DATA PRIVACY NOTICE

This Data Privacy Notice explains how Panalitix Global Ltd, Panalitix Pty Ltd, Panalitix UK Limited, Panalitix USA Inc., and Panalitix Technology Solutions Pty Ltd (“Panalitix” or “we”), process the personal data collected through Panalitix.com and all associated technology platforms (“Application”) in accordance with the EU General Data Protection Regulation.

Who is responsible for Your personal data?

We, Panalitix Pty Ltd (ACN 600 462 155) of 59 Doggett St, Newstead, Queensland, 4006, Australia, Panalitix UK Limited of 69 Hanover St, Liverpool, L1 3DY, United Kingdom and Panalitix USA Inc. of 8885 Rio San Diego Dr. Suite 370, San Diego, California, 92108, United States of America (“Panalitix”) will be the responsible controller for any personal data You provide to us in connection to the information collected through the Panalitix Application.

In addition, other Panalitix affiliates may control Your personal data to the extent we are required or permitted by law to share Your personal data with them for the purposes described below. Please click here for a list of the Panalitix Affiliates and Sub-Processors.

By accessing the Panalitix application or otherwise using any part of the service, You acknowledge that You have read and understood this data privacy notice

Which categories of personal data does Panalitix collect?

When You register or login and use the Application, the following categories of personal data will usually be collected and processed:

• Private or work contact information, such as full name, address, telephone number, mobile phone number, fax number and email address
• Device and Technical Data, such as the type of mobile device You use, Your mobile devices unique device ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browsers You use, and information about the way You use the Application
• Payment data, such as data necessary for processing payments, including credit/debit card numbers, security code numbers and other related billing information
• Further business information such as orders placed, purchases, services and other business activities, product feedback, surveys and any other information You may provide to us
• Information about Your interests and preferences and other information obtained by analytics tools, in particular Your activities when You use our Applications or products or other services we offer to You online (such as downloadable contents and e-trainings). This may include information about which content You download, click or view for how often and how long
• Information collected from publicly available resources, such as public social media profile (including LinkedIn profile, Facebook and Twitter name) integrity databases and credit agencies
• Information we are legally required to collect to comply with our legal or regulatory obligations, which may include information about relevant and significant litigation or other legal proceedings against You or a third party related to You and interaction with You which may be relevant for antitrust purposes

Generally, we will not process any special categories of Personal Data. If Panalitix is provided with information that may be classed as ‘Special Category’, it will be strictly used where permitted by law or as far as You have provided Your consent.

For which purposes do we use Your personal data?

We will process Your personal data strictly only for the following purposes (“Permitted Purposes“):

• Planning, performing, managing, and administering Your (or a third party’s to whom You are related) contractual business relationship with Panalitix, e.g., by performing transactions and orders of products or services, processing payments, performing accounting, auditing, billing and collection activities, arranging deliveries, facilitating repairs and providing support services or providing You with other services or things You may have requested
• Providing, maintaining and improving the Application and to enable You the use of the Application
• Maintaining and protecting the security of the Application, our products, services and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities
• Ensuring compliance with our legal and regulatory obligations. This may include sales record keeping obligations for tax or other purposes and sending required notices or other disclosures, compliance screening or recording obligations (e.g., under antitrust laws, export laws, trade sanction and embargo laws or to prevent white-collar or money laundering crimes). In this context we may be required to conduct automated checks of Your contact data or other information You provide about Your identity against applicable sanctioned-party lists and to contact You to confirm Your identity in case of a potential match, to record interaction with You which may be relevant for antitrust purposes and to report to or support investigations by competent supervisory, law enforcement or other public authorities
• Informing You, where permitted in accordance with local laws, within an existing business relationship about Panalitix products or services which are similar or relate to such products and services which have already been purchased or used within that business relationship
• Solving disputes, enforcing our contractual agreements and to establish, exercise or defend legal claims

Where You have expressly given us Your consent or otherwise legally permitted, we may process Your personal data also for the following purposes:

• Communicating with You through the channels You have approved to keep You up to date on the latest announcements, special offers and other information about Panalitix’s products, applications, technologies and services (including marketing-related newsletters) as well as events and projects of Panalitix
• Administrating and performing customer surveys, marketing campaigns, market analysis, or other promotional activities or events
• Profiling and automated processing: Collecting information about Your preferences on the basis of Your activities when You use our Application and any products or services we offer to You online (such as e-learning, seminars, etc.). On the basis of this information (e.g., which content is downloaded, clicked or viewed for how often and how long), we create a user profile to personalize and foster the quality of our communication and interaction with You (for example, by way of newsletter tracking or website analytics). The logic behind our profiling activities is to identify areas which may be useful or otherwise of interest for You and to inform You about such areas in a more effective and targeted way. The algorithms used apply this logic and automatically deliver the targeted content or information to You.

Where Your explicit permission is required for any marketing-related communication, we will only provide You with such information if You have opted in. You may opt out at any time if You do not want to receive any further marketing-related types of communication from us.

We will not use Your personal data for taking any automated decisions affecting You or creating profiles other than described above.

The legal basis for processing of Your personal data are set forth in Article 6 of the European General Data Protection Regulation. Depending on the above purposes for which we use Your personal data, the processing is either necessary for the performance of a contract or other business agreement with Panalitix or for compliance with our legal obligations or for purposes of legitimate interests pursued by us or a third party, always provided that such interests are not overridden by Your interests or fundamental rights and freedoms. In addition, the processing may be based on Your consent where You have expressly given that to us.

How do we collect and use personal data?

Panalitix will typically collect Your personal data directly from You when You register to the Application, when You interact with us, (e.g, when You use our Application), You communicate with us in relation to our products and services, request a product or service, register to receive our newsletter, register to become a member of the Panalitix Community or other specific marketing material or participate in our customer surveys and webinars).

Where You have expressly given Your consent, we may also obtain Your personal data from third parties for marketing purposes. In such cases, You will be informed about this in accordance with applicable law.

We automatically collect certain types of usage information when You access or use the Application, including cookies and similar tracking technologies, such as tracking pixels and web beacons. Our use of cookies and other tracking technologies is discussed in more detail in our Privacy Policy. In our Privacy Policy we also explain how You can opt-out from the use of Cookies and to prevent the collection of such data.

Where do we process personal data?

Panalitix is a globally active enterprise. In the course of our business activities, we may transfer Your personal data also to recipients in countries outside of the European Economic Area (“third countries”), in which applicable laws do not offer the same level of data protection as the laws of Your home country. When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of Your personal data, in particular by entering into the EU Standard Contractual Clauses, the clauses are available here.

You may contact us anytime using the contact details below if You would like further information on such safeguards.

How do we protect your personal data?

We maintain physical, electronic and procedural safeguards in accordance with the technical state of the art and legal data protection requirements to protect Your personal data from unauthorized access or intrusion. These safeguards include implementing specific technologies and procedures designed to protect Your privacy, such as secure servers, firewalls and SSL encryption. We will at all times strictly comply with applicable laws and regulations regarding the confidentiality and security of personal data.

With whom do we share your personal data?

We may share Your personal data as follows:

• With our affiliates or within the global Panalitix offices if and to the extent required for the Permitted Purposes and legally permitted. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Data Privacy Notice. Please click here [link to Affiliates list in Privacy Policy] for a list of the PPL Group affiliates with contact details.
• We may also instruct service providers (so called data processors) within or outside of Panalitix, domestically or abroad, e.g., shared service centers or cloud providers, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Panalitix will retain control over and will remain fully responsible for Your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of Your personal data when engaging such service providers.
• With courts, regulators, law enforcement or other competent authorities or attorneys if legally permitted and necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims. With credit reference agencies and other companies for use in credit decisions, for fraud prevention and to collect debts.
• With Any prospective buyer in the event we sell any part of our business or assets.

Otherwise, we will only disclose Your personal data when You direct or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or when we suspect fraudulent or criminal activities.

How long do we store personal data?

We will hold Your personal data for as long as You use the Application required to provide You with the products or services or information You have requested. Some personal data may also be kept to execute and administer a business relationship with You or assist with future Panalitix services and product development. If You have asked us not to communicate with You, Panalitix will only retain information for as long as required to comply with Your request. Panalitix in some instance, may be required to retain certain personal data (e.g., relating to business or tax relevant transactions) for certain retention periods under applicable law. Your personal data will be promptly deleted when it is no longer required for these purposes.

Your data protection rights

Subject to certain legal conditions, You may request access to, rectification, erasure or restriction of processing of Your personal data. You may also object to processing or request data portability. In particular You have the right to request a copy of the personal data that we hold about You. Panalitix reserves the right to on charge any incurred administrative costs that may arise as a result of manifestly unfounded, or repeated or excessive requests to any Personal Data held. Please refer to Articles 15-22 of the EU General Data Protection Regulation for details on Your data protection rights.

If You have given us Your consent for the processing of Your personal data, You may withdraw Your consent at any time with future effect, i.e. the withdrawal of the consent does not affect the lawfulness of processing based on the consent before its withdrawal. If You withdraw Your consent, we will only continue processing Your personal information where there is another legal ground or where we are legally required to do so.

For any of the above requests, please email info@panalitix.com as detailed below, a description of Your personal data concerned stating Your Full Name, Firm Name, Job Title and Proof of any business registrations (e.g. ABN / ACN, Tax ID number, Company Registration, etc.) from a verifiable company email or on a company letterhead as proof of identity. We may require additional proof of identity to protect Your personal data against unauthorized access. We will carefully consider Your request and may discuss with You how it can best be fulfilled.

If You have any concerns about how Your personal data is handled by us or wish to raise a complaint on how we have handled Your personal data, You can contact us at the contact details below to have the matter investigated. If You are not satisfied with our response or believe we are processing Your personal data not in accordance with the law You can complain to the competent data protection supervisory authority in Your country. You may approach either the supervisory authority, which is locally competent for You, or the supervisory authority, which is locally competent for us.

Are you required to provide personal data?

As a general principle, You will provide us with Your personal data entirely voluntary; there are generally no detrimental effects on You if You choose not to consent or to provide personal data. However, there are circumstances in which the Application or connected web services cannot take action without certain elements of Your personal data, for example some personal data is required to process Your orders, provide You with access to application tools, access to e-learnings, newsletters or to carry out a legally required compliance screening. In these cases, it will unfortunately not be possible for Panalitix to provide You with what You request without certain personal data.

What if I am under 16 years of age?

If You are under 16, please make sure that You obtain Your parent/guardian’s permission prior to providing us with any of Your personal data. Persons under the age of 16 are not permitted to provide us with their personal data without such consent.

Updates of this data privacy policy

This Data Privacy Notice was last updated on 1 January 2022. From time to time, we may make changes or amend it as required to reflect any changes to the way in which we use Your personal data or changing legal requirements. So You may wish to check back from time to time or whenever You make available personal data to us. Any amended Data Privacy Notice will apply from the date it is posted on our Application.

How to get in touch with us

If You have any questions regarding Your rights or if You have any specific requests relating to Your personal data please contact our data protection officer as follows:

Mr. Colin Dunn
Panalitix Pty Ltd ACN 600 462 155
PO BOX 1339, Fortitude Valley
Brisbane, Queensland, 4005
Email: info@panalitix.com
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