Effective date: September 20, 2018

Tech Strategies (“us”, “we”, or “our”) operates the https://www.formpa.com
website and the FormPA mobile application (hereinafter referred to as the
“Service”).

This page informs you of our policies regarding the collection, use and
disclosure of personal data when you use our Service and the choices you have
associated with that data.

We use your data to provide and improve the Service. By using the Service, you
agree to the collection and use of information in accordance with this policy.
Unless otherwise defined in this Privacy Policy, the terms used in this
Privacy Policy have the same meanings as in our Terms and Conditions.

DEFINITIONS

Service

Service means the https://www.formpa.com website and the FormPA mobile
application operated by Tech Strategies

Personal Data

Personal Data means data about a living individual who can be identified
from those data (or from those and other information either in our
possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of
the Service or from the Service infrastructure itself (for example, the
duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or
jointly or in common with other persons) determines the purposes for which
and the manner in which any personal information are, or are to be,
processed.

For the purpose of this Privacy Policy, we are a Data Controller of your
Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who
processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process
your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the
subject of Personal Data.

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to
provide and improve our Service to you.

TYPES OF DATA COLLECTED

Personal Data

While using our Service, we may ask you to provide us with certain personally
identifiable information that can be used to contact or identify you
(“Personal Data”). Personally identifiable information may include, but is not
limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or
promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or the instructions provided in any email we
send.

Usage Data

We may also collect information that your browser sends whenever you visit our
Service or when you access the Service by or through a mobile device (“Usage
Data”).

This Usage Data may include information such as your computer’s Internet
Protocol address (e.g. IP address), browser type, browser version, the pages
of our Service that you visit, the time and date of your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data may include
information such as the type of mobile device you use, your mobile device
unique ID, the IP address of your mobile device, your mobile operating system,
the type of mobile Internet browser you use, unique device identifiers and
other diagnostic data.

Location Data

We may use and store information about your location if you give us permission
to do so (“Location Data”). We use this data to provide features of our
Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any
time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our
Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous
unique identifier. Cookies are sent to your browser from a website and stored
on your device. Other tracking technologies are also used such as beacons,
tags and scripts to collect and track information and to improve and analyse
our Service.

You can instruct your browser to refuse all cookies or to indicate when a
cookie is being sent. However, if you do not accept cookies, you may not be
able to use some portions of our Service.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences
  and various settings.
• Security Cookies. We use Security Cookies for security purposes.

USE OF DATA

Tech Strategies uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when
  you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our
  Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about
  other goods, services and events which we offer that are similar to those
  that you have already purchased or enquired about unless you have opted
  not to receive such information

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), Tech Strategies legal basis
for collecting and using the personal information described in this Privacy
Policy depends on the Personal Data we collect and the specific context in
which we collect it.

Tech Strategies may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by
  your rights
• For payment processing purposes
• To comply with the law

RETENTION OF DATA

Tech Strategies will retain your Personal Data only for as long as is
necessary for the purposes set out in this Privacy Policy. We will retain and
use your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply
with applicable laws), resolve disputes and enforce our legal agreements and
policies.

Tech Strategies will also retain Usage Data for internal analysis purposes.
Usage Data is generally retained for a shorter period of time, except when
this data is used to strengthen the security or to improve the functionality
of our Service, or we are legally obligated to retain this data for longer
periods.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and
maintained on — computers located outside of your state, province, country or
other governmental jurisdiction where the data protection laws may differ from
those of your jurisdiction.

If you are located outside Australia and choose to provide information to us,
please note that we transfer the data, including Personal Data, to Australia
and process it there.

Your consent to this Privacy Policy followed by your submission of such
information represents your agreement to that transfer.

Tech Strategies will take all the steps reasonably necessary to ensure that
your data is treated securely and in accordance with this Privacy Policy and
no transfer of your Personal Data will take place to an organisation or a
country unless there are adequate controls in place including the security of
your data and other personal information.

DISCLOSURE OF DATA

Business Transaction

If Tech Strategies is involved in a merger, acquisition or asset sale, your
Personal Data may be transferred. We will provide notice before your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Tech Strategies may be required to disclose your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Legal Requirements

Tech Strategies may disclose your Personal Data in the good faith belief that
such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Tech Strategies
• To prevent or investigate possible wrongdoing in connection with the
  Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

SECURITY OF DATA

The security of your data is important to us but remember that no method of
transmission over the Internet or method of electronic storage is 100% secure.
While we strive to use commercially acceptable means to protect your Personal
Data, we cannot guarantee its absolute security.

OUR POLICY ON “DO NOT TRACK” SIGNALS UNDER THE CALIFORNIA ONLINE PROTECTION ACT (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can
set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings
page of your web browser.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain
data protection rights. Tech Strategies aims to take reasonable steps to allow
you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if
you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you.
  Whenever made possible, you can access, update or request deletion of your
  Personal Data directly within your account settings section. If you are
  unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information
  rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of
  your Personal Data.
• The right of restriction. You have the right to request that we restrict
  the processing of your personal information.
• The right to data portability. You have the right to be provided with a
  copy of the information we have on you in a structured, machine-readable
  and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your
  consent at any time where Tech Strategies relied on your consent to
  process your personal information.

Please note that we may ask you to verify your identity before responding to
such requests.

You have the right to complain to a Data Protection Authority about our
collection and use of your Personal Data. For more information, please contact
your local data protection authority in the European Economic Area (EEA).

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service
(“Service Providers”), provide the Service on our behalf, perform Service-
related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these
tasks on our behalf and are obligated not to disclose or use it for any other
purpose.

ANALYTICS

We may use third-party Service Providers to monitor and analyse the use of our
Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks
and reports website traffic. Google uses the data collected to track and
monitor the use of our Service. This data is shared with other Google
services. Google may use the collected data to contextualise and
personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the
Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en

PAYMENTS

We may provide paid products and/or services within the Service. In that case,
we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is
provided directly to our third-party payment processors whose use of your
personal information is governed by their Privacy Policy. These payment
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
MasterCard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.

The payment processors we work with are:

• Stripe

Their Privacy Policy can be viewed at https://stripe.com/us/privacy

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If
you click a third party link, you will be directed to that third party’s site.
We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone
under the age of 18. If you are a parent or guardian and you are aware that
your Child has provided us with Personal Data, please contact us. If we become
aware that we have collected Personal Data from children without verification
of parental consent, we take steps to remove that information from our
servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any
changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior
to the change becoming effective and update the “effective date” at the top of
this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.

CONTACT US

If you have any questions about this Privacy Policy, please contact us:

• By email: privacy@techstrategies.com.au
• By visiting this page on our website: https://www.formpa.com/contact/