PRIVACY POLICY

This Privacy Policy has been adopted by Zown Pty Ltd (ACN 658 764 455) (“Zown”, “we” “our” or “us”) and applies to Zown’s handling of personal information.

By subscribing to the Zown app (“the App”), by visiting or registering on the Zown websites found at domains zown.app and parents.zown.app (“the Websites”) or otherwise providing us with your personal information for any purpose and by any means, you agree to us dealing with your personal information in accordance with this Privacy Policy, as may be varied from time to time, and you hereby acknowledge and consent to us collecting, using, storing, and disclosing your personal information as set out herein.

This Privacy Policy will apply to both you and your child / minor and you should review and discuss this Privacy Policy with your child / minor prior to using the App or the Websites (collectively “the Sites”) to ensure you both understand what information we will collect when your child / minor uses the App, or when either of you access the Websites, and how we will use and share that information, prior to allowing your child / minor to use the App or providing us with any personal information. By approving the subscription and payment of the subscription fees through the relevant app store used to subscribe to the App, you, as the child’s parent or legal guardian, consent to the collection and handling of your child’s / minor’s personal information in accordance with this Privacy Policy.

Zown is designed to provide your child / minor with access to positive material related to the categories of information set out on the Websites. Your child / minor can view content and also provide their own contributions via the Zown Contributor’s Corner, where they can upload content on certain topics. All content uploaded via the Contributor Corner is vetted by Zown prior to publishing for viewing on the App, and if approved, is published without reference to the child’s legal name.

If any material is submitted by a child / minor via the Zown Contributor’s Corner, which Zown considers requires referral to a relevant authority, due for example, to possible health and safety concerns, physical or mental harm concerns, or other related concerns, Zown may refer such content to the relevant authorities without further notice. Such content will not be published on the App.

Zown deals with personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Zown does not intentionally collect any personal information from anyone located outside of Australia or monitor anyone outside of Australia’s use of the Sites. The App is available to users based within Australia only at this stage.

Collection of Personal Information

The types of personal information that we collect directly from you and / or your child / minor will depend on the nature of yours and their dealings with us. We only collect the personal information that we reasonably need to carry out one or more of our functions or activities. We may collect your personal information directly from you when you provide us with your personal information through the Sites, including, but not limited to via any AI on the Sites, via social media accounts operated by us, by email if you send us an enquiry, or in any other way in which you provide it to us.

We will only collect personal information about you directly from you unless it is unreasonable or impracticable to do so. We may collect personal information about a child / minor from a parent or guardian of the child / minor or directly from the child / minor if they provide it to us.

If you provide us with any information relating to a third party, you warrant to us that you have the right to authorise us to process that information in accordance with this Privacy Policy.

The following table sets out the personal information we may collect from you / your child when you deal with us in certain ways and why we need to collect it:

Circumstances when we might collect personal information from you / how we collect it What we might collect Why we need to collect it / how we use it

When you subscribe to be part of our mailing list Your name and your email address To send you our emails (including direct marketing emails).

When you enter a promotion advertised by us This will depend on the purpose of the promotion and the information we collect, and what we intend to do with it, which will be set out in the full terms and conditions for the promotion and made available to you on our social media accounts and / or the Websites, as the case may be. To administer the promotion, including to contact you if you win and to provide you with any prizes.

When you interact with us through our social media accounts Your name, your social media handle and, in some cases, your contact information including your phone number and your email address as well as any other personal information which you provide to us. To interact with you and meet your requests.

When you send us an enquiry Any personal information you provide to our user support team, which might commonly include your full name, your date of birth, your email address, your contact phone number, and any other information you provide to us. To assist you with your enquiry.

When you subscribe and create an account through the App Your full name, your child’s / minor’s full name, your email address, your Apple ID (or equivalent), your date of birth, your child’s / minor’s date of birth, your username (being a name chosen by you), the name of the country in which you reside, details about your preferences and whether you are an adult or a child. To approve you and / or your child / minor as users of the App, to create and maintain your account and subscription, to make the App available to you and / or your child / minor for use and to show you and / or your child / minor the information which is most relevant to you or which you or they have shown that you or they are most interested in.

When you register to access parents.zown.app Your name and email address are a requirement for registration by Ghost the host of parents.zown.app

Ghost’s servers are located in Amsterdam, The Netherlands. Ghost’s privacy policy is available on their website

It is a requirement for use of Ghost hosted sites for users to register. Personal information provided at the time of registration will be used for the purpose of maintaining the registration, and by Zown for sending newsletters and direct marketing from Zown from time to time if you have subscribed.

When you or your child interacts with any AI on the Site Your child’s name and any other information your child provides. To enable the AI to collect information and respond as requested.

When you access or use the Sites, we may also collect technical data, such as your IP address, device identifiers and location data and any other online identifiers that could be used to identify you. We use this information for internal purposes such as auditing, data analysis, and research to improve the Sites, including to undertake updates to the App. We may also use this information to protect our interests or enforce our commercial terms.

We will not directly collect or store any credit card details you provide when making a purchase through the App or when you make a payment of your subscription fees for subscribing to the App. Your credit card details are provided directly to and processed by the App store you use to subscribe to the App or make the purchase. You should refer to their Privacy Policy to understand how they will handle your personal information.

2. Use of Personal Information

The particular purpose for which we collect personal information will either be explained when we collect that information, is set out in this Privacy Policy or will be obvious from the context in which it is collected.

In addition to the ways in which we use your personal information in certain circumstances as set out above, we may also use the personal information we collect from you in the following ways:

to send you any special offers or promotions available from us or anyone we partner with for joint promotions if you have consented to receive our direct marketing materials;

to send important notices, such as updates to the App and changes to our terms of use and policies;

to help us deliver and improve the Sites and for loss prevention and anti-fraud purposes;

to enforce any of our terms of use or to comply with or enforce other commercial agreements of which we are a party, or to protect our rights or property;

for internal purposes such as auditing, data analysis, and research to improve the Sites and our user communications;

to enable third party service providers engaged by us to perform tasks like technical, logistic or other business tasks on our behalf; and

for account and network security purposes.

We will only use your personal information for the particular purpose we collected it for as set out herein, for any purpose for which you have consented as set out herein or in any subsequent consent, or for other purposes that are directly related to that purpose. If we want to use personal information for any other purpose, we will obtain your consent.

If you have consented to receive our direct marketing materials, we may send you direct marketing material via email, or other channels. You may opt out of receiving direct marketing material from us at any time by unsubscribing using the feature in any email communication sent to you by us.

We will not send direct marketing material to your child / minor via the App or their email, however they may view readily available content on the App which advertises third party sponsors in cases where third parties have sponsored specific pieces of content.

3. Disclosure of Personal Information

We may disclose your personal information to third parties if required by law, if necessary to report a data breach, or as otherwise permitted under the Privacy Act or other local laws. We may also disclose your personal information as is reasonably necessary to enforce any of our terms of use or to comply with or enforce other commercial agreements to which we are a party, or to protect our rights or property.

We may disclose personal information to our related entities, officers, employees and contractors and external service providers who help us operate or protect our business and to maintain the Sites, for example, app stores, IT consultants, developers, website hosts, advertising agencies, professional analytics tool providers, insurance advisors, independent contractors, lawyers, accountants and other professional advisors. When we engage external service providers, we require those contractors to comply with contractual privacy obligations that reflect our own privacy obligations where possible.

We may also exchange your personal information with third parties for the purpose of fraud protection.

We may disclose your personal information to any authority as contemplated by our Terms of Use and App Custom End-User Licence Agreement.

In the event of a re-organisation, merger or sale, we may transfer any and all personal information we collect to the relevant third party on a confidential basis for them to use in the same way that we use that information.

We do not rent or sell personal information to third parties in our usual course of business. We may use your personal information to advertise third parties’ goods or services to you where those third parties have agreed with us to sponsor certain pieces of content or paid us a fee to advertise their goods or services through any of the Sites.

Your personal information may de-identified and aggregated with other information to use or disclose the anonymous data.

4. Storage and security of Personal Information and overseas disclosure

Personal information provided to us is stored securely using reasonable security measures. Our employees and contractors who have a need to access personal information held by us, access that personal information through password protected electronic devices.

Your passwords created by you to access the App are handled by Firebase Authentication. We do not directly store your password information. We use Firebase Analytics to collect usage information and understand usage of the App. This information is processed anonymously. Firebase is located in Iowa, USA. You can view the Firebase Privacy Policy on the Firebase website.

Zown uses Google Firebase Firestore to collect and store email addresses for the purpose of electronic direct mail marketing. Firestore is based in Oklahoma USA. You can view the Firestore Privacy Policy on the Google Firebase Firestore website. Parents.zown.app is hosted by Ghost and will require a name and email address for registration. The Ghost server for data storage is located in Amsterdam, The Netherlands. You can view the Ghost Privacy Policy on the Ghost website.

Firebase and Firestore are based in the United States of America (USA) and the information collected by them will be transmitted to and stored by Firebase and Firestore on servers located outside Australia. Ghost is located in The Netherlands and the information collect by them will be transmitted to and stored on Ghost servers located outside Australia.

When interacting with any AI on the Sites, information provided by you will be collected by, and stored with, OpenAI. You can view OpenAI’s terms and privacy policy on OpenAI’s website. Open AI provides that information to Zown to enable Zown to provide the Sites’ functionality.

By using the App, or by joining our email community:

you understand and acknowledge that Zown utilises Firebase, Firestore, OpenAI and Ghost for the purposes set out herein, that Firebase, Firestore and OpenAI are located in the United States of America (USA) and Ghost is located in The Netherlands and that relevant local legislation of will apply, and you consent to that disclosure;

you consent to your personal information being collected, used, disclosed and stored as set out in Firebase’s, Firestore’s, OpenAi’s and Ghost’s Privacy Policies, and agree to abide by their relevant terms of use; and

that by consenting to that disclosure, Australian Privacy Principle 8.1 contained in Schedule 1 of the Privacy Act will not apply.

5. Access, correction and retention of Personal Information

You have the right to seek access to the records of personal information that we hold about you. You also have the right to ask us to correct your personal information where it is not otherwise correctly recorded.

If you wish to access the personal information that we hold about you, please set out your request in writing, and send it to us using the contact details set out at the end of this Privacy Policy.

Unless we are otherwise required by Australian law, or a court / tribunal order to retain the information, we will take reasonable steps to destroy the personal information that we hold about you and your child / minor, or to ensure that the information is de-identified, when we no longer need to retain the information for any purpose for which the information may be used or disclosed by us as set out herein.

In most cases, we will only continue to store your personal information provided to us when subscribing to and creating an account on the App or Websites for so long as you and / or your child / minor are subscribed to use the App or Websites, and if you or we terminate your subscription to the App, we will shortly thereafter erase personal information held by us about you and your child / minor unless otherwise required by law. We may continue to send you email communication until you unsubscribe to receive those emails, which you can do via the link in any email communication sent to you by us.

6. Management of privacy online

In general, you can visit parts of the Websites without telling us who you are or revealing personal information about yourself. If you wish to access specific content in parents.zown.app you will be required to register your name and email address for access. There are also other times when we may need to collect personal information from you. For instance, if you wish to subscribe to use the App, we will need to collect some personal information from you to create and maintain your account. At the time of collection, we will seek your permission to send you further electronic communications, and for your personal information to be stored in accordance with this Privacy Policy.

The Sites contain links to third-party websites. Information collected by third parties, which may include personal information, is governed by their privacy practices and not ours. You should review those policies prior to providing any personal information via those third-party websites.

We may from time to time decide to use cookies on the Sites to measure your use of the Sites, and to improve the Site functionality. Whilst most internet browsers are set to accept cookies, you can set your internet browser to reject cookies, or to notify you when they are being used. If you reject cookies, you may limit the functionality of the Site when you access it.

If you subscribe to the App and create an account then you must take all reasonable steps to create secure passwords and login information and to protect that information from unauthorised use.

No data transmission over the internet can be guaranteed as completely secure. We are not responsible for any unauthorised use of personal information by third parties which is outside of our reasonable control.

7. Networks and technologies

To advertise the App, we may target branded ads and banners to you when you are on other websites and apps. To do this we may utilise a variety of networks and technologies such as web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as specific services offered by some sites and social networks.

The types of advertisements you see may be based on the information you provide to us while interacting with the Sites, as well as ads you have engaged with previously.

Social media platform pixels may be installed on the Websites from time to time and capture your use of the Websites for ad retargeting purposes.

By continuing to use any of the Sites, you consent to us using networks and technologies as set out herein.

8. Complaints

If you have any questions about this Privacy Policy, or if you wish to make a complaint about how we have handled the personal information we hold about you, please send us an email to our privacy offer at help@zown.app setting out the details of your question or complaint.

Any complaint will be investigated, and the outcome of that investigation communicated to you within 30 days. If you are not satisfied with the outcome or the handling of the complaint by us, you can contact the Office of the Australian Information Commissioner by calling 1300 363 992 or by sending an email to enquiries@oaic.gov.au.

9. Review of Policy

We periodically review this Privacy Policy and reserve the right, at our absolute discretion, to modify or remove portions of this Privacy Policy at any time by publishing revised versions on the Websites.