Fraim Privacy Policy
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Introduction
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The Fraim Application is created, managed, and controlled by Fraim
Pty Ltd (ACN 661 995 517) (Fraim, we, us or our).
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We are committed to ensuring your personal information is protected.
We manage your personal information in accordance with the Australian
Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
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By accessing and using the Fraim Application, the Services and our
website (fraim.com) (Site), you agree to this Privacy Policy. For the purpose of this Privacy
Policy, Services means the data migration, modelling, storage and visualisation
services and solutions made available through the Fraim Application
(including customer support services provided by Fraim from time to
time).
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This Privacy Policy outlines how we collect, store, process, use and
disclose your Personal Information, and how you may access your
Personal Information (as defined in the Privacy Act) kept by us or how
you may make a privacy complaint.
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The information Fraim collect about you
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Personal Information
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Personal information has the same meaning that it has under the Privacy Act, namely,
information means information or an opinion about an identified
individual or an individual who is reasonably identifiable, whether
the information or opinion is true or not and recorded in a material
form or not.
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Fraim collect and use Personal Information and Non-Personal
Information from visitors to our Site, customers and authorised users
of the Fraim Application and Services, purchasers of any other
products or services offered by us from time to time, and any other
individual who interacts with us.
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Fraim will only collect and hold Personal Information about you that
is reasonably necessary to undertake our business activities and
functions, make the Fraim Application available to you and deliver our
Services to you, or as otherwise permitted by law.
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The type of Personal Information and Non-Personal Information that we
collect and use depends on the type of dealings that you have with us
and includes the following:
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your account registration information (for example, full name, email
address, username and password);
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contact details (for example, full name, address, mobile and
telephone numbers and email address);
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business details (for example, business name, business address, job
title, work mobile and office telephone number and work email
address);
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any information, data, meta-data and materials that you upload,
store, transmit or publish on, or via, the Fraim Application;
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information relating to your dealings, or enquiries you have made,
with us, including information about the Services (or other products
and services) you have ordered or purchased from us;
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information regarding your access and use of the Fraim Application,
the Site including location information, your device’s internet
protocol (IP) address, unique device identifier, browser
characteristics, device characteristics, operating system, language
preferences, URL preferences, information on actions taken by you on
the Fraim Application or the Site, the dates and times you accessed
the Fraim Application or Site and other analytics and usage
statistics;
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payment and billing information; and
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other information that you provide to us or that we may collect in
the course of our relationship with you.
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Sensitive Information
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We do not collect your Sensitive Information (as defined by the
Privacy Act). However, some of our services are automated and we may
not recognise that you have accidentally provided us with Sensitive
Information.
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If you have accidentally sent us Sensitive Information, please
contact us using the details below.
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How Fraim collect Personal Information
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Direct collection from you
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We will collect Personal Information about you in a number of
different ways. We may collect Personal Information directly from you
or in the course of our dealings with you. For example:
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when you set up or update an account or other registration on the
Fraim Application;
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when you visit, access and use the Fraim Application, the Services
and our Site;
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when you contact us by email, telephone or submit query via our Site,
or when you request information about the Fraim Application and the
Services, complete any forms or agreements for our other products or
services offered by us, request customer support services or setup
services, participate in surveys, competitions or promotional events
or when you subscribe to our publications, alerts and newsletters;
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when you otherwise interact or communicate with us, such as by
telephone, email or in person; or
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from publicly available sources of information; or
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when otherwise legally authorised or required to do so.
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When we collect Personal Information directly from you, we will take
reasonable steps to notify you (using a collection notice) at, before,
or as soon as practicable after, the time of collection.
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By providing your Personal Information to us, you acknowledge that
you are authorised to provide such information to us.
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Collection from third parties
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We may also collect Personal Information about you from publicly
available sources and third parties, including:
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when you provide your Personal Information to third parties
(including to our related bodies corporate, business partners, service
providers and third party contractors);
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if you use:
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our social media sites or applications, pages or plugins; or
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data visualisation software tools that interact with the Fraim
Application or other third party products and services that interact
with, or connect with, the Fraim Application.
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if third party payment processors are used by us to process payments
made by you.
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When Fraim collects your Personal Information from third parties, we
shall take reasonable steps to make sure you are aware of the
collection.
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If you provide us with Personal Information about another individual
(as their authorised representative), we rely on you to:
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inform them that you are providing their Personal Information to us;
and
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advise them that they can contact us for further information.
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You must take reasonable steps to ensure the individual is aware of,
and consents to, the matters outlined in this Privacy Policy,
including that their Personal Information is being collected, the
purposes for which that information is being collected, the intended
recipients of that information, the individual's right to access
that information, and who we are and how to contact us.
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Upon our request, you must also assist us with any requests by the
individual to access or update the Personal Information you have
collected from them and provided to us.
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How Fraim use your Personal Information
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Purposes of use and disclosure
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Fraim only use, process and disclose your Personal Information for
the purposes for which it is collected.
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In particular, Fraim use, process and disclose your Personal
Information to:
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provide you with access to, and use of, the Fraim Application, the
Services or Site;
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manage, operate, maintain, test, develop, improve and upgrade the
Fraim Application, systems, the Services, Site (or other products and
services offered by us from time to time); and
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notify you of opportunities we think you might be interested in,
including new product or service offerings, information about the
Fraim Application and Services, offers, competitions, promotions,
events and surveys;
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to customise the advertising and content on our Site;
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to verify your identity;
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to conduct fraud, risk reduction and creditworthiness checks;
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to perform research and analysis about the Services, the Fraim
Application and Site and for data analytics purposes, including usage
patterns, trends, benchmarking and other statistical or behavioural
data. Before we use your Personal Information for this purpose,
we ensure Personal Information is made anonymous by removing data that
can identify you;
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charge and bill you for the use of the Fraim Application;
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for direct marketing purposes (see section 6 below);
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to comply with regulatory or other legal requirements,
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for any purpose to which you have consented; and
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for any other purpose notified to you at the time of collection.
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In the event of a merger, acquisition or sale of the whole or part of
our business or assets, we reserve the right to transfer your Personal
Information as part of the transaction, without your consent or notice
to you.
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Disclosure to third parties
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With your consent, we may provide your Personal Information and
Non-Personal Information to the following recipients:
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our employees, related entities, business partners, third party
contractors, suppliers and agents from time to time for the purpose of
delivering, providing and administering the Services (including
customer support services and setup services), the Fraim Application,
our Site, our promotions, deals and competitions;
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third party service providers who process or use your Personal
Information and Non-Personal Information for the purpose of performing
functions on our behalf, but may not process or use such information
for any other purpose. Examples of these third-party service providers
include, but are not limited to, such as cloud-based accounting
software platform, analytics service providers; marketing and
analysis organisations, financial and credit card institutions to
process payments, hosting companies, web developers, internet service
providers, customer service providers, customer support specialists,
data visualisation software providers, fulfilment companies and
research and data analysis firms, government agencies, public
registries, search agencies, regulatory and licensing bodies, parties
to whom you refer us (for example, previous employers and referees);
and
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external business advisors, such as auditors, lawyers, insurers and
financiers,
(collectively, Authorised Affiliates).
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When we disclose your Personal Information to any of our Authorised
Affiliates, we will ensure that they undertake to protect your
privacy. Authorised Affiliates are not permitted to use the
information for any purpose other than the purpose for which they have
been given access.
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Our Authorised Affiliates may also provide us with Personal
Information collected from you. If you disclose Personal Information
to an Authorised Affiliate, we rely on you to provide the Authorised
Affiliates with consent for us to collect, storage, use, process,
alter and disclose your Personal Information.
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Fraim may also disclose any Personal Information we consider
necessary to comply with any applicable law, regulation, legal
process, governmental request or industry code or standard.
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Overseas disclosure
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In the course of providing you with access to, and use of, the Fraim
Application and Services, it may become necessary or desirable to
disclose Personal Information to Authorised Affiliates located
overseas. The countries in which these overseas recipients may be
located will depend upon the individual circumstances.
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The laws where these overseas recipients may be located provide
various levels of protection for Personal Information which are not
always equivalent to the level of protection that may be provided for
in Australia. Where we transfer your Personal Information overseas,
Fraim will take reasonable steps to ensure that your Personal
Information is treated securely and the means of transfer provides
adequate safeguards.
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By accessing or using the Fraim Application, or providing your
Personal Information to us, you explicitly and freely consent to the
transfer of your Personal Information to our overseas Authorised
Affiliates. If you do not wish to receive information from any of our
Authorised Affiliates, please let us know using the details below.
However, if you do not provide your Personal Information to us or our
Authorised Affiliates, we may not be able to provide you with access
to, and use of, the Fraim Application or Site.
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Disclaimer
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Fraim will not disclose your Personal Information to any third party
(other than our Authorised Affiliates) without your written consent,
unless:
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we are otherwise required by the relevant Privacy Laws;
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we are permitted to under this Privacy Policy; or
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such disclosure is, in our opinion, reasonably necessary to protect
our rights or property, avoid injury to any person or ensure the
proper functioning of the Fraim Application.
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This Privacy Policy only covers the use and disclosure of information
we collect from you. The use of your Personal Information by any third
party is governed by their privacy policies and is not within our
control.
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Notifiable Data Breaches Scheme
In the event of any loss, or unauthorised access or disclosure of your
Personal Information that is likely to result in serious harm to you,
Fraim will investigate and notify you and the Australian Information
Commissioner as soon as practicable, in accordance with notifiable data
breach scheme contained in Part IIIC of the Privacy Act.
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Marketing communications
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Direct marketing
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Fraim may use and disclose your Personal Information to send you
information about the Fraim Application, the Services and other
products or services we may offer from time to time, as well as other
information that may be of interest to you.
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These communications may continue, even after you stop using the
Fraim Application and the Services.
IIC of the Privacy Act.
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Communication channels
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Fraim may send this information to you via the communication channels
specified at the time you provide your consent.
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These communication channels may include mail, email, SMS telephone,
social media or by customising online content and displaying notices
or advertising on the Fraim Application.
- Opting-out
You can opt out of receiving these communications by:
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contacting us using the details below; or
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using the unsubscribe function in the email or SMS.
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Storage and security
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Protecting your Personal Information
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We take reasonable steps in the circumstances to keep your Personal
Information and Non-Personal Information safe. We use a combination of
technical, administrative, and physical controls to protect and
maintain the security of your Personal Information, including use of
Secure Sockets Layer (SSL) which is an encryption technology used to
protect data as it travels over the internet and Cryptographic Hash
Functions which anonymise and protect the security of your Personal
Information.
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Our officers, employees, agents and third-party contractors are
expected to observe the confidentiality of your Personal Information
and Non-Personal Information.
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Wherever possible, we procure that Authorised Affiliates who have
access to your Personal Information and Non-Personal Information take
reasonable steps to:
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protect and maintain the security of your Personal Information and
Non-Personal Information; and
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comply with the Australian Privacy Principles when accessing and
using your Personal Information.
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No guarantee
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The transmission of information via the internet is not completely
secure. While we do our best to protect your Personal Information and
Non-Personal Information, we cannot guarantee the security of any
Personal Information and Non-Personal Information transmitted through
the Fraim Application or Site.
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You provide your Personal Information and Non-Personal Information to
us at your own risk and we are not responsible for any unauthorised
access to, and disclosure of, your Personal Information and
Non-Personal Information.
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Destruction of Personal Information
We will destroy or de-identify Personal Information where it is no
longer required, unless we are required or authorised by law to retain
the information.
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Accessing and correcting your Personal Information
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Fraim shall use our reasonable endeavours to keep your Personal
Information accurate, up-to-date and complete. You have the right to
access any Personal Information we hold about you, subject to some
exceptions under the Privacy Act.
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You can access, or request that we correct, your Personal Information
by writing to us using the details below. Fraim may require proof of
identity. If we do not allow you to access any part of your Personal
Information, we will tell you why in writing.
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We will not charge you for requesting access to your Personal
Information but may charge you for our reasonable costs in supplying
you with access to this information.
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We will endeavour to respond to your request for access or correction
within 1 month from your request.
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Cookies policy
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Fraim and its Authorised Affiliates may collect information by
automated means when you access and use the Fraim Application or Site
by utilising features and technologies of your internet browser,
including cookies and similar technologies. A cookie is a piece of
data that enables us to track and target your preferences.
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The type of information we and our Authorised Affiliates collect may
include statistical information, details of your operating system,
location, your internet protocol (IP) address, the date and time of
your visit, the pages you have accessed, the links which you have
clicked and the type of browser that you were using and browser and
login authentication status.
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We may use cookies and similar technologies to:
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enable us to identify you as a return user, make it easier for you to
login to the Fraim Application and personalise and enhance your
experience and use of the Fraim Application or Site; and
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help us improve our Service to you when you access the Fraim
Application or Site and to ensure that the Fraim Application and Site
remain easy to use and navigate.
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Most browsers are initially set up to accept cookies. However, you
can reset your browser to refuse all cookies or warn you before
accepting cookies.
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If you reject our cookies or similar technologies, you may still use
the Fraim Application or Site but may only have limited functionality
of the Fraim Application or Site.
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We may also use your IP address to analyse trends, administer the
Fraim Application, our Site and other websites we operate, track
traffic patterns and gather demographic information.
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Privacy complaints
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If you have any issues about this Privacy Policy or the way Fraim
handle your Personal Information, please contact us using the details
below and provide full details of your complaint and any supporting
documentation.
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At all times, privacy complaints:
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will be treated seriously;
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will be dealt with promptly;
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will be dealt with in a confidential manner; and
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will not affect your existing obligations or your commercial
arrangements with us.
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Our Privacy Officer will endeavour to:
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respond to you within 10 business days; and
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investigate and attempt to resolve your concerns within 30 business
days or any longer period necessary and notified to you by our Privacy
Officer.
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If you are dissatisfied with the outcome of your complaint, you may
refer the complaint to the Office of the Australian Information
Commissioner.
- How to contact us
Fraim can be contacted by email at [email protected].
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Changes to this Privacy Policy
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From time to time, it may be necessary for us to review and revise
our Privacy Policy. We may notify you about changes to this Privacy
Policy by posting an updated version on our Site.
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We encourage you to check our Site from time to time to ensure you
are familiar with our latest Privacy Policy.