Privacy Policy

1Information We Collect

We do not independently collect personal information from end-users. Instead, we receive personal information provided by our business partners for processing in connection with our integration services and AI Chat Support system:

• Personal Information from Partners: Data such as names, email addresses, phone numbers, or other identifiers of end-users that business partners transmit to us during system integrations or chat interactions.
• Integration and Chat Data: Transcripts, timestamps, feedback, and usage patterns generated from end-user interactions facilitated through integrated systems.
• Technical Data: Device information, IP addresses, browser types, and cookies related to the operation of our platform and services, as provided or generated during integrations.

All such data is processed strictly as instructed by our business partners and only to the extent necessary for delivering our B2B services.

2How We Use Your Information

We use personal information provided by business partners solely to fulfill our role as a service provider and improve our B2B platform:

• To operate integrations and deliver AI Chat Support functionality as directed by our partners.
• To personalize and optimize responses or services based on instructions from business partners.
• To analyze system performance, diagnose issues, and enhance platform reliability for B2B use.
• To comply with contractual obligations to our partners, including any aggregated reporting on usage trends (de-identified where possible).

We do not use personal information for our own independent purposes, such as marketing, without explicit authorization from the relevant business partner.

3Data Sharing and Disclosure

As a B2B service provider, we do not sell, rent, or trade personal information. Data is shared only as necessary and under the direction of our business partners:

• With authorized sub-processors (e.g., cloud hosting providers) bound by data processing agreements ensuring APP compliance.
• Back to the originating business partner upon request or as part of standard service delivery.
• In de-identified or aggregated form for internal analytics, without revealing individual identities.

We may disclose information in limited circumstances, such as when required by Australian law, to protect rights or safety, or with the explicit consent of the business partner. Cross-border disclosures (e.g., to overseas servers) are subject to safeguards under APP 8, including contractual protections equivalent to the APPs.

4Data Security

We implement robust security measures to protect personal information processed on our platform, in line with APP 11, including encryption, access controls, firewalls, and regular vulnerability assessments.

As a processor, we take reasonable steps to ensure sub-processors maintain equivalent protections. In the event of an eligible data breach under the Notifiable Data Breaches scheme, we will promptly notify affected business partners to enable their compliance obligations.

5Data Retention

Personal information is retained only for as long as necessary to fulfill our contractual obligations to business partners or as required by Australian law (APP 11.2).

Upon termination of a partnership or instruction, we securely delete or anonymize data, subject to any legal retention requirements. Business partners may request data return or deletion via their integration agreements.

6Your Privacy Rights

Under the Australian Privacy Act 1988 and APPs, individuals (end-users) have rights including access, correction, and deletion of their personal information. As a processor, we facilitate these rights by:

• Directing requests to the relevant business partner, who controls the data.
• Processing deletion or access instructions from partners promptly.
• Supporting pseudonymity or anonymity where feasible within integrations (APP 2).

End-users should contact the business partner using our services for exercising rights. Complaints can be lodged with the Office of the Australian Information Commissioner (OAIC).

7Cookies and Tracking Technologies

Our B2B platform uses cookies and similar technologies to ensure secure integrations and functionality:

• Maintain session integrity during API calls and data transmissions.
• Analyze platform usage for performance improvements (anonymized).
• Detect and prevent fraud in system integrations.

Cookies are managed via partner configurations. End-users can control them through browser settings, though this may impact integrated service delivery.

8International Data Transfers

Data may be processed or stored on servers outside Australia (e.g., in the US or EU) to support global B2B operations.

Pursuant to APP 8, we ensure overseas recipients provide comparable protections through binding contracts, adequacy decisions, or other safeguards. Business partners are notified of transfer locations in our data processing agreements.

9Children’s Privacy

Our B2B services are intended for business integrations and not directed at children under 16. We do not knowingly process personal information from children. If informed of such data, we will delete it promptly and notify the relevant business partner.

Business partners are responsible for ensuring compliance with children's privacy where their end-users include minors.

10Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, integrations, or legal requirements under the Privacy Act.

Material changes will be communicated to business partners via email or in-app notifications, with the updated policy posted here including a revised effective date.

We recommend partners review this policy periodically, especially when integrating or renewing services.

11How to Contact Us

For questions about data processing, integration agreements, or this Privacy Policy, business partners should contact us:

End-users with privacy concerns should direct inquiries to the WagerLink business partner facilitating their interaction.