Handle AI Pty Ltd (formerly Cupcake AI Pty Ltd) (ACN 673 132 888) registered in Chatswood NSW 2067 (“Handle”, “we”, “us” or “our”) is committed to providing quality services to you and to respecting your privacy.

This privacy policy sets out how we collect, use, process, store, share and disclose your Personal Information (as defined in section 1 below) from the operation of our website at https://www.handle.work/ (“Website”), our product, being an AI assistant builder (“Platform”), our services, including support and solution enhancement services in respect of the Platform (each of the Website, Platform and services, together the “Services”) (“Privacy Policy”). Please note that if you are a Handle customer, when you signed up for any of our Services, you agreed to our terms and conditions by entering into an agreement with Handle, 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”), and if applicable, the California Consumer Privacy Act (“CCPA”) and any other relevant laws pertaining to privacy of individuals in jurisdictions which our Services are available (collectively, “Privacy Laws”).

We are a data controller for the purposes of the GDPR, but in some circumstances may be a data processor. 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 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.

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, email address, telephone number(s), 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 Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries.
• Provided Information: any additional information relating to you that you provide to us directly or indirectly through use of our Services or through other websites or accounts from which you permit us to collect information.
• User Content: any information which you post to Handle or to any workplace tools and applications used to facilitate communication, teamwork, and productivity within the User’s organisation such as Slack, Microsoft Teams, and similar platforms that support messaging, video calls, file sharing, and project collaboration (“Workplace Platforms”) or otherwise via our Services.
• 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 Handle.
• Other: any other Personal Information that may be required in order to facilitate your dealings with us.

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 Services; 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.

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

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 our Services. 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.

Our 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 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 and we will cease the use of that Personal Information and deactivate any related account.

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 Services to you;
• administering, protecting, improving or optimising our Services;
• manage, operate and improve our Services and grow our business, including data analytics, conducting research for understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, advertisements and publications, and diagnose or fix technology problems;
• creating industry reports from de-identified data;
• verifying your identity or age;
• billing you for purchasing our products and service;
• informing you about our Services, 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;
• access, recruit and hire staff;
• perform any other function that we believe reasonable and necessary to protect the security or proper functioning of 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 Handle, you or others.

Where we:

• have your express consent;
• 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 hello@handle.work.

We may disclose your Personal Information to the following service providers:

• Outsourcing Companies: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 5.
• Analytics: as a part of providing you with, measuring and improving our Services, we may engage with analytics providers who collect information utilising tracking technologies on our Website and software to measure visits and traffic on our Website or servers which provide you the Services.
• Related Bodies: we may share information with other entities in the Handle 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.

We will only disclose any Personal Information you have provided to any entity outside of the Handle corporate group if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy. We engage third-party vendors to help deliver our services, including Workplace Platforms and security platforms (each a “Service Provider”).

We use Vanta Inc. (www.vanta.com) (“Vanta”), a third-party compliance and security management platform, to maintain an up-to-date list of our vendors. For more information about our current vendors, please see https://trust.handle.work, or contact us at security@handle.work.

When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to any of the above Service Providers. 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.

We all reasonably necessary measures to protect the information we collect through our Services which are stored electronically. 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.

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.

Your Personal Information may be stored and processed in countries outside of your location, including in jurisdictions that may have different privacy and data protection standards. We use Vanta, to maintain an up-to-date record of the countries where that Personal Information is stored and processed. If you would like more information about these locations, please see https://trust.handle.work, or contact us at security@handle.work.

We retain user data as long as an account is active. If an account has been inactive for 24 months, we will endeavor to delete that user data from our platform.

You can streamline this deletion process by requesting that your account be deleted, in-app, via our contact form or by emailing hello@handle.work. Once we receive a deletion request, we aim to delete user data within 30 days.

Under the GDPR, we must have a legal basis to process Personal Information collected from individuals residing in the European Union. We rely on several legal bases to process your Personal Information, including:

• where it is necessary to provide you with access to, and use of, the Services;
• for our legitimate interests to provide, operate and improve our Services;
• 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.

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 Services to you. As at the date of this Privacy Policy, such third-party recipients are located in 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. It is possible that additional third parties from other countries may be recipients in the future.

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 Privacy Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by a third-party recipient of the relevant Privacy Laws.

Where we:

• have your express consent (which you may withdraw at any time by contacting us in writing at hello@handle.work;
• 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 our Services as well as other products and services we believe may be 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 hello@handle.work.

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. By accessing or using this Website, you agree that we can store and access Cookies in accordance with this Privacy Policy. You will be able to accept or reject the collection of Cookies by us.

Cookies are small files that can be stored on and accessed from a user’s device when the user accesses a website. They enable authorised web servers to recognise you across different websites, services, devices and browsing sessions.

We may use Cookies to enable users to access and use our Website and Services, including to:

• identify users of our Website and Services;
• process user requests;
• improve user experience;
• remember user preferences on our Website;
• monitor the use of our Website and for analysis of our user base;
• facilitate communication with users;
• control access to certain content on our Website; and
• protect our Website.

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.

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

• opting out or adjusting preferences for Cookies when your device accesses the Website;
• customising 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 Services; and
• using your mobile device's operating system to select options on how it collects and utilises your information for interest-based advertising, if accessing the Services from a mobile device).

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.

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.

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.

California

For the purposes of the California Consumer Privacy Act (as amended by the California Privacy Rights Act (“CPRA”), we do 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 us 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).

Information we may collect and disclose:

• Identifiers: This includes names, addresses (both physical and email) personal identifiers (including online, internet protocol addresses, or other similar identifiers;
• 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.

Information we will not collect or disclose:

• 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).

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 us in the past 12 months;
• a right to request that we move, copy or transmit your Personal Information stored by us to another location;
• a right to delete any of your Personal Information collected and stored by us, and, by extension, a service provider to us;
• a right to correct any of your Personal Information collected and stored by us; 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 hello@handle.work. California residents maintain the right to exercise the rights given to them under the CCPA.

When you provide any information to us, we ask that you provide sufficient:

(a) information that allows us to reasonably verify you or are an authorised representative of that person; and

(b) 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.

Subject to some exceptions provided by the relevant Privacy Laws, you may request access to your Personal Information in our customer account database, or seek correction of it, by contacting us at hello@handle.work Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.

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.

Our Services may contain links to other third-party websites and services including social media networks. This Privacy Policy applies solely to information collected by us via our Services.

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at hello@handle.work.

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.

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.

Handle AI Pty Ltd (formerly Cupcake AI Pty Ltd) (ACN 673 132 888) registered in Chatswood NSW 2067 (“Handle”, “we”, “us” or “our”) is committed to providing quality services to you and to respecting your privacy.

This privacy policy sets out how we collect, use, process, store, share and disclose your Personal Information (as defined in section 1 below) from the operation of our website at https://www.handle.work/ (“Website”), our product, being an AI assistant builder (“Platform”), our services, including support and solution enhancement services in respect of the Platform (each of the Website, Platform and services, together the “Services”) (“Privacy Policy”). Please note that if you are a Handle customer, when you signed up for any of our Services, you agreed to our terms and conditions by entering into an agreement with Handle, 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”), and if applicable, the California Consumer Privacy Act (“CCPA”) and any other relevant laws pertaining to privacy of individuals in jurisdictions which our Services are available (collectively, “Privacy Laws”).

We are a data controller for the purposes of the GDPR, but in some circumstances may be a data processor. 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 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.

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, email address, telephone number(s), 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 Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries.
• Provided Information: any additional information relating to you that you provide to us directly or indirectly through use of our Services or through other websites or accounts from which you permit us to collect information.
• User Content: any information which you post to Handle or to any workplace tools and applications used to facilitate communication, teamwork, and productivity within the User’s organisation such as Slack, Microsoft Teams, and similar platforms that support messaging, video calls, file sharing, and project collaboration (“Workplace Platforms”) or otherwise via our Services.
• 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 Handle.
• Other: any other Personal Information that may be required in order to facilitate your dealings with us.

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 Services; 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.

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

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 our Services. 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.

Our 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 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 and we will cease the use of that Personal Information and deactivate any related account.

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 Services to you;
• administering, protecting, improving or optimising our Services;
• manage, operate and improve our Services and grow our business, including data analytics, conducting research for understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, advertisements and publications, and diagnose or fix technology problems;
• creating industry reports from de-identified data;
• verifying your identity or age;
• billing you for purchasing our products and service;
• informing you about our Services, 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;
• access, recruit and hire staff;
• perform any other function that we believe reasonable and necessary to protect the security or proper functioning of 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 Handle, you or others.

Where we:

• have your express consent;
• 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 hello@handle.work.

We may disclose your Personal Information to the following service providers:

• Outsourcing Companies: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 5.
• Analytics: as a part of providing you with, measuring and improving our Services, we may engage with analytics providers who collect information utilising tracking technologies on our Website and software to measure visits and traffic on our Website or servers which provide you the Services.
• Related Bodies: we may share information with other entities in the Handle 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.

We will only disclose any Personal Information you have provided to any entity outside of the Handle corporate group if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy. We engage third-party vendors to help deliver our services, including Workplace Platforms and security platforms (each a “Service Provider”).

We use Vanta Inc. (www.vanta.com) (“Vanta”), a third-party compliance and security management platform, to maintain an up-to-date list of our vendors. For more information about our current vendors, please see https://trust.handle.work, or contact us at security@handle.work.

When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to any of the above Service Providers. 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.

We all reasonably necessary measures to protect the information we collect through our Services which are stored electronically. 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.

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.

Your Personal Information may be stored and processed in countries outside of your location, including in jurisdictions that may have different privacy and data protection standards. We use Vanta, to maintain an up-to-date record of the countries where that Personal Information is stored and processed. If you would like more information about these locations, please see https://trust.handle.work, or contact us at security@handle.work.

We retain user data as long as an account is active. If an account has been inactive for 24 months, we will endeavor to delete that user data from our platform.

You can streamline this deletion process by requesting that your account be deleted, in-app, via our contact form or by emailing hello@handle.work. Once we receive a deletion request, we aim to delete user data within 30 days.

Under the GDPR, we must have a legal basis to process Personal Information collected from individuals residing in the European Union. We rely on several legal bases to process your Personal Information, including:

• where it is necessary to provide you with access to, and use of, the Services;
• for our legitimate interests to provide, operate and improve our Services;
• 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.

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 Services to you. As at the date of this Privacy Policy, such third-party recipients are located in 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. It is possible that additional third parties from other countries may be recipients in the future.

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 Privacy Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by a third-party recipient of the relevant Privacy Laws.

Where we:

• have your express consent (which you may withdraw at any time by contacting us in writing at hello@handle.work;
• 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 our Services as well as other products and services we believe may be 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 hello@handle.work.

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. By accessing or using this Website, you agree that we can store and access Cookies in accordance with this Privacy Policy. You will be able to accept or reject the collection of Cookies by us.

Cookies are small files that can be stored on and accessed from a user’s device when the user accesses a website. They enable authorised web servers to recognise you across different websites, services, devices and browsing sessions.

We may use Cookies to enable users to access and use our Website and Services, including to:

• identify users of our Website and Services;
• process user requests;
• improve user experience;
• remember user preferences on our Website;
• monitor the use of our Website and for analysis of our user base;
• facilitate communication with users;
• control access to certain content on our Website; and
• protect our Website.

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.

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

• opting out or adjusting preferences for Cookies when your device accesses the Website;
• customising 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 Services; and
• using your mobile device's operating system to select options on how it collects and utilises your information for interest-based advertising, if accessing the Services from a mobile device).

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.

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.

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.

California

For the purposes of the California Consumer Privacy Act (as amended by the California Privacy Rights Act (“CPRA”), we do 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 us 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).

Information we may collect and disclose:

• Identifiers: This includes names, addresses (both physical and email) personal identifiers (including online, internet protocol addresses, or other similar identifiers;
• 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.

Information we will not collect or disclose:

• 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).

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 us in the past 12 months;
• a right to request that we move, copy or transmit your Personal Information stored by us to another location;
• a right to delete any of your Personal Information collected and stored by us, and, by extension, a service provider to us;
• a right to correct any of your Personal Information collected and stored by us; 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 hello@handle.work. California residents maintain the right to exercise the rights given to them under the CCPA.

When you provide any information to us, we ask that you provide sufficient:

(a) information that allows us to reasonably verify you or are an authorised representative of that person; and

(b) 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.

Subject to some exceptions provided by the relevant Privacy Laws, you may request access to your Personal Information in our customer account database, or seek correction of it, by contacting us at hello@handle.work Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.

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.

Our Services may contain links to other third-party websites and services including social media networks. This Privacy Policy applies solely to information collected by us via our Services.

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at hello@handle.work.

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.

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.

Handle AI Pty Ltd (formerly Cupcake AI Pty Ltd) (ACN 673 132 888) registered in Chatswood NSW 2067 (“Handle”, “we”, “us” or “our”) is committed to providing quality services to you and to respecting your privacy.

This privacy policy sets out how we collect, use, process, store, share and disclose your Personal Information (as defined in section 1 below) from the operation of our website at https://www.handle.work/ (“Website”), our product, being an AI assistant builder (“Platform”), our services, including support and solution enhancement services in respect of the Platform (each of the Website, Platform and services, together the “Services”) (“Privacy Policy”). Please note that if you are a Handle customer, when you signed up for any of our Services, you agreed to our terms and conditions by entering into an agreement with Handle, 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”), and if applicable, the California Consumer Privacy Act (“CCPA”) and any other relevant laws pertaining to privacy of individuals in jurisdictions which our Services are available (collectively, “Privacy Laws”).

We are a data controller for the purposes of the GDPR, but in some circumstances may be a data processor. 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 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.

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, email address, telephone number(s), 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 Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries.
• Provided Information: any additional information relating to you that you provide to us directly or indirectly through use of our Services or through other websites or accounts from which you permit us to collect information.
• User Content: any information which you post to Handle or to any workplace tools and applications used to facilitate communication, teamwork, and productivity within the User’s organisation such as Slack, Microsoft Teams, and similar platforms that support messaging, video calls, file sharing, and project collaboration (“Workplace Platforms”) or otherwise via our Services.
• 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 Handle.
• Other: any other Personal Information that may be required in order to facilitate your dealings with us.

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 Services; 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.

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

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 our Services. 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.

Our 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 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 and we will cease the use of that Personal Information and deactivate any related account.

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 Services to you;
• administering, protecting, improving or optimising our Services;
• manage, operate and improve our Services and grow our business, including data analytics, conducting research for understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, advertisements and publications, and diagnose or fix technology problems;
• creating industry reports from de-identified data;
• verifying your identity or age;
• billing you for purchasing our products and service;
• informing you about our Services, 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;
• access, recruit and hire staff;
• perform any other function that we believe reasonable and necessary to protect the security or proper functioning of 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 Handle, you or others.

Where we:

• have your express consent;
• 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 hello@handle.work.

We may disclose your Personal Information to the following service providers:

• Outsourcing Companies: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 5.
• Analytics: as a part of providing you with, measuring and improving our Services, we may engage with analytics providers who collect information utilising tracking technologies on our Website and software to measure visits and traffic on our Website or servers which provide you the Services.
• Related Bodies: we may share information with other entities in the Handle 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.

We will only disclose any Personal Information you have provided to any entity outside of the Handle corporate group if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy. We engage third-party vendors to help deliver our services, including Workplace Platforms and security platforms (each a “Service Provider”).

We use Vanta Inc. (www.vanta.com) (“Vanta”), a third-party compliance and security management platform, to maintain an up-to-date list of our vendors. For more information about our current vendors, please see https://trust.handle.work, or contact us at security@handle.work.

When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to any of the above Service Providers. 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.

We all reasonably necessary measures to protect the information we collect through our Services which are stored electronically. 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.

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.

Your Personal Information may be stored and processed in countries outside of your location, including in jurisdictions that may have different privacy and data protection standards. We use Vanta, to maintain an up-to-date record of the countries where that Personal Information is stored and processed. If you would like more information about these locations, please see https://trust.handle.work, or contact us at security@handle.work.

We retain user data as long as an account is active. If an account has been inactive for 24 months, we will endeavor to delete that user data from our platform.

You can streamline this deletion process by requesting that your account be deleted, in-app, via our contact form or by emailing hello@handle.work. Once we receive a deletion request, we aim to delete user data within 30 days.

Under the GDPR, we must have a legal basis to process Personal Information collected from individuals residing in the European Union. We rely on several legal bases to process your Personal Information, including:

• where it is necessary to provide you with access to, and use of, the Services;
• for our legitimate interests to provide, operate and improve our Services;
• 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.

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 Services to you. As at the date of this Privacy Policy, such third-party recipients are located in 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. It is possible that additional third parties from other countries may be recipients in the future.

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 Privacy Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by a third-party recipient of the relevant Privacy Laws.

Where we:

• have your express consent (which you may withdraw at any time by contacting us in writing at hello@handle.work;
• 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 our Services as well as other products and services we believe may be 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 hello@handle.work.

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. By accessing or using this Website, you agree that we can store and access Cookies in accordance with this Privacy Policy. You will be able to accept or reject the collection of Cookies by us.

Cookies are small files that can be stored on and accessed from a user’s device when the user accesses a website. They enable authorised web servers to recognise you across different websites, services, devices and browsing sessions.

We may use Cookies to enable users to access and use our Website and Services, including to:

• identify users of our Website and Services;
• process user requests;
• improve user experience;
• remember user preferences on our Website;
• monitor the use of our Website and for analysis of our user base;
• facilitate communication with users;
• control access to certain content on our Website; and
• protect our Website.

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.

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

• opting out or adjusting preferences for Cookies when your device accesses the Website;
• customising 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 Services; and
• using your mobile device's operating system to select options on how it collects and utilises your information for interest-based advertising, if accessing the Services from a mobile device).

Subject to some exceptions provided by the relevant Privacy Laws, you may request access to your Personal Information in our customer account database, or seek correction of it, by contacting us at hello@handle.work Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.

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.

Our Services may contain links to other third-party websites and services including social media networks. This Privacy Policy applies solely to information collected by us via our Services.

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at hello@handle.work.

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.

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.