Privacy Policy

Overview of Policy

Scope

At Portal Link, your privacy is important to us, and so is being transparent about our privacy practices.

This Privacy Policy ('Policy') applies to all persons that use our products and services and our Online Channels. This Policy describes the information we collect and how that information is used and shared by us. It also includes details about the choices we offer you in relation to that information.

Definitions

The Client refers to any customer that is using the portal, for example, the practitioner appointed over an external administration.

Portal Link, we, us and our refers to Enterprise Systems Pty Ltd (ABN: 73 674 063 917) trading as Portal Link.

Personal Information refers to any information or opinion relating to or about an individual or an individual who is reasonably identifiable.

Online Channels means:
- Websites operated by us (Websites);
- Our social media pages and apps that we control (collectively, our Social Media Pages);
- Email messages or other communications with you; and
- Device notifications and other channels or activities described in this Statement that we use that are not Websites, Apps or Social Media Pages.
Information We Collect

To allow for the proper operation of the platform, developed and managed by Portal Link, we will collect information necessary for those systems to operate.
We may collect the following information:
- Personal Information – this may include your name, date of birth, title, gender, mailing address, phone number, email address, nationality, occupation, and government-issued identification to verify your identity (including passport, driver’s license, government health benefits card or national ID card) or other authentication information, all of which may include photographs of you.
- Financial Information - we may collect financial information such as details of transactions that lead to the debt and bank account details for payment of dividends.
- Representative Information - we may collect personal information of the proxy or representative of a creditor.
- Business Information - We also may collect entity formation documents or other corporate records.
Log Data

When you access our Online Channels, we collect server logs, which may include information such as IP address, access times and dates, pages viewed and other system activity, including the third-party site you were using before and after accessing our services.

Device Information

We may obtain information about the devices you use to access our Online Channels including: the device type, operating systems and versions, the device manufacturer and model, preferred languages, unique identifiers (including identifiers used for advertising purposes), and plugins.

Usage and Preference Information

We collect information about how you interact with the Online Channels and how you use our Online Channels, including your user preferences and other settings selected by you. In some cases we do this by using cookies and other tracking technologies.

Geolocation Information

When you use certain features of our Online Channels, we may collect information about your approximate location as determined by data such as your IP address.

Aggregated, Anonymised and Deidentified Data

We may also collect or create aggregated, anonymised, or deidentified data about our users. This data is used for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

Other Information

We may collect any other Personal Information you may provide to us when you update your account information, respond to surveys, post to community forums, or use any other feature of our Online Channels or services.
How We Collect Information

We collect information about you in a variety of different ways, including the following:

Information You Provide

We collect Personal Information and other information from you when you complete a form, register for a Portal Link user account, submit to our verification procedures, respond to our emails, messages or surveys, communicate with us including by telephone, email and online, provide feedback, participate in promotions or contests, provide referrals, or upload content. We make and store recordings of our telephone communications with you.

Information from Your Use of services

When you use our services, we collect Personal Information and other information about you and the devices you use to access the Online Channels. If you connect your social media account to your Portal Link account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Portal Link account.

Information from Third Parties

We also collect Personal Information about you from third parties and other sources, including the Client, government agencies, identity verification and fraud detection service providers and databases, credit bureaus, credit reporting bodies, credit reference agencies, community forums used to post ratings or reviews, social media platforms, advertising, advertising technology and market research companies, contact list, demographic & profile data brokers including companies that publish Portal Link marketing and advertising materials that you interact with, Portal Link business partners and associates through which you access our services, or other sources of public records.
How We Use Your Information

We use Personal Information we collect from or about you for several purposes, including:

To provide or improve our services
- To provide services to the Client.
- To provide customer support.
- To evaluate requests for services.
- To develop new products or enhance existing products and services.
- To monitor and analyse trends, usage, preferences and other user activities on our Online Channels to optimise user experience and to enhance the effectiveness of our promotional campaigns.
- For quality control and staff training.
To ensure safety and security
- To verify your identity or authenticate your right to access an account or other information.
- To conduct manual or automated monitoring to protect against fraud, other crimes and harmful activities.
To comply with legal obligations
- To comply with laws, regulations, codes of conduct, stock exchange rules, binding determinations or to respond to legal process or government authorities.
- To address disputes or resolve claims related to use of our services.
- To enforce our terms and conditions and collect fees
To communicate with you
- To respond to your inquiries and support requests.
- To send you technical notices, updates, security alerts and other administrative messages.
To market and advertise our services
- To deliver promotional offers, incentives, and targeted or personalised marketing in a variety of ways including via email, SMS, push messages, telephone, social media or online.
- To provide invitations and information about events held by us or our partners.
- To facilitate promotional contests or sweepstakes.
- For analytics and insights with any Personal Information that we collect or obtain about you, including combining your Personal Information with other personal information and data to use in advertising and marketing that may influence your behaviour or decisions or provide insights and measurement to us in relation to any advertising initiatives that we may run.
You can opt-out of receiving marketing at any time through the unsubscribe function available in each marketing communication we send Other purposes

Any other purpose disclosed at the time of collection.
Information Sharing and Disclosure

We may create aggregated information and de-identified information from the data we collect. We may use and disclose this information for our business purposes, including analytics, insights, research, and reporting on and promotion of our services. We may also share information about you, including Personal Information, with the following third parties if you ask us to, if we consider it necessary to provide our services to you, if we have a duty to disclose it or an applicable law allows us to do so for legitimate interests or business reasons:

Our Clients

We operate our portals to collect information on behalf of practitioners of external administration appointments. The information collected is provided to the practitioner as part of the ordinary course of business.

Our Service Providers

We engage a variety of service providers to enable us to provide our services to you. For example, service providers may be used to support technology or infrastructure, analytics and insights generation, collect debts, determine who we should market and advertise to, distribute marketing materials, conduct market research, perform audits, provide professional advice or other functions.

Credit Reference and Identity Verification Agencies

To credit bureaus, credit reporting bodies, credit reference agencies, identity verification agencies and other companies and organisations (Verification Agencies) to check your details, verify your identity and protect against fraud, other crimes and harmful activities.

In some cases Verification Agencies may need to access third party databases (including without limitation databases of government issuers of identification documents). You provide your authority for Verification Agencies to act as your agent in accessing these databases. Verification Agencies may disclose to third parties any information provided to them for identity verification purposes.

Our Partners, Business Associates or Contractors

To any of our partners, business associates, or contractors or your agents that you have authorised to have access to your Portal Link account or your Personal Information in connection with the provision of our services. A partner’s, business associate’s or contractor’s access to and use of any data provided by Portal Link will be treated in accordance with that third party’s terms of use.

Other Authorised Third Parties

If you provide your consent, we may share your information including your Personal Information with other authorised third parties. Such disclosure will only be carried out in the manner described to you at the time you agreed to the sharing. Authorising a third-party application or website to access your Portal Link account or participating in certain promotional activities constitutes such consent to share your information.

Government Authorities

If we believe it is necessary or appropriate, we may share your Personal Information with law enforcement officials, government authorities, regulatory bodies or other third parties, including for purposes of: (i) enforcing our Customer Agreement or other applicable agreements or policies; (ii) protecting our rights, property, privacy, or security, or that of others; or (iii) complying with applicable law, legal process, or government orders.

Third-Party Acquirers

If we are the subject of or are involved in any corporate merger, acquisition, consolidation, reorganisation, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with bankruptcy or similar proceedings), we may disclose or transfer data, including Personal Information, with third parties in connection with such events.

Professional Advisors

We may share your information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they provide to us.

International Transfers

We collect information globally and may transfer, process and store your information outside of your country of residence, to wherever we, our third party service providers or any recipients referred to in section 5. Whenever we transfer your information, we take steps to protect it.
How long we keep Information

We need to keep your Personal Information so that we can provide our services to you. We also need to keep it for longer than services are provided for legitimate business purposes (such as accounting purposes) and for other legal and regulatory reasons. Subject to this, we will destroy, erase, or anonymise your Personal Information when it is no longer needed.
Choices and Transparency

You have choices regarding how to manage your Personal Information and how we use and disclose your Personal Information.

How Your Information may be Accessed, Updated or Corrected

To ensure the information we hold is accurate, you should tell us as soon as possible if any of the information you have provided us has changed. You may request that we correct or update the Personal Information you provided to us at any time by contacting us at privacy@exad.com.au. If you want to access a copy of the Personal Information we hold about you, you can contact us at privacy@exad.com.au.

We will respond to any such request consistent with applicable law. Prior to changing or correcting your information or providing your information to you, we may be required to verify your identity.

There may be situations where we cannot action your request including where the information may impact the privacy of other individuals, the information is subject to legal privilege, the disclosure could threaten the safety, physical or mental health or life of an individual or Portal Link is prohibited by applicable law from providing you with access. If this is the case, we will set out in writing to you any reasons for our refusal to provide access to such information.

We will take reasonable steps in the circumstances to ensure that your Personal Information is accurate, complete and up-to-date to minimise the possibility that inappropriate information may be used to make a decision about you. We will not routinely update your
Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected.

Device Permissions

Most mobile devices allow you to disable the use of location services, or revoke consent to applications to access your camera and photo library or send you push notifications. Some devices allow you to activate a ‘do not track’ function, reset your device specific advertising identifier. Please refer to your device settings to restrict collection of certain information.

Marketing Opt-Out

You can opt out of receiving our marketing at any time through the unsubscribe function in each marketing communication, we will continue to send you non-promotional messages that are required to provide our services.

Testimonials

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@exad.com.au.

Declining to Provide Information

We need to collect Personal Information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Security

We employ technical, physical, and organisational measures designed to safeguard your Personal Information against loss, misuse, or unauthorised access.

Unfortunately, the transmission of information over the Internet or the telephone is never 100% secure and no data storage system can be guaranteed safe. We cannot warrant the security of data transmitted to us and any transmission is at your own risk.

We encourage you to understand the integral role you play in keeping your own Personal Information secure and confidential, always keep your log-in details secure. You should also take care not to give any security credentials we provide you or you choose (such as a password) to someone who is not a Portal Link representative. We will never ask you for your full security credentials. If you are unsure, please end the session. If you suspect any unauthorised use or access to your account or information, please contact us immediately by emailing privacy@exad.com.au.
Cookies and Tracking Technologies

We use cookies and similar tracking technologies to recognise you and to customise your online experience.
Advertising, Profiling, non-advertising issues and analytics

We may partner with third parties to display and personalise Portal Link advertisements to you and to track and report on the performance of those advertisements. These third-party partners use cookies and other technologies to gather information about your activities on our Online Channels, as well as information from third parties and your activities on other sites or online services on any of your devices, in order to serve you advertising based upon your online behaviours including browsing history and interests. They also use these technologies, along with information they collect about your online use, to recognise you across the devices you use.
Third Party websites and services

This Policy does not apply to third party websites, applications, products or services, even if they are linked to our services or Online Channels, and we are not responsible for the privacy, information, or other practices of third parties. The inclusion of a link on the Online Channels does not imply endorsement. You should review the privacy policies of any third party websites you visit.
Children

Our services are not intended for or directed at individuals under the age of 18. If you are a parent or guardian of a child from whom you believe we have collected Personal Information in a manner prohibited by law, please contact us using the “Contact Us” information below. If we learn that we have collected Personal Information through the Online Channels from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Complaints

Portal Link will investigate all complaints. For more information on how we manage complaints contact us at privacy@exad.com.au.
Updates to This Policy

We may change this Policy from time to time. If we make any material changes we will notify you by means of a notice on our Websites. Any changes will become effective on the date specified in the revised Policy posted on our Websites.
Contact Us

If you have questions or concerns about this Policy, need it in an alternative format, have a specific request related to your Personal Information or any complaints about our privacy practices, please contact us at privacy@exad.com.au or at:

For Australian Residents

Enterprise Systems Pty Ltd (trading as Portal Link)

Attn: Privacy Officer

Email: privacy@exad.com.au

Additional Information for Residents of Australia

Office of the Australian Information Commissioner (OAIC)

OAIC is a government agency which oversees the Privacy Act 1988 (Cth) and related legislation, and investigates complaints about handling of Personal Information under the Privacy Act. OAIC will in many cases only investigate once Portal Link has been given the opportunity to resolve your complaint internally. You may lodge your complaint with OAIC by sending the necessary documents and information to:

Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001

Website: http://www.oaic.gov.au

Telephone: 1300 363 992

Facsimile: (02) 9284 9666

Email: enquiries@oaic.gov.au