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Fraim Privacy Policy

  1. Introduction

  1. The Fraim Application is created, managed, and controlled by Fraim Pty Ltd (ACN 661 995 517) (Fraim, we, us or our).

  2. 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).

  3. 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).

  4. 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.

  1. The information Fraim collect about you

    1. Personal Information

      1. 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.

      2. Fraim collects and uses 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.

      3. 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.

      4. 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:

        1. your account registration information (for example, full name, email address, username and password);

        2. contact details (for example, full name, address, mobile and telephone numbers and email address);

        3. business details (for example, business name, business address, job title, work mobile and office telephone number and work email address);

        4. any information, data, meta-data and materials that you upload, store, transmit or publish on, or via, the Fraim Application;

      5. 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;

      6. 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;

      7. payment and billing information; and

      8. other information that you provide to us or that we may collect in the course of our relationship with you.

    1. Sensitive Information

      1. 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.

      2. If you have accidentally sent us Sensitive Information, please contact us using the details below.

  2. How Fraim collect Personal Information

    1. Direct collection from you

      1. 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:

        1. when you set up or update an account or other registration on the Fraim Application;

        2. when you visit, access and use the Fraim Application, the Services and our Site;

        3. 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;

        4. when you otherwise interact or communicate with us, such as by telephone, email or in person; or

        5. from publicly available sources of information; or

        6. when otherwise legally authorised or required to do so.

      2. 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.

      3. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

    2. Collection from third parties

      1. We may also collect Personal Information about you from publicly available sources and third parties, including:

        1. when you provide your Personal Information to third parties (including to our related bodies corporate, business partners, service providers and third party contractors);

        2. if you use:

          1. our social media sites or applications, pages or plugins;

          or

          1. 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.

        3. if third party payment processors are used by us to process payments made by you.

      2. When Fraim collects your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.

      3. If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:

        1. inform them that you are providing their Personal Information

        to us; and

        1. advise them that they can contact us for further information.

      4. 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.

      5. 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.

  3. How Fraim use your Personal Information

    1. Purposes of use and disclosure

      1. Fraim only uses, processes and discloses your Personal Information for the purposes for which it is collected.

      2. In particular, Fraim use, process and disclose your Personal Information to:

        1. provide you with access to, and use of, the Fraim Application, the Services or Site;

        2. 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

        3. 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;

        4. to customise the advertising and content on our Site;

        5. to verify your identity;

        6. to conduct fraud, risk reduction and creditworthiness checks;

        7. 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;

        8. charge and bill you for the use of the Fraim Application;

        9. for direct marketing purposes (see section 6 below);

        10. to comply with regulatory or other legal requirements,

        11. for any purpose to which you have consented; and

        12. for any other purpose notified to you at the time of collection.

      3. 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.

    2. Disclosure to third parties

      1. Fraim employs advanced AI models to facilitate and enhance user interactions within the application. These interactions often involve users setting daily goals or planning activities through conversational interfaces. The primary functions of the AI in these processes are inference and summarisation to better understand and respond to user queries and inputs. Here's how we handle and safeguard your data in this context:

        1. User-generated content such as text inputs from conversations are shared with AI models. This data is used to perform real-time analysis and generate responses that aid users in tracking their daily tasks and achieving their goals.

        2. It is important to note that the data shared with AI models is strictly for operational purposes — specifically, for inference and summarisation within your current interaction. We do not use this data to train or refine the AI models.

        3. Users are required to give explicit consent for their data to be processed in this manner, distinct from any other consents provided (such as Google OAuth). This consent is obtained during the user's initial account setup through a clear and specific prompt, ensuring that users are fully informed about what data is being used, how, and why.

        4. Users may opt out of data sharing with third-party tools at any time. To withdraw consent, users can access their settings within the app and deselect the permissions granted to third-party data sharing. Instructions for opting out are clearly detailed in our app's settings section, ensuring that users can easily exercise their rights to privacy and data control.

      2. We may provide your Personal Information and Non-Personal Information to the following recipients:

        1. 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;

        2. 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

        3. external business advisors, such as auditors, lawyers, insurers and financiers,

          (collectively, Authorised Affiliates).

      3. 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.

      4. 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, store, use, process, alter and disclose your Personal Information.

      5. 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.

    3. Overseas disclosure

      1. 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.

      2. 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.

      3. 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.

    4. Use of Google API data

      1. Any information received from Google APIs is managed in strict accordance with the Google API Services User Data Policy, including its Limited Use requirements. This information is primarily used to enhance your user experience and improve our application's

        functionalities, consistent with the policies outlined here: Google API Services User Data Policy.

    5. Disclaimer

      1. Fraim will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless:

        1. we are otherwise required by the relevant Privacy Laws;

        2. we are permitted to under this Privacy Policy; or

        3. 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.

      2. 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.

  4. 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.

  5. Marketing communications

    1. Direct marketing

      1. 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.

      2. These communications may continue, even after you stop using the Fraim Application and the Services.IIC of the Privacy Act.

    2. Communication channels

      1. Fraim may send this information to you via the communication channels specified at the time you provide your consent.

      2. 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.

    3. Opting-out

      You can opt out of receiving these communications by:

      1. contacting us using the details below; or

      2. using the unsubscribe function in the email or SMS.

  6. Storage and security

    1. Protecting your Personal Information

      1. 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.

      2. Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.

      3. Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and Non-Personal Information take reasonable steps to:

        1. protect and maintain the security of your Personal Information and Non-Personal Information; and

        2. comply with the Australian Privacy Principles when accessing and using your Personal Information.

    2. No guarantee

      1. 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.

      2. 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.

    3. 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.

  7. Accessing and correcting your Personal Information

    1. 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.

    2. 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.

    3. 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.

    4. We will endeavour to respond to your request for access or correction within 1 month from your request.

  8. Cookies policy

    1. 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.

    2. 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.

    3. We may use cookies and similar technologies to:

      1. 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

      2. 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.

    4. 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.

    5. 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.

    6. 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.

  9. Privacy complaints

    1. 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.

    2. At all times, privacy complaints:

      1. will be treated seriously;

      2. will be dealt with promptly;

      3. will be dealt with in a confidential manner; and

      4. will not affect your existing obligations or your commercial arrangements with us.

    3. Our Privacy Officer will endeavour to:

      1. respond to you within 10 business days; and

      2. investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.

    4. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.

  10. How to contact us

    Fraim can be contacted by email at privacy@fraim.ai.

  11. Changes to this Privacy Policy

    1. 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.

    2. We encourage you to check our Site from time to time to ensure you are familiar with our latest Privacy Policy.

hello@fraim.ai

351 Elizabeth St, Melbourne, AUS

© Fraim 2024. All Rights Reserved.

hello@fraim.ai

351 Elizabeth St, Melbourne, AUS

© Fraim 2024. All Rights Reserved.

hello@fraim.ai

351 Elizabeth St, Melbourne, AUS

© Fraim 2024. All Rights Reserved.