OSINT Combine and NexusXplore Privacy Policy

1.1     OCNX Holdings Pty Ltd (ACN 637 522 073) and its subsidiaries, including OSINT Combine Pty Ltd (ACN 637 543 803) and NexusXplore (ACN 637 541 738), are business registered in Australia (collectively referred to as OCNX, we, or us) and are committed to keeping your information safe and secure in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles contained therein, and any applicable State or Territory law governing your data collection or privacy. By engaging with our services (the Services) or using our website and platform (the Website), you are giving consent to us for the use of your private information in the manner set out in this Privacy Policy.   

 

1.2     To the extent we must comply with General Data Protection Regulation (GDPR) as applied respectively by the European Economic Area or the United Kingdom (EEA), and the information that we collect, receive or use for our business purposes is information that relates to an identified or identifiable individual in the EEA, we will treat such information as personal information as required by the GDPR and pursuant to section 10 of this Privacy Policy.    

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2 COLLECTION OF PERSONAL INFORMATION

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2.1        We may collect and use the following kinds of information:  

   

(a)          information about your use of the Website or Services (including your IP address; browser type, version and language; operating system; device name or identification number; location; pages viewed while browsing the Website or Services; page access times; “cookies”; and referring website address); and  

   

(b)          information about your personal details (including name; phone contact details; address information; and email).  

 

2.2        Information about your personal information may be collected in a variety of ways, including, but not limited to:  

   

(a)          when you register for the Website and the Services;  

(b)          when you interact with us electronically or in person;  

(c)          when you apply for a job or provide us services (as an employee or contractor); 

(d)          access our office or systems;  

(e)          when you access the Website or the Services;  

(f)           from a third party who is our customer, such as your employer, so we can provide information, services or products to that customer, or from companies contracted by us or you to provide products and services to you; and  

(g)          when we provides products and/or Services to you.  

   

2.3        You have the option of not identifying yourself or of using a pseudonym when dealing us.  However, it will be impracticable for us to provide you with information or Services.  

   

3             USE OF PERSONAL INFORMATION  

   

3.1        We may use your personal information in relation to its business, including but not limited to:  

   

(a)          enable your access to the Website; 

(b)          track usage and measure traffic statistics of the Website; 

(c)          supply to you the products and/or Services that you purchase or request as a customer;  

(d)          receive and/or access information from third party providers for the provision of our products and/or Services to you;  

(e)          contact you regarding your use of the products and/or Services offered by us;  

(f)           contact you in relation to comments, complaints, enquiries or dispute resolution;  

(g)          collect payments from you;  

(h)          to improve our Website and Services;  

(i)           to verify your identity;  

(j)           to consider you for a job with us (whether as an employee or contractor) or in the context of other relationships with us;  

(k)          to address any issues or complaints that we or you have regarding our relationship;  

(l)           communicate with third party providers or associate parties with respect to the provision of the Services; and  

(m)        send you marketing communications.  

   

3.2        We may also use your personal information to protect the copyright, trademarks, or other intellectual property or legal rights, property or safety of us, the Website, and its customers or third parties.  

   

4            DISCLOSURE OF PERSONAL INFORMATION  

   

4.1        We will not disclose personal information about you, unless it is required, incidental or otherwise related to the primary purpose of providing the Services to you or a third party for which you have consented to by engaging our Services or by using our Services. However, We may disclose your personal information to its business partners who can assist them to provide the Services to you as a customer or to maintain its products or systems. This includes but is not limited to providing personal information to:  

   

(a)          our employees and related bodies corporate;  

(b)          our contractors and other third parties that provide goods and services to us (including website and data hosting providers, and other suppliers);  

(c)          our accountants, insurers, lawyers, auditors and other professional advisers and agents 

(d)          payment system operators or credit reporting bodies;  

(e)          if you are an individual contractor to us or a prospective or current employee, to our related companies and HR related service providers (e.g. for outsourced payroll processing);  

(f)           any third parties necessary to verify your information (e.g. referees or ID verifiers);  

(g)          in the event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors;  

(h)          third parties that require the information for law enforcement or to prevent a serious threat to public safety; and  

(i)           otherwise as permitted or required by law.  

   

4.2        We, in our sole discretion, may disclose your personal information if it is required to do so by law or legal process, including:  

   

(a)          in order to establish, exercise or defend its legal rights (including but not limited to debt recovery, credit rating services, and employment related matters);  

(b)          as required or authorised by law; or  

(c)          to the extent required to permit Us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, our policies, or the rights of third parties or any other suspected conduct We deem improper.  

   

4.3        If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We will use reasonable effort to only disclose personal information in good faith and where required by any of the above circumstances.    

   

5             SECURITY AND ACCURACY  

   

5.1        It is important that you advise Us of changes to your personal information that you have provided to Us as it is essential that your personal information is accurate, complete, and up-to-date in order for Us to provide the Services to you.  

   

5.2        We will take commercially reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure. However, we are not liable for any unauthorised access to this information beyond its reasonable control.  

   

5.3        We will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes of providing our Services to you and where we is not required to retain that information by law.  

   

5.4        In the event of a data breach that is likely to result in serious harm, the Notifiable Data Breaches Scheme in the Privacy Act sets out obligations for notifying affected individuals, and the Australian Information Commissioner (Commissioner), about an “eligible data breach”. Where a data breach occurs and serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations.  

   

6             ACCESS AND CORRECTION  

   

6.1        You are responsible to ensure that the information you provide to ss is accurate, complete and up-to-date.  

   

6.2        By request, you may contact Us and ask to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used and disclosed.  

   

6.3        By request, you may access your personal information by contacting Us at legal@osintcombine.com. We reserve the right to charge a reasonable administration fee for this access.  

   

6.4        We, in our sole discretion, may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law to withhold personal information, or not make the requested changes.  

   

7             IDENTIFIERS AND ANONYMITY  

   

7.1        You acknowledge that we retain, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). You agree that we may share, distribute and/or transfer information which you have provided to us to third parties, after that information has been de-identified.  

   

8             SENSITIVE INFORMATION  

   

8.1        Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, or health information.  

   

8.2        Sensitive information will be used by us only:  

   

(a)          for the primary purpose for which it was obtained;  

(b)          for a secondary purpose that is directly related to the primary purpose;  

(c)          with your consent; or  

(d)          where required or authorised by law.  

   

9             TRANS-BORDER DATA FLOWS  

   

9.1        We may use cloud services, and as such, its servers may be located in Australia or overseas and you acknowledge, agree and understand that your personal information may be transferred and stored in Australia and other foreign jurisdictions, such as Japan, the US, and the UK, which the cloud services may direct the data to be stored. You agree for us to transfer your information into foreign jurisdictions for the purposes of providing you with the Services.  

   

9.2        In addition to the above, we will transfer personal information to someone who is in a foreign country where:  

   

(a)          We reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles;  

(b)          the individual consents to the transfer;  

(c)          the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to your request;  

(d)          the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and a third party;  

(e)          all of the following apply:  

(i)           the transfer is for your benefit;  

(ii)          it is impracticable to obtain your consent to that transfer; and  

(iii)         if it were practicable to obtain such consent, you would be likely to give it; or  

(f)           We has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.  

   

10            EEA RESIDENTS  

   

10.1       Processing. We process your personal information on one or more of the following legal bases:  

   

(a)      as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide the Services, to respond to requests from you, or to provide customer support;  

(b)      where we have a legitimate interest, as described in this Privacy Policy (see  Use of Personal Information above);  

(c)      as necessary to comply with relevant law and legal obligations, including to respond to lawful requests and orders; or  

(d)      with your consent.  

   

10.2       Legitimate Interest: We process the following categories of Personal Data, such as:  

   

(a)      contact data;  

(b)      account data;  

(c)      log data;  

(d)      web analytics; and  

(e)      publicly available information  

   

when we believe it furthers the legitimate interest of us or third parties, such as:  

   

(a)      operation and improvement of our business, products and services; 

(b)      marketing of our products and services;  

(c)      provision of customer support;  

(d)      corresponding with you; 

(e)      protection from fraud or security threats;  

(f)       compliance with legal obligations; and 

(g)      completion of corporate transactions.  

 

10.3       Your Rights. Subject to applicable law, you have the right to:  

   

(a)      ask whether we hold personal information about you and request copies of such personal information and information about how it is processed; 

(b)      request that inaccurate personal information is corrected;  

(c)      request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;  

(d)      request us to restrict the processing of personal information where the processing is inappropriate;  

(e)      object to the processing of personal information; and  

(f)       request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or a contract with you and is carried out by automated means.  

   

10.4       If you wish to do any of these things, please contact us.  

   

10.5       When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.  

   

10.6       Transfers outside of the EEA. When we transfer your personal information outside the EEA we do so in accordance with the terms of this Privacy Policy and applicable data protection law.  

   

11          COMPLAINTS  

   

11.1     As a valuable customer, if you have any complaints in relation to this Privacy Policy or privacy practice, please feel free to contact Us via legal@osintcombine.com.  

   

11.2     A complaint should identify whether it is about:  

   

(a)          the collection of personal information;  

(b)          the use of personal information;  

(c)          the disclosure of personal information;  

(d)          the security or storage of personal information;  

(e)          the accuracy of personal information;  

(f)           a refusal to give access to or provide about their personal information; or 

(g)          a refusal to change or delete personal information.  

   

11.3     We value your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, We may require additional information to confirm your identity and will respond in a timely manner to advise you of the outcome. You will also be invited to respond to its outcome. If a response is received, We will assess your response and advise if it has changed its view.  

   

11.4     If you are unsatisfied with the final outcome, we will advise further options including, if appropriate, making a complaint with the Office of the Australian Information Commissioner.  

   

11.5     For residents of the EEA or the UK, you may lodge a complaint with a data protection authority for your country or region or where any alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.  

   

12         OPTING-OUT OF DIRECT MARKETING  

   

12.1     We aim to give you a highly personalised experience when using the Website and the Services. In order to do so, we may use your personal information to send you advertisements to your email address. If you decide you do not want to receive these emails containing advertisements, you can request to unsubscribe from the mailing list by clicking ‘Unsubscribe’ at the bottom of the email.  

   

13          COOKIES  

  

13.1     We use cookies and measurement software (the Cookies) on the Website and the Services to:  

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(a)          store details about your use of the Website to provide you with a personalised experience tailored to you, for example remembering your preferences; 

(b)          server to identify and interact more effectively with your device; 

(c)          analyse Website traffic, trends and reporting statistics to improve the Website and Services; and 

(d)          provide you with targeted marketing communications.  

  

13.2     We use Google Analytics remarketing codes to log when users view specific pages or take specific actions on the Website. This allows us to provide targeted advertising in the future.  

  

13.3     You may reject or delete the use of Cookies through the settings on your browser or mobile settings.  

   

13.4     We do not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.  

   

14          THIRD PARTY SITES  

   

14.1     The Website may from time to time have links to other websites not owned or controlled by Us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.  

   

15          HOW TO CONTACT US  

   

15.1     If you would like to access your personal information, have a query in relation to this privacy policy or would like to complain about our handling of your personal information, please contact our Privacy and Data Protection Officer by email at legal@osintcombine.com or by mail to:  

   

Privacy and Data Protection Officer  

Level 14, 138 Macquarie Street  

Sydney NSW 2000, Australia 

   

16          VARIATION TO THIS PRIVACY POLICY  

   

16.1     This Privacy Policy is available online via www.osintcombine.com  

   

16.2     We reserve the right to modify or amend this Privacy Policy at any time, for any reason, and without any notice, by posting a revised version on our Website. Any changes to this Privacy Policy will become effective when We post the revised Privacy Policy on our Website. Your browsing of our Website or use of the Website or Services following these changes means that you accept the revised Privacy Policy.  

   

16.3     This policy was last modified on 23 July 2021.