Adora Software Pty Ltd  (ACN  671 450 650) of Level 16/80 Collins Street, South Tower, Melbourne, VIC 3000, Australia (“we”, “us” or “our”) and our operation of the website at www.adora.so (“Website”) is committed to respecting your privacy. This privacy policy sets out how we collect, use, process, store, share and disclose your personal information on our Website (“Privacy Policy”). Please note that if you are an Adora Customer, when you signed up for services, you entered into an agreement with Adora’s Terms and Conditions, which includes obligations in this Privacy Policy.

We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) and the General Data Protection Regulation (EU 2016/679) (the “GDPR”), the California Consumer Privacy Act (“CCPA”) and other relevant laws pertaining to privacy of individuals in jurisdictions which our Website and services are available (collectively, “Privacy Laws”).  We are a data controller for the purposes of the GDPR. We ensure that we will take all necessary and reasonable steps to comply with the relevant Privacy Laws and to deal with inquiries or complaints from individuals about compliance with the relevant Privacy Laws.

By accessing and using our Website, products and services, you freely and expressly consent to the collection, use, processing, storage and disclosure of personal information by us as set out in this Privacy Policy.

1. What Information is Collected by Adora?

Personal information is any information relating, directly or indirectly, to an identified or identifiable natural person (“Personal Information”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

The type of Personal Information we collect from you includes, without limitation, the following:

• Identification and contact details: your full name, mailing address, email address, telephone number(s), date of birth, gender, profession, role and place of work.

• Billing Information: credit or debit card information and your ABN.

• Traffic Information: your device ID, device type, geo-location information, computer and connection information, screen resolution, site usage, session information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information.

• Product Information: details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries.

• Provided Information: any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website, software, app or online presence or through other websites or accounts from which you permit us to collect information, such as related social media sites.
  • This will include all information, data, documents or records which are uploaded or utilised in using Adora.

• User Content: any information which you publicly post to Adora or social media sites via the software or app.

• Survey/feedback information: information you provide to us through customer surveys or requests for feedback.

• Biographical information: information provided when you inquire about or apply for a position with Adora.

• any other Personal Information that may be required in order to facilitate your dealings with us.

2. How Do We Collect Your Personal Information?

We will collect Personal Information only by lawful and fair means and never in an unreasonably intrusive way. Generally, we will collect your Personal Information:

• directly from you, where you provide information to us or interact with us;

• automatically in the course of using our Website, software or app; and

• from our business partners or other third-party sources that provide consumer data, such as information about your interests, demographic information and marketing details.

If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our Website, do not sign into it or provide any information that might identify you.

We require individuals to provide accurate, up to date and complete Personal Information at the time it is collected.

3. What Personal Information Does Adora Collect from End Users?

This section applies to the Personal Information collected from persons who use websites, software or products integrated with Adora services (“End Users”).

Where Adora only collects usage details, device information, location information and limited contact information from End Users, such Personal Information is collected and processed pursuant to this Privacy Policy. This encompasses the resources accessed by End Users, the pages they view, the duration of their visits on each page, the method by which they arrived at our customer’s website, the number of visits to our customer’s website, and data generated while interacting with our customer’s website. The latter includes, but is not limited to, mouse movements, clicks, page visits, text input, time spent on each page, and other specifics regarding their actions while navigating our customer’s website.

Otherwise, this Privacy Policy does not apply to End Users of a platform that has integrated the Adora services. Instead, the privacy policy of the third-party platform will apply to you.

Any requests for information made by End Users should be directed to the relevant Adora customer platform and will not be responded to by Adora.

Adora applies this Privacy Policy consistently to all individuals who interact with our site, irrespective of their browser’s Do Not Track settings. As such, we are not required to alter our data collection practices based on an individual browser’s Do Not Track preferences.

4. We Don’t Want Sensitive Personal Information.

We will not collect sensitive Personal Information or special categories of Personal Information (as defined under the relevant Privacy Laws) from you. We ask that you do not send us, or do not disclose, any sensitive personally identifiable information (such as information related to racial or ethnic origin, sex life or sexual orientation, political opinions, religious or other beliefs, genetic or biometric data, health criminal background or trade union membership) on or through the Website, our software or otherwise. If you do provide any sensitive Personal Information, we will require that you provide express consent to us collecting that information as part of you using our services.

5. Information About Minors

Our Website and services are not intended for users under the age of 18. We acknowledge that the definition of a “minor” changes between jurisdictions, however we do not knowingly or intentionally seek or collect Personal Information from any children below the age of 18 years. Any Personal Information found to have been provided by a user under the age of 18 will be removed as soon as possible, cease the use of that information and deactivate any related account.

6. How Does Adora Use Your Personal Information?

We use, process and disclose your Personal Information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):

• providing our Website, products and services to you;

• administering, protecting, improving or optimising our Website, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);

• manage, operate and improve our services and grow our business, including understanding our customer base and the effectiveness of our marketing, events, promotional campaigns and publications, and diagnose or fix technology problems;

• creating industry reports from de-identified data;

• verifying your age;

• billing you for purchasing our products and service;

• informing you about our Website, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us;

• responding to any inquiries or comments that you submit to us;

• verifying your identity;

• assess, recruit and hire staff;

• perform any other function that we believe reasonable and necessary to protect the security or proper functioning of the Adora website or our services;

• any other purpose you have consented to; and

• any use which is required or authorised by a relevant Privacy Law, including detecting, investigating and preventing conduct which may violate our policies, are fraudulent or illegal and protect the rights of Adora, you or others.

Where we:

• have your express consent (which you may withdraw at any time by contacting us in writing at privacy@adora.so);

• have a legal basis; or

• are otherwise permitted by relevant Privacy Laws,

we may use and process your Personal Information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.

At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at privacy@adora.so .

7. Who Adora may need to Disclose your Personal Information.

We may disclose your Personal Information to:

• Service Providers: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 6.

• Analytics: as a part of providing you with, measuring and improving our service, we engage with analytics providers who collect information utilising tracking technologies on our website and software to measure visits and traffic on our Website, our software and app.

• Related Bodies: We may share information with other entities in the Adora corporate group, for purposes consistent with this Privacy Policy.

• Consented Parties: any person or entity to whom you have expressly consented to us disclosing your Personal Information to.

• External Advisors: our external business advisors, auditors, lawyers, insurers and financiers.

• Payment Providers: our payment processing service provider to enable billing transactions.

• Legal: any person or entity to whom we are required or authorised to disclose your Personal Information to in accordance with the relevant Privacy Laws.

Disclosure of your Personal Information to Service Providers

We will only disclose any Personal Information you have provided to any entity outside of the Adora company if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy. This may include, but is not limited to, disclosing information to the following service providers:

• Amazon Web Services ‘AWS’ (Data hosting)

• Clearbit (Marketing data engine)

• Cloudflare (Cloud data hosting)

• GitHub (Open source repositories and internal project management)

• Google Cloud (Data hosting)

• Google Workspace (Internal collaborations)

• Sentry (Error monitoring)

• Slack (Internal communications and platform support)

• Stripe (payment processing)

• Linear (Development task management)

When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to such Recipients. We will take steps reasonably necessary to ensure your Personal Information is treated securely and in accordance with this Privacy Policy. We use reasonable endeavours to ensure that each Recipient receiving your Personal Information is bound by the relevant Privacy Laws (including the standard contractual clauses approved by the European Commission). The standard contractual clauses are available on the European Commission’s Website at https://ec.europa.eu/info/law/law-topic/data-protection_en.

8. How Adora Stores and Protects Your Personal Information

Adora takes all reasonably necessary measures to protect the information we collect through the Website and our services which are stored in either electronic or hard copy. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information.

However, we cannot guarantee the absolute security of any Personal Information transmitted over the internet and therefore you disclose information and Personal Information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your Personal Information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.

We may disclose your Personal Information to third party recipients such as our payment processing provider Stripe. As at the date of this Privacy Policy, such third party recipients (“Recipients”) are located in countries including the USA, Australia and other countries whose laws may not be recognised by the EU Commission as providing an adequate level of protection to Personal Information.

If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.

9. What Is Our Legal Basis?

We rely on several legal bases to process your Personal Information under the relevant laws, including:

• where it is necessary to provide you with access to, and use of, products, services and websites;

• for our legitimate interests to provide, operate and improve our products, services or Website;

• where you have freely and expressly consented to the processing of your Personal Information by us, which you may withdraw at any time; or

• where we are under a legal obligation to process your Personal Information.

10. Cross-Border Disclosure

We may disclose your personal information to third party recipients located in or outside of the jurisdiction in which Personal Information is provided in order to provide our Website, products and services to you.  As at the date of this Privacy Policy, such third party recipients are located in the USA. It is possible that additional third parties from other countries may be recipients in the future.

We are based in Australia so your data will be processed in Australia and the USA. In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

When entering into a transaction with us you consent to your Personal Information being disclosed or transferred to such third party recipients and you acknowledge and agree that we have no obligation to take such steps as are reasonable in the circumstances to ensure that the information that is transferred or disclosed to the third party recipients will be treated in a manner that is consistent with the Relevant Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by the Recipient of the Relevant Laws.

11. Direct Marketing and Communications

Where we:

• have your express consent (which you may withdraw at any time by contacting us in writing at privacy@adora.so);

• have a legal basis; or

• are otherwise permitted by relevant Privacy Laws,

we may use and process your Personal Information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.

At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at  privacy@adora.so

12. Cookies

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. Some of the information collected by Adora is collected through the use of Cookies, which may be operated by our partners who assist us with marketing activities or providing services to you. You will be able to accept or reject the collection of Cookies by us.

You can delete and refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website.

Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Website.

13. Choices Regarding Your Privacy

You may be provided with choices with how we collect and process your information, including:

• updating your Adora Account Settings which contains your profile information, notification settings and your subscription plan;

• where you no longer wish to receive any marketing or promotional communications from Adora, you can unsubscribe or email us at privacy@adora.so;

• opting out or adjusting preferences for cookies when your device accesses the Website;

• customise your browser settings to disable or reject cookies across the internet. It’s important to note that deleting cookies or declining them in your browser settings might affect the functionality of our Website or services. Specifically, Adora won’t be able to automatically link your anonymous user identity across pages on the same website into sessions.

• If you’re accessing the Services from a mobile device, using your device’s operating system to select options on how it collects and utilises your information for interest-based advertising.

14. Notices Specific to Certain Jurisdictions

We are dedicated to ensuring that individuals in certain jurisdictions have access to their privacy rights as provided by the Privacy Laws of your jurisdiction. We have set out details below dependent on your location.

Adora Users in Australia

You have the right to both ask:

• for access to Personal Information that we hold about you; and

• that we correct Personal Information we hold about you.

If you ask, we must within a reasonable timeframe give you access to your Personal Information and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.

We will notify you in writing and explain our reasons if we refuse to give you access to, or correct, your Personal Information.

Adora Users in California

This section relates to how Adora processes Personal Information under the California Consumer Privacy Act (“CCPA”). For the purposes of the CPA, Adora does not sell your Personal Information for any commercial purposes.

Under the CCPA, Californian residents are given the right to know what type of Personal Information has been collected by Adora about them, and if this Personal Information has been disclosed for purposes set out in this Privacy Policy in the last 12 months.

We set out below the categories of information we collect (utilising terms as defined in the CCPA).

CATEGORY	COLLECTED?	DISCLOSED?
Identifiers This includes names, addresses (both physical and email) personal identifiers (including online, internet protocol addresses, or other similar identifiers.	Yes	Yes
Personal Information categories under the California Customer Records statue (Cal. Civ. Code §1798.80e)  This includes names, signatures, physical characteristics, address, telephone numbers, state identification numbers, education, employment, bank account numbers, credit card number, debit card number.	Yes	Yes
Protected Classification characteristics under Californian or federal law  This includes age, race, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical conditions, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information.Biometric Information  Genetics, physiological behavioural or biological characteristics. Internet or similar network activity  History or search history. Geolocation date Physical location or movements Employment  Current or past employment history. Education Information that is not publicly available as defined in the California Family Education Rights and Privacy Act (20 U.S.C section 1232g, 34 C.F.R, Part 99).	No	No

Californian residents also have specific rights provided by the CCPA set out below:

• a right to access your Personal Information collected, used and disclosed by Adora in the past 12 months;

• a right to request that we move, copy or transmit your Personal Information stored by Adora to another location;

• a right to delete any of your Personal Information collected and stored by Adora, and, by extension, a service provider to Adora;

• a right to correct any of your Personal Information collected and stored by Adora; and

• a right to non-discrimination for the exercise of your privacy rights under the CCPA.

If you are a resident of California and wish to exercise any of your rights under the CCPA, please contact us at privacy@adora.so. California residents maintain the right to exercise the rights given to them under the CCPA.

We ask that when you provide any information to us (a) you provide sufficient information that allows us to reasonably verify you or are an authorised representative of that person; and (b) provide sufficient detail such that we understand and can evaluate your request.

We will always endeavour to respond to you within a reasonable time period after receipt of a request. If we require additional time or have been delayed, we will communicate with you directly. All our communications will be via email and any disclosures we provide will only cover a 12-month period preceding your request. If applicable, any response from us may also provide a reason why we cannot comply with a request.

Adora Users in the European Economic Area

For the purposes of the GDPR, we are a ‘data controller’ of your Personal Information. Under the GDPR, an individual residing in the European Union has enhanced privacy rights, including the right to:

• require us to correct any Personal Information held about you that is inaccurate or incomplete;

• require the deletion of Personal Information concerning you in certain situations;

• data portability for Personal Information you provide to us;

• object or withdraw your consent at any time to the processing of your Personal Information;

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; or

• otherwise restrict our processing of your Personal Information in certain circumstances.

Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.

We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.

If you believe that we hold Personal Information about you that is not accurate, complete or up-to-date, then you may request that your Personal Information be amended.  We will respond to your request to correct your Personal Information within a reasonable timeframe, and you will not be charged a fee for correcting your Personal Information.

If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.

15. Managing or Deleting your Personal Information

In the instance that your account is deleted, you may request the erasure of your personal data by contacting us at privacy@adora.so.

We may retain your Personal Information, for as long as necessary to comply with legal obligations or for the purpose of customer service inquiries. However, any personal information not required for these purposes will be securely deleted within thirty (30) days of your account deletion request.

If you no longer want us to use your Personal Information or to provide you with the services, you can request that we erase your Personal Information and close your Adora account by submitting a request by sending an email to privacy@adora.so

16. Third Party Sites

The Website may contain links to other third party websites including social media networks. This Privacy Policy applies solely to information collected by us on our Website.

17. Contacting Us

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us at privacy@adora.so or send mail to:  Level 16/80 Collins Street, South Tower, Melbourne, VIC 3000, Australia.

18. Notices and Revisions

We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice. Non-material changes and clarifications will take immediate effect, and material changes will take effect 30 days after the posting of the amended Privacy Policy on the Website.

19. Enforcement

We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personally identifiable information that cannot be resolved between us and the individual.

Dated: 24th June 2024