PRIVACY POLICY

LYFE LANGUAGES LTD ACN 671 368 657

1. We respect your privacy

(a)Lyfe Languages Ltd (“Lyfe Languages”, “we”, “us”) respects your privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and manage your personal information.

(b)We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

(c)"Personal information" is information or an opinion about an identified individual, or an individual who is reasonably identifiable. This includes information such as your name, email address, identification number, or any other type of information that is about an individual who is reasonably identifiable.

2. What personal information is collected

(a)Lyfe Languages will, from time to time, receive and store personal information you submit to our websites, provide to us directly or give to us in other forms.

(b)The kinds of personal information that we collect and hold about you may include information such as your name, phone number, address and email address. This information enables us to send you information, provide updates and process your product or service order.

3. How we collect your personal information

(a)Lyfe Languages collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our websites and when we engage in business activities with you.

(b)We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

(c)We may receive personal information from third parties, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services. If we do, we will protect your personal information as set out in this Privacy Policy.

4. How we use your personal information

(a)Lyfe Languages uses personal information that we collect about you for the following purposes:

(i)provide you with products and services during the usual course of our business activities;

(ii)administer our business activities;

(iii)manage, research and develop our products and services;

(iv)provide you with information about our products and services;

(v)communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail; and

(vi)investigate any complaints.

If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our websites.

(b)We may from time to time use your personal information in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). You can opt-out of receiving marketing communications from us by contacting us at rani@lyfelanguages.org or following the “unsubscribe” link in the communication.

(c)We may also use and disclose your information for other purposes as authorised by you, or in accordance with your requests or instructions.

5. Disclosure of your personal information

(a)Lyfe Languages may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy.

(b)We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.

(c)If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

(d)In some cases the people to whom we disclose your personal information may be located overseas and may be subject to different privacy regimes. The countries in which these people are likely to be located include Australia, Africa, Malaysia, New Zealand, Norway, Singapore and United States of America.

6. Websites

(a)When you visit our websites

When you come to our websites (https://www.lyfelanguages.com and https://app.lyfelanguages.org), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our sites, such that we can improve our service.

(b)Cookies

We may from time to time use cookies on our websites. Cookies are small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our websites. Our websites may from time to time use cookies to analyse website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third-party services such as Google AdWords. These ads may appear on our websites or other websites you visit.

(c)Third party sites

Our sites may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third-party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Lyfe Languages is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our websites, to read the privacy statements of each and every website that collects personal information.

7. Storage and security of your personal information

(a)Lyfe Languages take reasonable steps to ensure that any of your personal information which we hold is accurate, complete and up-to-date. These steps include promptly updating personal information when we are advised that the information has changed, checking out contact lists of accuracy, and providing individuals with a simple means to update their personal information.

(b)We store personal information for as long as it is needed for the purpose for which it was collected or as required by law. We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

8. Access to your personal information

(a)You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at privacy@lyfelanguages.com. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity.

(b)There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

9. Complaints about privacy

(a)If you have any complaints about our privacy practices, please feel free to send in details of your complaints to privacy@lyfelanguages.com. We take complaints very seriously and will respond shortly after receiving written notice of your complaint, and will keep you informed of the progress of our investigation.

(b)If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved satisfactorily, you can contact us to discuss your concerns. You are also entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC). Contact details can be found at the OAIC’s website: www.oaic.gov.au.

10. Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Privacy Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our websites or notice board. Please check back from time to time to review our Privacy Policy.

11. General Data Protection Regulation (GDPR) for the European Union (EU)

(a)This section applies to the extent that the GDPR applies to our processing of your personal information. For example, this may be the case where we offer services to a resident in the EU.

(b)Where the GDPR applies, we will act as the controller of any processing of your information on our behalf and will comply with the principles of data protection set out in the GDPR, including in relation to fairness, transparency and lawful data collection and use. We rely on a range of legal bases to process your personal information, depending on the circumstances these legal bases include:

(i)your consent;

(ii)because the processing is necessary for us to perform a contract with you;

(iii)because the processing is necessary for us to comply with legal obligations; or

(iv)because the processing is necessary for the purposes of our legitimate interests, including our legitimate interests in operating the Platform and providing our other products and services.

(c)In addition to the other rights noted in this Privacy Policy, to the extent provided for in the GDPR, you can also object to our processing of your personal information, ask us to restrict our processing of your personal information or request that we transfer your personal information to another person.

(d)If we have obtained your consent to collect your personal information, you can withdraw your consent at any time. Please note that this does not affect the lawfulness of any processing we conducted prior to your consent being withdrawn, nor will it affect ongoing processing of your personal information where we are not relying on your consent.

(e)Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy. We may ask you to verify your identity before acting on any of your requests.

(f)We retain your personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested). We aim to keep your information for no longer than is necessary. We apply our standard document retention and disposal procedures and processes to the information we hold, which take account of retention requirements imposed by law in the jurisdictions where we operate. For more information on our information retention practices you can contact us at the contact details in this Privacy Policy.

(g)As noted above, in some cases personal information that we collect may be disclosed to people in another country where it may be subject to different privacy rules. We take appropriate safeguards to protect your information in these instances. If you are in the EU, you can request further information about the safeguards we put in place to ensure compliance with the GDPR.

(h)Should you wish to report a complaint or if you feel that Lyfe Languages has not addressed your concern in a satisfactory manner, you may contact a relevant local data protection authority in the EU.

Contact details

(a)You may contact us in writing at rani@lyfelanguages.org or at 15 Hospital Avenue, Nedlands Western Australia, 6009 for further information about this Privacy Policy.

Effective date

(a)This policy is effective from 12th September 2023.