Privacy Policy

Version 2.0 Effective on and from June 2024
Zeligate Pty Ltd ACN 669 471 523 (Zeligate, we or us) is committed to providing quality services to you and this policy explains how we collect, use, disclose and protect information that applies to our AI workforce solutions platform (Services), and your choices about the collection and use of your information. Capitalised terms that are not defined in this Privacy Policy have the meaning given to them in our Customer Agreement. If you do not want your information processed in accordance with this Privacy Policy in general or any part of it, you should not use our Services. This policy applies to all users of our Services.

Where we provide the Services under contract with an organisation (for example, your employer), that organisation controls the information processed by the Services. For more information, please see the End user section below. This policy does not apply to the extent we process personal information in the role of a processor on behalf of such organisations.

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1. INFORMATION WE COLLECT

We collect information about you when you input it into the Services or otherwise provide it directly to us, including:

● Account and Profile Information: We collect information about you when you register for an account, create or modify your profile, set preferences or sign-up for the Services. For example, you provide your contact information and billing information when you register for the Services.

● Content you provide or make available through the Services: We also collect any messages you send us through the Services and information you submit, post, display, transmit, or otherwise made available on the Services in the Customer Content (such as files, photos, documents, audio, digital works, livestreams, videos, profile information, comments, questions, and other content). We use this information to operate, maintain, and provide the features and functionality of the Services to you, to correspond with you, and to address any issues you raise about the Service.

● Content you provide through our websites: The Services also include our websites owned or operated by us. We collect other content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, activities or events.

● Payment Information: We collect payment and billing information when you register for certain paid Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services, including:

● Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size and filenames of attachments you upload to the Services; search terms; and how you interact with others on the Services. We also collect information about the teams and people you work with.

● Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address and other items. We use your IP address and/or country preference in order to approximate your location to provide you with a better experience.

● Cookies and Other Tracking Technologies: Zeligate and our third-party partners use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognise you across different Services and devices. Further information about our use of cookies is set out below.

We may also receive information about you from other users of our Services, from third-party services, from our related companies, social media platforms, public databases, and from our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalised advertising and suggest services that may be of interest to you.

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Cookies

Definition of cookies

We use the term cookie to describe cookies and similar technologies such as tags and pixels. Cookies are small data/text files that websites place on your computer, laptop or mobile device.

Our use of cookies

We use cookies for the following purposes:

To improve the performance of our websites by understanding which parts work well, and which don't.
To deliver relevant online advertising to you both on our websites and elsewhere. This is sometimes done by combining data that we already have about you with the data collected through cookies. These cookies are placed by us and selected third parties and enable adverts to be presented to you on our and third-party websites.
To measure how effective our online advertising and marketing communications are.
To enable us to collect information about how you and other people use our websites.
To improve your experience on our websites, including your use of the Services.

What Cookies do we use?

Necessary cookies. Necessary cookies enable basic functions of the website. The website will not work properly without these cookies.
Analytical cookies and cookies that improve performance. These cookies collect information on how users use our websites and the Services and allow us to improve the functioning of our websites. The data is aggregated and anonymised, which means we cannot identify you as an individual. An example of analytical cookies are cookies used within Google Analytics.
Functional cookies. These cookies allow us to provide enhanced functionality and personalise content for you. For example, they're used to recognise you when you return to our websites. If you do not allow these cookies then some or all of these services may not function properly.
Advertising cookies. These cookies help us decide which products, services and offers may be relevant for you. We use this data to customise the marketing content you see on websites, apps and social Media They also help us understand the performance of our marketing activities. These cookies are set by us or our carefully-selected third parties.

Web beacons

We also use a tracking technology called web beacons which is a clear image that works similarly to cookies and are used to track online movements. Web beacons are embedded invisibly on a web page or HTML-based email. We use web beacons to help measure the effectiveness of a particular campaign.

Blocking or enabling cookies

You have the right to accept or decline cookies by modifying the appropriate settings within your browser. Blocking some types of cookies may negatively impact your experience on our websites and limit the features and services we can provide. Most web browsers allow you to control cookies through the browser settings. Please see your browser support information on how to do this. If you set your browser to reject cookies you may not be able to make full use of our websites.

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2. USING YOUR INFORMATION

We use the information we collect about you for the purposes set out below:

1. Providing you with the Services: We use the information that you directly give us to provide the Services to you. This includes allowing you to log in to Zeligate, operating and maintaining the Services, processing the Customer Content and giving you access to the Customer Content. We also use information we collect about you automatically to remember information about you so that you will not have to re-enter it during your visit or the next time you visit the site.

2. For data analytics: We use information about you to help us improve the Services and our users’ experience, including by monitoring aggregate metrics.

3. For data and predictive analytics: We may analyse content, uploads and activity in your account to provide and customise the Services and to train our algorithms and models using machine learning in order to improve our Services.

4. Customising the Services for you: We use and combine the information you provide us and information about you that we collect automatically and receive from other sources and combine it with information about the behaviour of other users to make sure that your use of the Services is customised to your needs.

5. To communicate with you about the Services: We use your contact information to Get in Touch with you and to send communications about critical elements of the Services. For example, we may send you emails about technical issues, security alerts or administrative matters.

6. To promote and drive engagement with Zeligate: We use your contact information to Get in Touch with you about taking part in our surveys or about features and offers relating to the Services that we think you would be interested in. We also use information we collect about you to make sure that you get the most relevant offers and promotions based on your use of the Services.

7. To improve the Service: We analyse information about your use of the Services and your Customer Content to better understand how users are engaging with our Services and measure the effectiveness of the Services so that we can make improvements and develop our Services for users.

8. For security measures: We use information about you and from within your account to monitor activity that we think is suspicious or potentially fraudulent, and to identify violations of this Privacy Policy or our Customer Agreement.

9. For customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyse crash information, and to repair and improve the Services. Where you give us express permission to do so, we disclose information to a third-party expert for the purpose of responding to support-related requests.

10. For matters that you have specifically consented to: From time-to-time Zeligate may seek your consent to use your information for a particular purpose. Where you consent to our doing so, we will use it for that purpose. Where you no longer want us to use your information for that purpose you may withdraw your consent to this use.

11. For matters that we are required to use your information by law or for enforcement: Zeligate will use or disclose your information where we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Customer Agreement or to protect the security or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of Zeligate, our users or others.

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3. DISCLOSING YOUR INFORMATION

When you use the Services, we disclose certain information about you to other users of the Services, including:

1. For collaboration: You can create content, which may contain information about you, and grant permission to others to see, disclose, edit, copy and download that content. Some of the collaboration features of the Services display some or all of your profile information to other users of the Services when you disclose or interact with specific content.

2. Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organisation or associate that email address with your existing account, and such organisation wishes to establish an account or site, certain information about you including your name, contact info, content and past use of your account may become accessible to that organisation’s administrator and other users of the Services sharing the same domain.

We disclose information to third parties that help us operate, provide, improve, integrate, customise, support and market our Services, including:

1. Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, marketing, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including appropriate security and confidentiality procedures designed to protect your information.

2. Third Party Apps: You, your administrator or other users of the Services may choose to add new functionality or change the behavior of the Services by installing third party apps within the Services. Doing so may give third-party apps access to your account and information about you like your name and email address, and any content you choose to use in connection with those apps. If you are an administrator, or a technical or billing contact listed on an account, we disclose your details to the third-party app provider upon installation. Third-party app policies and procedures are not controlled by us, and this privacy policy does not cover how third-party apps use your information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to information about you being disclosed to these third parties, please uninstall the app.

3. Links to Third-Party Sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit.

4. Third Party Services: We may offer you the ability to interact with or disclose information to third parties through the Services. When you intentionally interact with these third parties, we may disclose certain information to those third parties or receive information from those third parties, consistent with your privacy settings on the third-party service. Such information may include contact information, identification, and demographic information, and device information and identifiers. You should always check the privacy settings and notices in these third-party services to understand how those third parties may use your information.

5. With your consent: We disclose information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

6. Compliance with laws and for enforcement: We may disclose information about you to a third party if we believe that disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements; (b) enforce our agreements, policies and terms of service; (c) protect the security or integrity of our products and services; (d) protect Zeligate, our customers or the public from harm or illegal activities; or (e) respond to an emergency which we believe in good faith requires us to share information to assist in preventing the death or serious bodily injury of any person.

7. Affiliates: We may disclose information we have about you to other Zeligate corporate affiliates in order to operate and improve products and services and to offer other Zeligate affiliated services to you.

8. Business transfers: We may disclose or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

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4. Limited Use

Data accessed via Google APIs is used solely to provide requested services to you. We prohibit ads, unauthorised access/use, and comply with Google's data policies and Google Privacy Policy. Explicit user consent is obtained for covered API scopes. Data is retained temporarily for service provision, then deleted / anonymized. No sharing with 3rd parties unless authorised or legally required. Our Google API use fully complies with applicable policies.

Youtube API Client Terms of Use and Privacy Policies as we currently use YouTube API services.
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5. AI and Third Party Data sharing

Zeligate application leverages third-party AI models including Claude 3 and OpenAI GPT-4 models to generate results and share data with these models for each service.

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5.1 Calendar

Zeligate calendar service utilizes the below fields of calendar events.

Summary
Creator
Create, start, and end time
Sender’s email
Attendees’ emails
Response statuses

The purpose of sharing this data with AI models includes using AI models to generate corresponding results per users’ command. e.g., a quick view of daily/weekly/monthly meetings or availability check.

Zeligates use this data to enable users to immediately obtain a brief view of important meetings every period by voice input or selecting suggestive prompts.

5.2 Email

Zeligate email service utilizes the below fields of email messages.

Subject
Sender's and receivers' emails
Snippet
Date
Attachments
Email threads

The purpose of sharing this data with AI models includes using AI models to generate corresponding results per users’ command. e.g., summary, action items, tones of email threads or suggestive drafts.

Zeligates use this data to enable users to immediately obtain a brief summary of important emails every period by voice input or selecting suggestive prompts.

5.3 Overall

Do users have any options to control or opt out of data sharing with AI models?

There is no option for an an opt out as this removes a significant proportion of the products features, however users can choose not to opt in through the onboarding process and emails modal.

Zeligate ensures responsible and ethical use of data adhering to the policy of the AI models.

According to Claude 3 usage policy and OpenAI privacy policy, they don’t use users’ privacy for training models without consent. Zeligate only utilises user data as prompts to generate results. Therefore we can ensure our user-sensitive information is not exposed to the public for the principle of ethical use of data.

Claude 3 Usage Policy https://www.anthropic.com/legal/aup
OpenAI Privacy policy https://openai.com/policies/privacy-policy

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6. STORING, TRANSFERRING AND SECURING YOUR INFORMATION

Your information collected through the Services will be stored and processed in Australia and any other country in which Zeligate or its subsidiaries, affiliates or service providers maintain facilities or employ staff or contractors.

Zeligate may transfer information that we collect about you, including personal information, to affiliated entities, and to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. As a result, we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. However, we will take steps to ensure that your information remains protected wherever it is stored and processed in accordance with applicable laws.

We use industry standard technical and organisational measures to secure the information we store. We care about the security of your information and use appropriate safeguards to preserve the integrity and security of all information collected through the Services. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Zeligate, at all times. However, Zeligate cannot ensure or warrant the security of any information you transmit to Zeligate or guarantee that information on the Services may not be accessed, disclosed, altered or destroyed.

Following termination or deactivation of your account, Zeligate will retain your profile information and Customer Content for a commercially reasonable time, and for as long as we have a valid purpose to do so. In particular, Zeligate will retain your information for the purpose of complying with its legal and audit obligations, and for backup and archival purposes.

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7. ACCESSING OR CORRECTING YOUR PERSONAL INFORMATION

You have certain choices available to you when it comes to your information. Where applicable under local law, you may have certain rights with respect to your personal information.

Depending on which jurisdiction you live in, you may have rights to request information about our processing of your information, to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, to request your information in a structured, electronic format, to request to correct or update your information, to request to opt out of “sales” or “sharing” of personal information and targeted advertising (as these terms are defined under applicable law), and to request to opt out of certain profiling activities.

You can do any of these things by emailing us at privacy@zeligate.ai.

If you request access to your personal information or ask us to correct or update information about you, we may need to verify your identity. In some circumstances, there may be a valid reason for us to deny your request to access or correct your information. If we do this, we will tell you why.

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8. Additional information for users in Europe

This section applies to users who live in the European Economic Area (EEA), Switzerland or United Kingdom (UK). Zeligate processes your personal data in accordance with European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR). For the purposes of the GDPR and UK GDPR, Zeligate Pty Ltd is the controller of your personal data. Zeligate Pty Ltd’s registered address is at Gold Coast, Australia.

We need a lawful basis to collect, use and disclose your personal data as a controller in these jurisdictions. Our lawful basis will depend on the information concerned and the context in which it is processed. Generally, we will collect and use your information as follows:

Contractual necessity: We need it to provide the Services to you and fulfil our obligations to you under our Terms and Conditions. For example, this includes creating and maintaining your account, resolving issues you may experience with the Services, obtaining payment for our Services and providing you with access to the Customer Content.
Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and customised Service, sending you relevant marketing messages, displaying advertising and tracking its effectiveness, using information we collect about you so that we can make more informed decisions and offers for our users and enhancing our Services. We do not rely on this lawful basis where our legitimate interests are overridden by your rights and interests.
Consent: You consent to us, and our third party partners, using your information in a certain way – for example, to hear about new features or offers, and for machine learning and predictive analysis relating to your Customer Content.
Legal obligations: It is necessary for compliance with our legal obligations – for example, to disclose your information in response to law enforcement requests and to retain your information for our record keeping purposes.

If you consented to our use of your information, you can withdraw that consent at any time. You can withdraw your consent by emailing us at privacy@zeligate.ai. Where we use your information for our legitimate interest, you have the right to object to that use by emailing us at privacy@zeligate.ai. However, if you do, it may diminish the quality of the Services you receive or prevent you from using the Services.

You understand and agree that Zeligate Pty Ltd (an entity in Australia) will receive and process your personal data. We may transfer your personal data to other countries where our affiliates and service providers are located. Please note that some of these countries may have data protection laws that are different from your country (and, in some cases, may not be as protective). For users in the EEA, Switzerland or UK, where we transfer your information to a third-party service provider that is not located in Europe, and is not in a country that benefits from an adequacy decision by the European Commission, UK or Swiss authorities, we will require those third party providers to enter into an agreement that provides appropriate safeguards for your information, including by using the EU Model Clauses and the UK International Data Transfer Addendum.

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9. Additional information for users in the United States

9.1 Categories of personal information collected by Zeligate

For more details about the personal information Zeligate has collected in the last 12 months, please see section 1 “Information we collect”. For details on how we use that information, please see section 2 “Using your information”. For details on who we share that information it with, please see section 3 “Disclosing your information”. For details on how long we keep that information, please see section 4 “Storing, transferring and securing your information”.

9.2 Rights in respect of your personal information

These state privacy laws give resident users various rights with respect to the personal information we collect, including the rights detailed in section 5 “Accessing or correcting your personal information”.

9.3 Exercising your rights

You may make a request by emailing us at privacy@zeligate.ai. We will authenticate your request using the email address associated with your account and if necessary, proof of residency. Depending on applicable state law, you may also appeal a refusal to take action on a request by emailing us at privacy@zeligate.ai. You may opt out of the “selling or sharing” of your personal information by emailing us at privacy@zeligate.ai.

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10. END USERS

Where the Services are made available to you through an organisation (e.g. your employer), that organisation is the administrator of the Services and is responsible for the accounts and/or Services sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organisation's policies. We are not responsible for the privacy or security practices of an administrator's organisation, which may be different to this policy.

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11. HANGES

We may change this Privacy Policy from time to time. We will post any updates to this Privacy Policy on this page. We encourage you to review our Privacy Policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy, you will need to stop using the Services and deactivate your account.

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12. COMPLAINTS

If you would like more information about how we handle your information or our approach to privacy, or to exercise any of your rights outlined above, please contact our Privacy Compliance Officer:

We will investigate any complaint and inform you of the outcome. If you are not satisfied with the outcome of any internal investigation we conduct, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/contact-us or on 1300 363 992.

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13. CONTACT US

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information or a request from you to access or correct your personal information, you can contact us using the details set out below. Please include your name, email address and telephone number and clearly describe your complaint.

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Privacy Compliance Officer
Zeligate Pty Ltd
Gold Coast

Email: privacy@zeligate.ai