Privacy Policy

1. Introduction

Innocr Pty Ltd ABN [TBD] ("Innocr", "we", "us", or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, and disclose your personal information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act"), the Australian Privacy Principles (APPs), and other applicable Australian privacy laws.

This Privacy Policy applies to all personal information collected through our website (innocr.au), our stored value wallet solution, mobile applications, and any related services we provide.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Identity information: Full name, date of birth, gender
• Contact information: Email address, phone number, postal address
• Business information: Company name, ABN, industry type, business size
• Financial information: Payment details, transaction history, wallet balances
• Technical information: IP address, browser type, device information, operating system
• Usage information: How you use our services, preferences, interaction data
• Location information: General location data for fraud prevention and service optimization

2.2 Sensitive Information

We generally do not collect sensitive information as defined under the Privacy Act. If we need to collect sensitive information, we will obtain your explicit consent and explain why the information is needed.

2.3 How We Collect Information

We collect personal information through:

• Direct collection when you register for our services
• Forms submitted through our website or applications
• Customer service interactions
• Automated collection through cookies and similar technologies
• Third-party service providers (with your consent)
• Publicly available sources where permitted by law

3. How We Use Your Information

We use your personal information for the following purposes:

• Providing and maintaining our stored value wallet services
• Processing transactions and managing customer accounts
• Customer support and service improvement
• Fraud prevention and security monitoring
• Compliance with legal and regulatory requirements
• Marketing and promotional communications (with your consent)
• Analytics and business intelligence to improve our services
• Developing new features and services
• Conducting research and analysis for business purposes

4. Information Disclosure and Sharing

4.1 When We Share Information

We may disclose your personal information to:

• Service providers and contractors who assist in our operations
• Payment processors and financial institutions
• Legal and regulatory authorities when required by law
• Professional advisors (lawyers, accountants, auditors)
• Business partners (with your explicit consent)
• New owners in the event of a business sale or merger

4.2 Overseas Disclosure

We may disclose personal information to overseas recipients, including cloud service providers. Countries may include the United States, Singapore, and European Union member states. We ensure appropriate safeguards are in place to protect your information in accordance with Australian privacy law.

5. Data Security and Storage

We implement robust security measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Multi-factor authentication systems
• Regular security audits and penetration testing
• Employee training on data protection
• Secure data centers with physical access controls
• Regular backup and disaster recovery procedures

We retain personal information only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. When information is no longer needed, we securely destroy or de-identify it.

6. Your Rights and Choices

Under Australian privacy law, you have the right to:

• Access: Request access to your personal information we hold
• Correction: Request correction of inaccurate or outdated information
• Deletion: Request deletion of your personal information (subject to legal requirements)
• Portability: Request a copy of your data in a portable format
• Opt-out: Unsubscribe from marketing communications
• Complaint: Make a complaint about our handling of your personal information

To exercise these rights, please contact us using the details provided in Section 9. We will respond to your request within 30 days or as otherwise required by law.

7. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your experience and analyze usage patterns. Types of cookies we use include:

• Essential cookies: Required for basic website functionality
• Analytics cookies: Help us understand how visitors use our website
• Marketing cookies: Used to deliver relevant advertisements
• Preference cookies: Remember your settings and preferences

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect website functionality.

8. GDPR Compliance for International Users

For users located in the European Union, we comply with the General Data Protection Regulation (GDPR). In addition to the rights outlined above, you have the right to:

• Data portability in a machine-readable format
• Object to processing based on legitimate interests
• Restrict processing in certain circumstances
• Lodge a complaint with your local data protection authority

Our lawful basis for processing includes contract performance, legal compliance, legitimate interests, and consent where explicitly obtained.

9. Contact Information and Complaints

If you have any questions about this Privacy Policy or wish to make a complaint about our handling of your personal information, please contact us:

We will investigate any complaints and respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending email notifications to registered users
• Displaying prominent notices on our platform

The updated policy will be effective from the date specified in the "Last Updated" section. Your continued use of our services after the effective date constitutes acceptance of the updated policy.

11. Definitions

• Personal Information: Information or opinion about an identified individual or an individual who is reasonably identifiable
• Sensitive Information: Information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal records, health information, biometric or genetic information
• Australian Privacy Principles (APPs): Privacy standards set out in the Privacy Act 1988 (Cth)
• Data Controller: The entity that determines the purposes and means of processing personal data
• Data Processor: The entity that processes personal data on behalf of the data controller