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PRIVACY POLICY

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1. OVERVIEW
This is the Privacy Policy for the Verireal software program (‘Verireal’) created by 100 Points Pty Ltd
or “we, our, us” and it explains how we handle personal information and acknowledges our
obligations under the Privacy Act 1988 (Cth) (Privacy Act).


By proceeding to use Verireal you warrant to us that you accept this Privacy Policy. If you do not
agree, you must not use Verireal.


2. COLLECTION OF YOUR PERSONAL INFORMATION
2.1. We collect personal information as required for the purposes of providing the Verireal
service, and for operating and managing our business as required or permitted by law. The
personal information we collect depends on the type of enquiry you make with us. For the
purposes of Verireal, we may collect:


2.1.1. your name, address, email address, and phone number;
2.1.2. Date of birth, drivers licence number, passport number, medicare card number;
2.1.3. Images of your driver licence, passport, and other photo identification;
2.1.4. A photograph or video of your face; and
2.1.5. Your general location whilst you are using Verireal to verify your identity.
2.2. We may also collect information about your preferences which might relate to other
services and products that we offer.


3. USE OF YOUR PERSONAL INFORMATION
3.1. We generally use and disclose your personal information for the purposes for which we
collected it (as described above) and for other related purposes that you would reasonably
expect. Generally, these purposes include:
3.1.1. providing our services to you;
3.1.2. responding to your enquiries;
3.1.3. to connect you with independent contractors and assist with the provision of services
to you;
3.1.4. to assist you in relation to any issue or problem you are having with a particular
service;
3.1.5. providing you with marketing information or updates about our services;
3.1.6. obtaining your feedback on your experiences with us and conducting other
promotional activities;
3.1.7. for our general business operations (for example, maintenance of our business
records, compliance with our legal and insurance obligations, research and
development, business planning and statistical purposes); and
3.1.8. as otherwise permitted or required by law.


4. SHARING YOUR PERSONAL INFORMATION
4.1. Other than your Verifier, we may disclose your personal information to independent
contractors and third-party services providers for the reasons described above and including
but not limited to, providing services to you, marketing and promotions, handling customer
support enquiries, processing transactions, connecting you with providers to obtain finance,
conveyancing, property management and other related services by us, our channel partners
and our related bodies corporate.

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4.2. Generally, we will not disclose your personal information to overseas recipients. However, in
some cases, it may be necessary and we may disclose personal information we hold about
you to recipients who are located outside of Australia where permitted by law.


5. HOW AND WHERE WE STORE YOUR PERSONAL DATA
5.1. The personal information received by Verireal is encrypted in transit using AES-256 bit SSL
standard. Access to the data required a 25-character passcode with AWS cloud storage,
which has server storage facilities in many countries.


5.2. The data is encrypted with an app key, meaning that if the database was stolen or hacked, it
still cannot be decrypted without the internal server key.


5.3. There are no links to the stored documents, and the verification links (URL) expire after 15
minutes.


5.4. The internet is not a guaranteed secure method of transmitting information. Accordingly, we
cannot and do not accept responsibility for the security of the methods you use to transfer
information when you send it to us or where you receive it from us over the internet, or for
any unauthorised access or use of that personal information by others.


6. YOUR RIGHTS
6.1. You have the right to ask us not to process your personal data for marketing purposes. We
will usually inform you (before collecting your data) if we intend to use your data for such
purposes or if we intend to disclose your information to any third party for such purposes.
You can exercise your right to prevent this from occurring via the ‘opt out’ options provided.
You can also exercise the right at any time by submitting an inquiry on our website:
www.verireal.me.


6.2. Our site may, from time to time, contain links to and from the websites of our partner
networks, advertisers and affiliates. If you follow a link to any of these websites, please
note that these websites have their own privacy policies and that we do not accept any
responsibility or liability for these policies. Please check these policies before you submit
any personal data to these websites.


7. ACCESS TO INFORMATION
7.1. The Australian Privacy Principles give you the right to access information held about you.
Your right of access can be exercised in accordance with those principles and the Privacy Act
and is subject to exceptions provided by law. You may be required to put your request in
writing for security reasons.


7.2. We will take all reasonable steps to correct any information you find inaccurate. Should we
deny access and or refuse to correct your personal information, we will provide you with
reasons that will be based on the grounds provided by the Privacy Act. All requests for
access to personal information should be made by submitting an inquiry on our website
www.verireal.me


8. COMPLAINTS
8.1. We place a high priority on effectively dealing with any complaints you might have about
breach of your privacy. We prefer that complaints about breaches of the Privacy Act and the
Australia Privacy Principles are made or confirmed in writing so that we can be sure about
the details of the complaint. Generally, we will only accept complaints from an individual
who believes an act or practice of us has interfered with their privacy and may have
breached one of the Australian Privacy Principles.


8.2. A complaint should identify whether it is about:
8.2.1. the collection, use or disclosure of personal information;
8.2.2. the security or storage of personal information;
8.2.3. the accuracy of personal information;

8.2.4. a refusal to give access to, change or delete personal information.
8.3. A privacy officer whom we elect will normally deal with privacy complaints. If the privacy
officer is involved in the conduct the complaint is about, the complaint will be dealt with by
an alternative privacy officer appointed by us who was not involved in the complaint.
8.4. We will attempt to confirm with the complainant:
8.4.1. their understanding of the conduct relevant to the complaint;
8.4.2. their understanding of the Australian Privacy Principles relevant to the conduct;
8.4.3. what they expect as an outcome.
8.5. We will inform the person making the complaint:
8.5.1. whether we will conduct an investigation;
8.5.2. the name, title and contact details of the investigating representative.
8.6. After we have completed our enquiries, we will contact the complainant, usually in writing,
to advise the outcome and invite a response to our conclusions about the complaint. If a
response is received, we will assess it and advise if we have changed our view.
8.7. If the complainant is unsatisfied with the outcome, we will advise further options including,
if appropriate, review by the Privacy Commissioner within the Office of the Australian
Information Commissioner.


9. CHANGES TO OUR PRIVACY POLICY
9.1. We reserve the right to make amendments to this Privacy Policy at any time.


9.2. Any changes we may make to our privacy policy in the future will be posted on this page
and, where appropriate, notified to you by e-mail. We recommend you check our site
frequently to see any updates or changes to our Privacy Policy.


9.3. If you have any objections to our Privacy Policy, you should not access or use our site.


10. CONTACT US
10.1. Questions, comments and requests regarding this Privacy Policy are welcomed and
should be submitted online through our website www.verireal.me.

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ACN 654 230 289   |   ABN 85 654 230 289

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