Containa Privacy Policy

Containa Pty Ltd (ACN/ABN: [PLACEHOLDER — NO ABN/ACN REGISTERED YET; INSERT ONCE AVAILABLE]) ("Containa," "we," "us," "our") provides a software platform for container, freight, warehouse, and logistics invoicing and workflow management (the "Platform"), accessible via our website and associated web, mobile, and progressive web applications (collectively, the "Services").

We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains what personal information we collect, how we use and disclose it, and how you can access, correct, or complain about our handling of it.

Note on business size: Containa currently operates below the AUD $3 million annual turnover threshold that would otherwise make it a "small business operator" potentially exempt from parts of the Privacy Act. We have chosen to comply with the APPs voluntarily as a matter of policy, regardless of any exemption that may technically apply.

Because Containa is a business-to-business ("B2B") platform used by other companies ("Tenant Businesses") to run their own operations, personal information flows through Containa in two distinct ways. It matters which one applies to you:

(a) Information you give us directly

If you are a prospective customer, a website visitor, a Tenant Business's admin or billing contact, or otherwise deal with Containa directly (e.g. signing up for an account, contacting support, subscribing to marketing), Containa is directly responsible for that personal information under the APPs, and this Policy governs it in full.

(b) Information handled on behalf of a Tenant Business

If you are an employee, contractor, driver, warehouse or packing staff member of a Tenant Business, or a customer/contact of a Tenant Business whose shipment, booking, or invoicing details appear in the Platform, your personal information is generally collected and input by the Tenant Business, and Containa processes it on that Tenant Business's behalf and instructions, under our commercial agreement with them — similar in function to a service provider processing data for a client.

In this scenario:

• The Tenant Business is the appropriate party to contact regarding access, correction, or complaints about your personal information, as they control what is collected and why.
• Containa handles this information only to provide, maintain, and support the Platform for the Tenant Business, keeps it confidential, and does not use it for Containa's own independent purposes (e.g. our own marketing) without separate consent.
• If you're unable to resolve a request with the relevant Tenant Business, contact us at the details in Section 13 and we will assist where we reasonably can.

[PLACEHOLDER — the categories below are drafted broadly to cover reasonably foreseeable data types for a logistics/driver/warehouse PWA platform. These need to be confirmed against what the driver, pack, and warehouse apps actually capture (e.g. GPS/location, delivery photos, signatures) before this Policy is finalised or published. Narrow or expand as needed once confirmed.]

Depending on how you interact with us, we may collect:

• Identity and contact information: name, email address, username, phone number, job title, employer/Tenant Business affiliation.
• Account and authentication information: login credentials (stored in hashed/encrypted form), account roles and permissions, session and device identifiers.
• Business and operational data: container/freight bookings, rate cards, invoices, packing and warehouse workflow records, and related logistics data entered into the Platform by Tenant Businesses (which may itself contain personal information about a Tenant Business's own customers or contacts).
• Device and app data (driver, pack, and warehouse PWAs): device type and identifiers, push-notification tokens, and, where the relevant app feature is enabled, potentially location/GPS data, delivery confirmation photos, and electronic signatures — to be confirmed and itemised precisely once each app's data capture is finalised.
• Website and usage data: IP address, browser type, pages visited, referring URLs, and similar log data collected automatically when you visit our website.
• Communications: records of correspondence when you contact support or sales.
• Cookies and similar technologies: see Section 8.

We do not intentionally collect sensitive information (as defined under the Privacy Act, e.g. health, biometric, or government-identifier data) unless a Tenant Business inputs it into the Platform as part of its own operational data; Containa does not independently seek or use such information.

• Directly from you, when you or your Tenant Business create an account, contact us, or use the Services.
• Automatically, through your use of our website and applications (e.g. cookies, log files, push-notification registration).
• From a Tenant Business, where it inputs data about its own staff, drivers, or customers into the Platform.

Where practicable, we collect personal information directly from the individual concerned. Where information is provided to us by a Tenant Business about its own personnel or customers, that Tenant Business is responsible for ensuring it has the appropriate notice or consent in place to provide that information to us.

We collect, hold, use, and disclose personal information to:

• provide, operate, and maintain the Platform and Services;
• create and manage accounts and user permissions across tenant, driver, pack, and warehouse roles;
• process and generate invoices, bookings, and related logistics workflows on behalf of Tenant Businesses;
• send push notifications and service communications relevant to the Services (e.g. job assignments, status updates);
• provide customer support and respond to enquiries;
• maintain the security and integrity of the Platform, including fraud prevention and troubleshooting;
• comply with our legal obligations; and
• with consent (or otherwise in accordance with the Spam Act 2003), send direct marketing communications about Containa's products and services — see Section 6.

We do not sell personal information to third parties.

If you provide us with your contact details (e.g. through the website contact form or a demo request), we may send you marketing communications about Containa's Services in accordance with the Spam Act 2003 (Cth). Every marketing communication will include a functional unsubscribe mechanism, and you may also opt out at any time by contacting us at the details in Section 13. We will not send marketing communications to Tenant Business staff accounts (drivers, pack, warehouse users) without an appropriate basis to do so.

We may disclose personal information to:

• Service providers and subprocessors who help us deliver the Platform, such as cloud hosting, email delivery, and push-notification infrastructure providers. [PLACEHOLDER — insert a specific subprocessor list once finalised, e.g. named hosting provider, email service, push notification service.]
• Tenant Businesses, to the extent relevant information relates to their own staff, drivers, or customers using the Platform under their account.
• Professional advisers, regulators, or law enforcement, where required or authorised by law.
• A purchaser or prospective purchaser of Containa's business or assets, in the event of a sale, merger, or restructure, subject to appropriate confidentiality protections.

We require our service providers to protect personal information consistently with this Policy and applicable law.

Our website currently uses cookies that are strictly necessary for authentication and session management. We may in future use additional cookies or similar technologies for analytics, marketing, or advertising purposes (for example, to understand website usage patterns or measure the effectiveness of marketing campaigns), even though no such tools are active as at the date of this Policy. If and when such tools are introduced, this Policy — together with our separate Cookie Policy — will describe the specific categories of cookies used and the choices available to you.

See our [Cookie Policy] for further detail on cookie types and management.

As at the date of this Policy, Containa's infrastructure and the personal information it holds are hosted in Australia. [PLACEHOLDER — confirm and name the specific hosting region (e.g. AWS ap-southeast-2, Sydney) once finalised, and update this section immediately if hosting ever moves overseas or a subprocessor stores/accesses data outside Australia — this would trigger APP 8 disclosure obligations that are not currently required.] We do not currently disclose personal information to overseas recipients.

We take reasonable steps to ensure the personal information we hold is accurate, complete, and up to date, and to protect it from misuse, interference, loss, and unauthorised access, modification, or disclosure. This includes access controls, encryption of credentials, and role-based permissions across tenant, driver, pack, warehouse, and administrative accounts. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

In the event of an eligible data breach likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches (NDB) scheme in Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.

You may request access to, or correction of, personal information we hold about you that falls under Section 2(a) above (our direct relationship with you), by contacting us using the details in Section 13. We will respond within a reasonable period and may need to verify your identity first.

If you are not satisfied with our response, you may lodge a complaint with the OAIC at www.oaic.gov.au.

If your personal information was provided to Containa by a Tenant Business (see Section 2(b)), please direct access, correction, or complaint requests to that Tenant Business in the first instance.

For any questions about this Privacy Policy or how we handle personal information, contact:

Containa Pty Ltd
Email: support@containa.io
[PLACEHOLDER — registered address to be inserted once available]

[PLACEHOLDER — this Policy is currently drafted on the assumption that Containa Pty Ltd will be registered/operating out of New South Wales, and is expressed to be governed by the laws of New South Wales, Australia. Confirm this once the company's actual state of registration/operation is settled — if it turns out to be Victoria or another state, this clause (and the equivalent clause in the Terms and Conditions) should be updated to match, for consistency.]

This Policy is governed by the laws of New South Wales, Australia.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last updated" date. We encourage you to review this Policy periodically.