Pronti Co Pty Ltd (ABN 20 684 730 596) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.

For our Australian retailers, customers and drivers Pronti Co Pty Ltd complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) as set out in Schedule 1 of the Act.

For our New Zealand retailers, customers and drivers we comply with the Privacy Act 2020 (NZ) and the 13 Information Privacy Principles in how we collect, use, store, and disclose your personal information.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. The types of personal information we may collect about you include:

·      Identity Data including your full name, age, profession and photographic identification.

·      Contact Data including your telephone number, address and email.

·      Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).

·      Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

·      Technical and Usage Data when you access any of our websites, platforms or emails, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies, tracking pixels or analytics), and communications with our website.

·      Profile Data including your username and password for your Pronti account, profile picture, purchases or orders you have made or completed with us, content, messages and images you post, send, receive and share through our platform, information you have shared with our social media platforms, and support requests you have made.

·      Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.

·      Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

·      Professional data including where you are a driver, a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience, or whether you hold required authorisations or licences.

Drivers

If you are a driver of ours, then we also collect biometrics and criminal history, certain information about your vehicle, perform DVS checks and perform automated processing as follows:

Government data services

·      In applying for a driver account you confirm that you are authorised to provide your identity details to us.

·      We will use your identity details to verify your identity and provide confidence in that verification to our retailers and customers:

    o  If you provide Australian identification, your personal information will be sent to the Australian DVS to match against records held by Commonwealth or state bodies (eg the passport office, your state driver licence authority or another relevant Commonwealth or state body that holds your data);

    o  If you provide New Zealand identification, we may use services such as NCC (National Crime Check) and government-authorised identity verification providers in New Zealand to validate identity documents and confirm the legitimacy of personal information you provide;

    o  Our check to the Australian government or state records will be made via a third party identity verification entity.

·      You will need to give your express consent to the collection, use and disclosure of your personal information that you have provided to us. If you do not consent then we cannot verify your identity and you will not be able to set up a driver account.

·      In respect of the Australian DVS, please note the following:

    o  We will use the Australian DVS to verify your identity matches the records held at Commonwealth or state level;

    o  We must comply with our access agreements with the Attorney General’s office and also the Privacy Act;

    o  Your rights are set out in this Privacy Policy, including the right to access your data, correct inaccurate data, complain about our processing to OAIC and withdraw your consent;

·      You can visit idmatch.com.au for more information about the DVS service.

Biometrics and criminal history

·      We, or our identity verification provider, may use biometric matching services to verify your identity and then to authenticate your identity again. We will only do this with your consent. If you do not consent then you may not be able to complete the verification journey and therefore will not be able to set up a driver account.

·      We will not keep your biometrics for longer than necessary to perform the matching and authentication. We will process your data and biometrics in Australia or New Zealand.

·      We will never transfer or sell your biometric data to anyone else.

·      We will ask for and process your criminal history information. We use this to decide whether you can provide driving services through our platform. In providing this information you consent to our processing of it for this purpose.

Driver information

We also collect your vehicle registration details, vehicle history, drivers licence details and driver history.

Automated Processing

·      Our verification process uses automated processing to verify your identity. The automated decision making includes:

    o  Matching the selfie of your face to the image on any document you provide using biometric matching technology, and then also reauthenticating your identity in the future;

    o  Matching the data you input against the data held by the DVS Service; and

    o  Using the results of any vehicle or criminal data we obtain about you.

·      We will use these automated processes to determine if you can open a driver account.

How we collect personal information

We collect personal information in a variety of ways, including:

·      when you provide it directly to us, including face-to-face, over the phone, over email, or online;

·      when you complete a form, such as registering for any events or newsletters, or responding to surveys;

·      when you use any website we operate (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);

·      from third-party identity verification providers and government-authorised services.We may use services such as NCC (National Crime Check) and the Australian Government’s Document Verification Service (DVS) to validate identity documents and confirm the legitimacy of personal information you provide. This may include matching your ID information with government records, and where required, using biometric tools (such as selfies) to verify your identity; and

·      from publicly available sources.

Why we collect, hold, use and disclose personal information

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

·      to enable you to access and use our application, including to provide you with an account and to create, purchase or deliver orders;

·      to assess whether to take you on as a driver, including to perform identification and authentication, and working rights, vehicle, criminal and other background checks on you (whether by us or through our third-party verification providers);

·      to work with you as a customer or merchant, including to enable the merchant to supply goods to a customer, to be delivered by a driver;

·      to contact and communicate with you about our business, including in response to any support requests you lodge with us or other enquiries you make with us;

·      to contact and communicate with you about any enquiries you make with us via any website we operate;

·      for internal record keeping, administrative, invoicing and billing purposes;

·      for analytics, market research and business development, including to operate and improve our business, associated applications and associated social media platforms;

·      for advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you;

·      to run promotions, competitions and/or offer additional benefits to you;

·      if you have applied for employment with us, to consider your employment application; and

·      to comply with our legal obligations or if otherwise required or authorised by law.

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

·      any purposes you consent to;

·      as necessary to operate the platform and provide services to you;

·      to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and

·      if otherwise required or authorised by law.

Our disclosures of personal information to third parties

·      Personal information: We will only disclose personal information to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information (excluding sensitive information) to:

·      our employees, contractors and/or related entities;

·      IT service providers, data storage, web-hosting and server providers;

·      marketing or advertising providers;

·      where you are a customer, to enable our drivers to identify you as the recipient of the order;

·      where you are a merchant, to enable our drivers to collect orders from you;

·      where you are a driver, to enable merchants or customers to identify you as the delivery driver for their order;

·      where you are a driver, to our third-party verification providers for the purpose of conducting background checks and identity verification;

·      professional advisors, bankers, auditors, our insurers and insurance brokers;

·      payment systems operators or processors;

·      our existing or potential agents or business partners;

·      if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;

·      courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

·      the police or other enforcement bodies if we reasonably suspect that you are using the services to send, receive or transport illegal or restricted goods;

·      courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

·      third parties to collect and process data, such as analytics providers and cookies; and

·      any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

We store your personal information in Australia and New Zealand. We may disclose your personal information to third parties located in the United States (for example, our payment provider).

We take reasonable steps to ensure your personal information is protected in accordance with the Australian Privacy Principles and we will ensure all recipients are contractually bound to protect your personal information. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles and the New Zealand 13 Information Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to work with you as a customer or supplier of our business.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. A reasonable administrative fee may be payable for the provision of such information and we may ask you to prove your identity to us. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner or the Office of the Privacy Commissioner in New Zealand.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

User-Generated Content

We may enable you to post reviews, comments, photos and other user-generated content. Any content you choose to submit will be accessible by anyone, including third parties not associated with us. We have no control over how others may use or misuse information you make publicly available. We are not responsible for the privacy, security or accuracy of any user-generated content you choose to post or for the use or misuse of that information by any third parties.

Cookies and Analytics

We may use cookies, tracking pixels and similar technologies on our website and in our emails from time to time. Cookies are text files placed in your computer's browser to store your preferences. Tracking pixels are tiny, invisible images (typically the size of one pixel) embedded in web pages or emails. Cookies and tracking pixels, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie or collected by tracking pixels. Unlike cookies, tracking pixels do not store any information on your device, but instead send information to our servers when the pixel is loaded.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

You can block tracking pixels by using ad-blocking or privacy-focused browser extensions. Some email providers allow you to block images by default, which can prevent tracking pixels in emails from loading.

However, if you use your browser settings to block all cookies (including essential cookies) and tracking pixels you may not be able to access all or parts of our website and you may not receive personalised content.

·      Google Analytics: We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

·      You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

·      To find out how Google uses data when you use third party websites or applications, please see here.

Facebook/Meta Analytics: We may use tools provided by Meta, such as the Meta Pixel, advanced matching, and Conversions API. These allow us to measure ad performance and deliver ads that may be relevant to you on Meta platforms based on your activity on our website/app. You can control whether we can join data from third party partners with your Meta account for ads by adjusting your preferences within Meta's settings. You can disconnect this data from your Meta account by changing your settings for Off-Facebook activity. For more information, please see Meta's Privacy Policy here.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from single sign-on accounts

If you connect your account with us using a single sign-on account, such as Apple, Meta or Google, we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.

We use the personal information we receive from the single sign-on provider to create a profile for you on our platform.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Use of location services data

·      With your consent, we collect your precise or approximate location via our mobile application for the following purposes:

·      to enable drivers to pick up deliveries and to deliver them to our client’s customers;

·      to generate routes and improve routes via the data collected;

·      to allow the warehouse to monitor the vehicle location within their account dashboard;

·      to allow our users (customers or retailers) to access order location in real time;

·      for security and safety;

·      to prevent and detect fraud; and

·      as permitted by law.

·      We collect this information when an order is made via our platform. If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide geolocation data to us, it may affect our ability to work with you as a customer or supplier of our business.

Use of Artificial Intelligence (AI)

Overview: We may use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations and the provision of our Services. We will only use AI Technologies when legally permitted and necessary for our business operations.

How we use AI Technologies: We may use AI Technologies to assist with customer support and queries, to analyse use of the platform (using non-identifiable data only) and to improve our services (again, using non-identifiable data only).

Data Protection and Security: Where we use service providers who provide AI Technologies to us, we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.

We may input your personal information into platforms provided by AI Technology service providers which may then be used to train the service provider’s AI Technologies model based on that information.

Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this privacy policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:

●      Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon; and

●      Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability; and

●      Risk mitigation: We regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.