Privacy Policy Highlights

SaleFish Inc. knows that your privacy is important. This SaleFish Inc. Privacy Policy (“Privacy Policy”) describes the personal information we and our affiliates (including SaleFish Australia Pty Ltd., ABN 76 639 484 610 of 215/566 St. Kilda Rd Melbourne 3004 Victoria Australia) (collectively “SaleFish”, “we”, “our”, “us”), collect from and about users of and visitors to our websites and portals (“you”, “your” or “user”) including salefishsoftware.com or our SaleFish Online Global Marketplace or SaleFish Online Private Marketplace (such as provided at salefishonline.com/[●]) (collectively, the “Websites”). This Privacy Policy describes how the personal information is used, processed and shared. This Privacy Policy applies to any personal information collected about you by SaleFish when you use any of the following (collectively, the “Services”): (i) use any website, mobile or tablet application, or other online service or platform of the SaleFish Inc. brand including the Websites and this Privacy Policy sets out our privacy practices that apply to our interactions with you on third party platforms (such as social media).

In this Privacy Policy, when we use the term “Personal Information”, we mean as that term is defined under the Australian Privacy Act 1988 (Cth) which is “information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.” Some of this Personal Information may be “sensitive information” as defined under the Australian Privacy Act 1988 (Cth) (such as health information, biometric information (such as a picture of your face), credit information or information or opinion about an individual's racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, or genetic information).

your agreement to this Privacy Policy is a condition of use of our Services or Websites. If you do not agree to this Privacy Policy, please stop use of the Services or our Websites.

Types of Personal Information We Collect

We collect various types of Personal Information about you or our other users in connection with the Services, including:

• Personal Information you provide to us;
• Personal Information we collect about your use of our Services and Websites; and
• Personal Information we obtain from publicly available or third-party sources.

We also may collect Personal information in ways that we describe to you at the point of collection or otherwise with your consent.

The types of Personal Information that we collect and process about you will depend on our relationship with you. It will include some or all of the following:

• General information about you: your name, title, gender, date of birth, contact details, passport, or other identification details (which may include your image) and your answer to a security question (for example, your favourite colour);
• Contact details: such as phone number, address, email address, and social media handle;
• Transaction interests, history, and details: such as real estate inventory, real estate purchases or sales, real estate preferences, and inspection requests;
• Biometric data (which is sensitive information): such as a picture of your face, a selfie and a liveness check based on that so we can verify your identity);
• Payment details: such as credit or debit card number and expiry date;
• Your use of our products and services: such as use of our systems and your previous transactions with us;
• Our interactions with you: such as any feedback, complaints, compliments, claims you have made, responses to market surveys, records of any correspondence and interactions with us and our staff (including in person, online, by telephone or email and via social media);
• Your interests: such as real estate you have bought, sold or expressed an interest in or attempted to buy or sell;
• Website and mobile apps: if you use our Website or mobile applications, your geolocation, IP address, mobile telephone number or ID, and details of how you use the website or app and any third party sites that you have accessed from them;
• Employment information: if you are an employee or applicant or obtaining products or services in relation to one of our corporate, business or government customers, certain information about your employment or relationship with our customers such as your employer’s name, your employee number, your professional title and your work contact information;
• Information used to prevent and detect fraud: an assessment of whether your transaction is potentially fraudulent, including the historical and other information used by our service providers to make this assessment;
• Certain aspects of your Personal Information, for example details of your transaction or identity documentation, payment details and contact information, are required for many of our products and services and if you fail to supply such information as requested for specific services, we may be unable to provide you with the products and services in full.

How We Use Personal Information

We use the Personal Information we collect to, among other things:

• Register and create your account with us or the accounts of others who are authorized by you to transact through your account;
• Provide and manage the inventory of real estate and Services you request;
• Communicate with you about our third-party customers (sellers’ and vendors’ and agents’) inventory, programs, services, and promotions;
• Deliver targeted real estate inventory, advertising, promotions, and offers; and
• Understand you and our customers so that we can develop and improve our customer service, promotions, inventory, programs, and Services.

We may otherwise use your Personal Information with your consent or at your direction. We use your Personal Information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities, and we generally do not give it to government agencies, private sector organisations or anyone else unless one of the following applies:

• the individual has consented;
• the individual would reasonably expect, or has been told, that information of that kind is usually passed to those individuals, bodies or agencies;
• it is otherwise required or authorised by applicable law;
• it will prevent or lessen a serious and imminent threat to somebody's life or health;
• it is reasonably necessary for the enforcement of the criminal law or of an applicable law imposing a pecuniary penalty, or for the protection of public revenue.

Digital Identity Verification

You agree that we can collect your Personal Information (which may include biometric data such as a picture of your face or identity documents with your face on it and a liveness check) so that you can be provided with our identity checking services, facilitated through our digital identity verification service provider. Without this information, your identity documents cannot be validated, and our Services cannot be provided.

You acknowledge that information about your identity documents that you provide may be given to identity verifiers such as the Australian government and other issuing authorities to confirm whether it matches information held by the authority or entity that issued the identity document. You agree that the identity verifiers can give us information about whether there is a match, and that we can use that match information in providing our identity checking services. If we offer checking of an identity document issued overseas and you provide such a document in connection with the identity verification service, you agree that information may be transferred internationally for the purpose of this identity checking process, and that we may use third party systems and services as we engage with government identity verifiers.

We may hold some information about Australian and non-Australian residents as a result of the provision of our Services. We may use this information to assist in checking details of information about your identity and/ or complete a verification check. Details checked in this way may be disclosed to participating organisations who access the digital identity verification services with your consent to authenticate your identity and/ or complete a verification check.

By registering a profile, you agree that we may link some details of this information to your profile, which helps us keep your registered information up to date.

We will disclose your information to some other third-party identity verifiers to assist in the administration of the digital identity verification service and in order to verify your details, and may collect some Personal Information from them.

Where you have consented to have your identity checked for an organisation, we provide to the organisation some Personal Information that has been checked, which may include your name, address, email address and date of birth, and whether a match has been confirmed by government identity verifiers. We may provide to the organisation copies of identity documents, identification numbers used on these documents, or details of the authentication sources used to check your identity, where we have your express consent. If we reasonably believe that any information provided to an organisation was or has become incorrect, misleading or out-of-date, we may inform the organisation and provide corrections or details of our concerns. You should check the privacy policy for each organisation before you agree for us to provide the organisation with information about your identity.

In cases where the identity checking process needs to be completed in person, we may retain the information you provided through the Websites, including your Personal Information, for a limited period to allow you time to complete the process. If you do not complete the process within the timeframe we specify, we will discard the information you provided. If you continue the process:

• your information may be disclosed to the SaleFish representative you deal with;
• information you provide to the SaleFish representative may be collected and processed as part of the digital identity verification service; and
• the information received or collected by the representative may be stored for processing and auditing purposes.

Where we check an identity document, we may retain your Personal Information and details from the identity document as well as details of the check we performed and the result of the check for audit and assurance purposes. We do not store images of identity documents.

If you register a profile:

• we may store some information, including your name, date of birth, email address and address, and identity document numbers, in an encrypted form and will only use or share them with Your express consent in connection with your future use of digital identity verification services; and
• we may also store other Personal Information, information about the types of identity document you have checked with us and information collected from identity verifiers for your future use of the digital identity verification services.

You consent to us creating a biometric template from the data collected from the digital identity verification service. For example, we may use biometric templates to verify your profile image by comparing it with other images.

If following registering a profile, when checking an identity document, we will also retain a record of your Personal Information and details from the identity document you provided us to carry out the check (such as identity document numbers, your date of birth), so that you can access this information at a later date. You acknowledge and agree that the Personal Information you supplied to us to carry out a point in time identification verification was validated against sources that are not controlled by us. If the details of your identity documents have changed from the Personal Information you supplied to us when the check was fulfilled, and you wish to correct any details, You should engage directly with the custodians of that information (for example, VicRoads).

Your information will be used to check your identity for an organisation only with your consent. You may give the consent to us through the digital identity verification service via the Websites, or directly to another organisation. If you do not use the digital identity verification service to check your identity to any organisation for an extended period, the information stored in your profile may be deleted.

You hereby authorise us to disclose the information we hold about you and grant access to your profile to law enforcement and government authorities and agencies in accordance with their lawful requests.

Your biometric information (such as a picture of your face) will be collected and handled securely, and for the purpose of checking your identity or facilitating that checking process and our provision of the Services.

Sharing of Personal Information

We may share your Personal Information with:

• Business partners, service providers, and social media services;
• Companies that provide content, advertising, or functionality; and
• Other parties when required or permitted by law, as necessary to protect our users, affiliate, or customers or in connection with a corporate transaction or sale of our business or assets.

We may use or provide aggregated information, and data with personal identifiers removed, to third parties to describe how our customers and users are using the Services. We also may share Personal Information about you with third parties whenever you consent to or direct such sharing.

Online Advertising and Cookies

We and other companies that provide advertising and other services on our Services use cookies, web beacons, do-not-track signals, and similar technologies to improve and customize your advertisements and your experience using our Services.

Privacy and Access Choices Available to You

You are able to manage the privacy and access choices available to you. For example, you may block cookies and similar technologies, opt out of receiving certain targeting real estate inventory, advertising, and opt out of receiving commercial communications. In some circumstances, you also may have a right to access, update, and correct inaccuracies in your Personal Information. You can change your cookie preferences at any time. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit About Cookies or All About Cookies. To opt out of being tracked by Google Analytics across all websites, visit Google Analytics.

Data Security and Other Important Information

SaleFish Inc. is certified for Cyber Security by Cyber Essentials Canada (CEC). Cyber Essentials aims to be one of the most comprehensive annual third-party cyber certification process for business in the world today. For more information about the certification visit Cyber Essential Canada.

Information You Provide to Us

We collect information you give us when you use the Services. For example, when you visit one of our Websites or use one of our Services, create an account with us, participate in a survey or promotion, we may ask for Personal Information such as your name, e-mail address, year of birth, birthday, gender, street address, or mobile phone number, identity details so that we can provide Services to you or verify your identity. We may collect payment information, such as your credit card number, security code and expiration date, to process a financial transaction you have requested. We also may collect Personal Information about the real estate you browse, sell or purchase, including what, where and how frequently you browse, sell or purchase.

Information About Your Use of the Services

In addition to the information, you provide to us directly, we may collect Personal Information about your use of the Services. For example, we may collect:

• Device Information - such as your hardware model, IP address, other unique device identifiers, operating system version, and settings of the device you use to access the Services.
• Usage information - such as information about the Services you use, the time and duration of your use of the Services and other information about your interaction with content offered through a Service, and any information stored in cookies and similar technologies that we have set on your device.
• Location information - such as your computer’s IP address, your mobile device’s GPS signal or information about nearby Wi-Fi access points and cell towers that may be transmitted to us when you use the Services.

Personal Information from Third-Party Sources

We may acquire or receive Personal Information about you from publicly and commercially available sources, as permitted by applicable law, which we may combine with other Personal Information or other information we receive from or about you. For example, we may receive information about you from a social media site if you connect to the Services through that site.

Other Personal Information We Collect

We also may collect other Personal Information about you, your device, or your use of the Services in ways that we describe to you at the point of collection or otherwise with your consent.

Personal Information Storage Time

We will keep your Personal Information for as long as it is needed to fulfil the purposes for which it was collected and in order to comply with applicable legal or regulatory requirements. This may mean that some Personal Information is held for longer than other information. When Personal Information is no longer needed, we either securely destroy it, or irreversibly anonymise the data (and we may further retain and use the anonymised information).

Sharing of Personal Information

The following provides information about entities with which we may share your Personal Information. Our practices vary depending on the type of information and sharing.

Affiliates

We may share your Personal information within our family of affiliated companies (“Affiliates”) so that we may provide offers from those companies that may be relevant to you, better understand your preferences, and improve our Services.

Business Partners

We may also share your Personal information with our business partners and customers or your authorised representatives to provide you with Services that you request. For example, if you sign up for a promotion that runs on our Services but that is sponsored or co-sponsored by another company, your information may be shared with that sponsor. We are not responsible for the privacy practices of these entities and recommend you review their privacy policies carefully.

Service Providers

We may share your Personal Information with companies providing services on our behalf, such as hosting vendors, advertising service providers, data analytics companies, marketing service companies, and list managers. We also may share your Personal information, including your payment information, as appropriate to process your payments for the Services or complete a transaction. Our service providers are given the Personal information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other unrelated purposes.

Social Media Services

If you connect a social media account with the Services or engage with our services through a social media platform, we may share your Personal Information with that social media platform, and it may share Personal Information about you with us. We may use this Personal Information to personalize your experience on the Services and on the third-party social media platforms, or to provide you with offers or other real estate inventory or Services you may request. The social media services’ use of the shared Personal Information will be governed by the social media services’ privacy policy and your social media account settings. If you do not want your Personal information shared in this way, do not connect your social media service account with the Services.

Companies that Provide Content, Advertising, or Functionality

Some of the content, advertising, and functionality on our Services may be provided by third parties, such as our customers, service providers (such as verification of identity) or advertisers. These companies may collect or receive certain Personal Information about your use of the Services, including through the use of cookies, beacons, and similar technologies, and this information may be combined with Personal Information collected across different websites and online services in order to deliver ads that are more relevant to you, both on and off our Services.

Other Parties When Required or Permitted by Applicable Law, or As Necessary to Protect Our Users, Affiliates and Services

We and our service providers (including affiliates) may use and share your personal information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users, to detect, suppress or prevent fraud or where otherwise required or permitted by applicable law or legal process, including responding to a search warrant or other legally valid requests from public and government authorities (which may include lawful access by U.S., Canadian, Australian or other governmental authorities, courts or law enforcement agencies).

Other Parties in Connection with a Corporate Transaction

We may transfer to the purchaser any Personal Information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, sale or in connection with a bankruptcy reorganization.

Otherwise with Your Consent or at Your Direction

In addition to the sharing described in this Privacy Policy, we may share Personal Information about you with third parties whenever you consent to or direct such sharing.

• Aggregated Data - We also may provide aggregated information, and data with personal identifiers removed, to third parties to describe how our users and customers are using the Services.
• Sale of Personal Information - We do not “sell”, as defined in certain state laws/regulations (e.g., the California Consumer Privacy Act or the Nevada Privacy Act), your Personal Information to any third parties for monetary or other financial considerations and have not done so within the previous 12-month period from the effective date listed on this Privacy Policy.

Interest - Based Advertisements

We may use third parties to serve advertisements on our Services and on other websites and digital platforms. These companies may use cookies, web beacons or other technologies to report certain information about your visits to our Services and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off our Services. To learn more and to opt-out of having your information used by these companies for online behavioral advertising purposes, please see “Choices with Respect to Interest-Based Advertisements” below. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.

Cookies

“Cookies” are small text files that are placed on your computer or devices when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes. For example:

• Cookies can remember your sign-in credentials, so you do not have to enter those credentials each time you visit a Service;
• Cookies can help us, and third parties understand which parts of our Services are the most popular because they help us see which pages and features visitors’ access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Services and provide you with a better experience;
• Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access a Service.

Most browsers accept cookies automatically but can be configured not to do so. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable cookies, it may interfere with the functioning of the Services.

We and other companies that provide advertising and other services on our Services use cookies, web beacons, do-not-track signals and similar technologies to improve and customize your advertisements and your experience using our Services. We use cookies to make our Websites work. We set analytics cookies to help us improve our Services and Websites (when you enable them) and some of these cookies allow us to remember your preferences. Some cookies enable core functionality such as security, network management, and accessibility. You may disable these by changing your browser settings, but this may affect how the Websites function. We may use cookies such as Google Analytics cookies to help us to improve our Websites by collecting and reporting information on how users use them. The cookies may collect information in a way that does not directly identify anyone.

Beacons

We, along with third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of Personal Information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our Services and (in conjunction with cookies) to provide real estate inventory and ads that are more relevant to you both on and off the Service.

Do-Not-Track Signals and Similar Mechanisms

Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no agreed worldwide industry standard concerning what, if anything, websites should do when they receive such signals, the Services currently do not take action in response to these signals. If and when such a standard is established and accepted, we will reassess how to respond to these signals.

Local Storage And Other Tracking Technologies

We, along with third parties, may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found here.

Privacy and Access Choices Available to You

Choices with Respect to Cookies and Similar Technologies.

You may block cookies and similar technologies in your browser or device settings, as and if permitted by such device.

Choices with Respect to Interest - Based Advertising

You may opt out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Network Advertising Initiative, Digital Advertising Alliance and Digital Advertising Alliance of Canada.

Manage Your Account

You may access and modify or delete your account on the settings or profile page of our Websites, or by contacting our Privacy Officer at privacy@salefishsoftware.com with a written request to do so. In addition, you may contact us at the SaleFish Australia office located at Suite 215, 566 St Kilda Rd Melbourne VIC 3004 Australia (Telephone: 1300 169 025) or the SaleFish Global Headquarters located at 8395 Jane Street, Suite 203 Vaughan, ON, L4K 5Y2 Canada (Telephone: +1 877-892-7741 or +1 905-761-5364). Whichever way you elect to contact us, we may ask that you confirm and verify your identity.

Data Access

Subject to applicable law, you may also have a right to access, update, and correct inaccuracies in other personal information in our custody and control, subject to certain exceptions prescribed by applicable law.

Under the Australian Privacy Act 1988 (Cth), you have a right to request us for access to and/or to correct your Personal Information or to withdraw consents that allow us to use or process your Personal Information (subject to any legal obligations with which we are required to comply). We will take reasonable steps to correct your Personal Information if we consider it is incorrect. If you wish to exercise any of the rights set out above, please contact us as set out below in Questions. You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights) under applicable law however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will try to respond to all legitimate written requests by you regarding your Personal Information within 30 days after your requests and as soon as practicable after receiving them. It may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will let you know and keep you updated.

You may request access, updating and corrections of inaccuracies in the Personal Information we have in our custody or control by emailing or writing to us at the contact information set out below in Questions. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records.

Email Promotions

You may opt out of receiving commercial email, text message, and other electronic messages from us (excluding transactional messages) by following the instructions contained in those messages.

Data Security

SaleFish Inc. is certified for Cyber Security by Cyber Essentials Canada (CEC). Cyber Essentials aims to be the most comprehensive annual third-party cyber certification process for business in the world today. The Cyber Essentials standard started as a government-backed cybersecurity process that was developed and implemented by the United Kingdom in 2016. For more information about the certification visit Cyber Essential Canada.

Children’s Privacy

We do not knowingly collect any Personal Information from children or any person under the age of 13 without parental consent, unless permitted by applicable law. If we learn that a child or a person under the age of 13 has provided us with Personal Information, we will delete it in accordance with applicable law.

Links to Third-Party Sites

Our Services may link to third-party websites and services that we do not operate and are outside of our control. We are not responsible for the security or privacy of any information collected by other websites or other services. Please exercise caution and review the privacy statements applicable to the third-party websites and services you use.

International Transfers

We and the Services are headquartered in Canada. Any Personal Information provided to us may be transferred to, stored by or disclosed to an overseas recipient outside of Australia. For example, SaleFish may use a server hosted overseas to store data, which may include your Personal Information. Your Personal Information may also be processed by employees or by other third parties operating outside of Australia in countries including the United States of America, Canada, India, the European Union, the United Kingdom and the locations of our other Affiliates, or representatives or employees.

We will take reasonable steps, in the circumstances, before your Personal Information is disclosed to an overseas recipient outside Australia, to ensure that the overseas recipient does not breach the Australian Privacy Act 1988 (Cth) as may be applicable in relation to your Personal Information.

This means that you consent to Personal Information that you provide to us or that we obtain as a result of your use of the Services being collected, stored, processed or used in your country or transferred, stored, used, maintained or processed in Canada or another country by us or our service providers for the purposes mentioned above in accordance with applicable law. By using the Services, you consent to the collection, international transfer, storage, and processing of your information.

Changes to Our Privacy Policy

We may modify this Privacy Policy from time to time. We will notify you of changes by posting changes on our Websites, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Services or our Websites. Your use of the Services or your provision of Personal Information to use the Services or Websites following such changes indicates your acceptance of the revised Privacy Policy. This Privacy Policy is effective on the date set out at the top of it as the Effective Date.

Questions. Please contact our Privacy Officer at privacy@salefishsoftware.com with such written request. In addition, you may contact us at the SaleFish Australia office located at Suite 215, 566 St Kilda Rd Melbourne VIC 3004 Australia (Telephone: 1300 169 025) or at the SaleFish Global Headquarters located at 8395 Jane Street, Suite 203 Vaughan, ON, L4K 5Y2 Canada (Telephone: +1 877-892-7741 or +1 905-761-5364). Whichever way you elect to contact us, we may ask that you confirm and verify your identity.