use information collected by our Mobile Applications to enforce our rights arising from contracts we enter into with the Customer or with a User. 
To provide this Mobile Application, we work with our group companies and certain partners and service providers who may have access to your information. Information accessed or obtained by the Mobile Application on a User’s Device may be also accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application. We may disclose User’s information to law enforcement, competent government authorities, court and other third parties where we believe are required to do so by applicable law or regulation (including a court order), or where we believe disclosure is necessary to exercise, establish or defend legal rights or to protect the vital interests of any person. If a third party buys all or part of our business or assets, then we may also disclose User information in connection with the sale. Where we do, we will inform the third party that it is required to use User’s information only for the purposes set out in this Privacy Policy. We may also share a User’s personal information to any other person with such User’s consent to the disclosure. In addition to Mobile Applications we provide, third party Mobile Applications may be made available for download to a User’s Devices. The collection and use of information through third-party Mobile Applications (if any) is governed by the applicable privacy notices of such third parties. Contractual terms related to a particular Mobile Application may be found in the End User License Agreement or relevant terms of service for that application.

Your Privacy Rights 

Since each Customer is in control of what information, including any personal information, it collects from its Users, how that information is used and disclosed, and how that information can be changed, Users of the Subscription Service must contact the applicable Customer administrator with any inquiries about how the Customer uses and discloses personal information and how to access, rectify, correct, delete, and port personal information contained in Customer Data as well as object to or restrict the processing of personal information contained in Customer Data.

We provide you with certain choices regarding the General Information you provide to us. In particular:

• To access, correct, update, or request deletion of any personal information Customer or Partner provided us as part of the General Information, please contact your account representative or SetupMy relationship manager or, where possible, use our portals you have access to (for example, our partner portal) to carry out these requests.

• Certain jurisdictions, for example the European Economic Area, provide their residents specific privacy rights under applicable law. We will process requests to exercise such rights, including objection to and restriction of processing and requests for portability of personal information contained in General Information, in accordance with applicable data protection laws. You may send us an email at privacy@setupmy.com.au or using the contact details under the “Contact Us” heading below.

We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfill your request, we may need you to provide certain information to verify your identity.

General

Children's Privacy 

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our systems.

Third Party Services 

We may also provide applications and integrations hosted by third party services (for example, Microsoft Intune) for mutual customers that we have with such third-party service providers. These applications and integrations will interact with the Subscription Service and our collection, use, and disclosure of information will be in accordance with this Services Privacy Statement and our Customer Agreement with the Customer. This Services Privacy Statement does not cover such third-party service stores where we make our applications available. The use of any data you make available to such a third party is subject to that party’s privacy policy and your agreements, if any, with that party.

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Third Party Websites and Applications 

Customers, Partners and other third parties, including our consultants, may develop applications (including Mobile Applications) or provide services to you or other third parties using our Service. This Privacy Policy does not apply to information collected by Customers, our business partners, and other third parties or third-party applications (including Mobile Applications) or services, even if this information is collected using our Service.

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Changes to this Services Privacy Statement 

We reserve the right to update or change this Services Privacy Statement from time to time. If we make material changes to this Privacy Policy, we will notify our Customers through an appropriate online notice (and obtain their consent where required by applicable law). For clarity, any update or change to this Privacy Policy will not change or modify the agreement between SetupMy and Customer.

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Contact Us

We have a Privacy Team that is responsible for the implementation of our global privacy program. If you have questions or comment about this Privacy Policy and our privacy practices or if you are a Customer and need to update, change, or remove information from the Service, please log a ticket through our customer support portal. 

For written inquiries, you may contact us at: 
SetupMy 
1 Norfolk Place, Malvern, VIC 3144

Disclaimer 

SetupMy, a global technology company headquartered in Australia, provides IT managed services, infrastructure solutions, consulting and products to AFR200 companies committed to enhancing their end users’ experience. Founded in 2022, privately held SetupMy counts three of the four pillar banks as customers. For more information, visit www.setupmy.com.au. ©2022 SetupMy Pty Ltd. All rights reserved. Apple and the Apple logo are trademarks of Apple Computer, Inc., registered in the U.S. and other countries. Apple iPad®, iPhone®, iPod® and Mac® are registered trademarks of Apple Inc. IDC is a trademark or registered trademark of International Data Corporation. All other trademarks and product names mentioned herein are the property of their respective owners in Australia, the United States, Canada and other countries.The information contained herein is subject to change without notice. SetupMy shall not be liable for technical or editorial errors or omissions contained herein.The only warranties for SetupMy products and services are set forth in the express warranty statements accompanying such products and services. Nothing herein should be construed as constituting an additional warranty. SetupMy services are governed by the applicable SetupMy terms and conditions of service provided or indicated to Customer at the time of purchase. Customer may have additional statutory rights according to applicable local laws, and such rights are not in any way affected by the SetupMy terms and conditions of service or the SetupMy Limited Warranty provided with your product.