TacCom PRIVACY AND COOKIE POLICY

Welcome to TacCom's Privacy and Cookie Policy (“Policy”). All references in this policy to “TacCom”, “we”, “us”, or “our”, refer to TacCom, its parent companies, and its subsidiaries such as OzVet Pty Ltd. This Privacy Policy describes how TacCom collects, uses and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as ‘Personal Data’) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.

When we refer to 'TacCom', we mean TacCom, as explained in more detail in the 'Identifying the data controller and processor' section below.

Applicability of this Privacy Policy

This Privacy Policy applies to TacCom’s online workplace productivity tools and platform, including the associated TacCom mobile and desktop applications (collectively, the ‘Services’). If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of TacCom’s business. For the avoidance of doubt, this is the only privacy policy that applies to TacCom.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the TacCom platform (‘Third-Party Services’), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the ‘Customer Agreement’), including the processing of data such as messages, files or other content submitted through Services accounts (collectively, ‘Customer Data’). The organisation (e.g. your employer or another entity or person) that

entered into the Customer Agreement (the ‘Customer’) controls its instance of the Services (its ‘Workspace’) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

Information we collect and receive

TacCom will collect and receive information through operating the Services and Websites, and through other interactions with TacCom. Such information will include Customer Data and other information and data (‘Other Information’) in a variety of ways:

Customer Data. Customers or individuals granted access to a Workspace by a Customer (‘Authorised Users’) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to TacCom when using the Services.
Other Information. TacCom also collects, generates and/or receives the following categories of Other Information:
1. Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) supply TacCom with an email address, password, domain and/or other account set-up details.
2. Usage information:
  - Services metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way that an Authorised User uses the Services. For example, TacCom logs the Workspaces, channels, people, features, content and links that you view or interact with, the types of files shared and what Third-Party Services are used (if any).
  - Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page that you visited before using the Website or Services, browser type and settings, the date and time that the Services were used, information about browser configuration and plugins, and your language preferences.
  - Device information. TacCom collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
3. Cookie information: TacCom uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options.
4. Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace and TacCom can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorised Users to enable and disable these integrations for its Workspace TacCom may also develop and offer TacCom applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with TacCom. For example, if a cloud storage application that you are using is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorised Users, along with additional information that the application makes available to TacCom to facilitate the integration. Authorised Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to TacCom. When a Third-Party Service is enabled, TacCom is authorised to connect and access Other Information made available to TacCom in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including by its Authorised User(s)). Examples of information which TacCom may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to TacCom usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.
5. Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorised User chooses to import (such as importing an address book to find colleagues and TacCom Connect contacts or calendar from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
6. Third-party data: TacCom may receive data about organisations, industries, lists of companies that are customers, website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information that we collect and might include aggregate-level data, such as which IP addresses correspond to postcodes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively “Information”). However, certain Information is collected automatically and if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How we process your information and our legal bases for doing so

Customer Data will be used by TacCom in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality and as required by applicable law. TacCom is a processor of Customer Data and the Customer is the controller. The Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data, and otherwise apply its policies to the Services.

TacCom uses Other Information to operate our Services, Websites and business. More specifically, TacCom uses Other Information for the following purposes:

Compliance with a legal obligation:

TacCom processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use Workspace and account information, usage information, cookie information, Third-Party Services information, contact information, third-party data, and additional information provided to TacCom for compliance with a legal obligation.

Legitimate interests:

We rely on our legitimate interests or the legitimate interests of a third party where they are not outweighed by your interests or fundamental rights and freedoms (‘legitimate interests’).

We use Workspace and account information, usage information, cookie information, Third-Party Services information, contact information, third-party data, audio and video metadata, and additional information provided to TacCom for the following legitimate interests:

To provide, update, maintain and protect our Services, Websites and business. This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities, or at an Authorised User’s request.
- It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.
To develop and provide search, learning and productivity tools and additional features. TacCom tries to make the Services as useful as possible for specific Workspaces and Authorised Users. For example, we may:
- improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User;
- make Services or Third-Party Service suggestions based on historical use and predictive models;
- identify organisational trends and insights;
- customise a Services experience; or
- create new productivity features and products.
- It is in our interest and in the interest of Customers and Authorised Users to continuously improve and develop the customer support that we provide.
To investigate and help prevent security issues and abuse. We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how TacCom is used or to prevent spam or abuse.
- It is in our interest to keep the Services secure and to detect, prevent and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.
To aggregate or de-identify information. In some cases, we aggregate or de-identify information that we have associated with you and use the resulting information, for example, to improve the Services.
- It is in our interest to research and improve the Services;
- It is in the interests of Customers and Authorised Users to practice data minimisation and privacy by design in respect of their information.
Share information with others, including law enforcement, and to respond to legal requests.
- It is in our interest and the interest of the general public to prevent and address fraud, unauthorised use of TacCom, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.
Transfer, store or process your information outside the European Economic Area. As the Websites and Services operate globally, with Customers around the world, we need to share information that we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea and the United States, to provide, update, maintain and protect our Services, Websites and business. For more information, review the ‘International data transfers’ section below.
- It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.

We use Workspace and account information, Third-Party Services information, third-party data and additional information provided to TacCom for the following legitimate interests:

To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- It is in our, our Customers’ and Authorised Users’ interests to facilitate communication (for example to answer questions from Customers).
To send service emails and other communications. For example, we may:
- send you service, technical and other administrative emails, messages and other types of communications; or
- o contact you to inform you about changes in our Services, our Services offerings and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt out of them. It is in our Customers’ and Authorised Users’ interests to address service-related issues.

How we share and disclose information

This section describes how TacCom may share and disclose Information, as described in the section entitled ‘Information we collect and receive’ above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. TacCom does not control how a Customer or any third party chooses to share or disclose Information.

The Customer's instructions. TacCom may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.
Displaying the Services. When an Authorised User submits Information, it may be displayed or discoverable to other Authorised Users in the same or connected Workspaces or TacCom Connect instances. For example, an Authorised User’s email address may be displayed with their Workspace profile, or other profile and organisational information may be displayed to Authorised Users.

Collaborating with others. The Services provide different ways for Authorised Users working in independent Workspaces to collaborate, such as TacCom Connect or email interoperability. Information, such as an Authorised User’s profile and organisational information, may be shared, subject to the policies and practices of the Workspace(s) that you use. For example, depending on the settings of your Workspace, to enable connections with other Authorised Users, your profile may be shared or searchable or discoverable by Authorised Users or other users outside of the Workspace(s) that you belong to, or shared via email when you invite an Authorised User or other user to collaborate via TacCom Connect. In many instances, TacCom includes either administrator controls or user controls, depending on the use case, with respect to external collaboration. Authorised Users may also decide to expand the visibility of certain content and Customer Data, such as files.

Customer access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details, or to export logs of Workspace activity.

With consent. TacCom may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For Workspaces registered to corporate entities, TacCom may share Information with consent of the Workspace primary owner or authorised corporate officer, or their designee. For workplaces created without a formal affiliation, TacCom may require user consent.

Data retention

TacCom may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features that you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for TacCom to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Security

TacCom takes security of data very seriously. TacCom works hard to protect Information that you provide from loss, misuse and unauthorised access or disclosure. These steps take into account the sensitivity of the Information that we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, TacCom cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.

Age limitations

TacCom does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to this Privacy Policy

TacCom may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, TacCom will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the ‘controller’ and ‘processor’ of information. In general, the Customer is the controller of Customer Data. In general, TacCom is the processor of Customer Data and the controller of Other Information

Contacting TacCom

Please also feel free to contact TacCom if you have any questions about this Privacy Policy or TacCom’s practices or if you are seeking to exercise any of your statutory rights. TacCom will respond within a reasonable timeframe. You can contact us at privacy@TACVE.com.au or at our postal address below:

Attention: Privacy Statement Personal

PO Box 2481

Rowville VIC 3178 Australia

Email: privacy@tacve.com.au

TacCom will use commercially reasonable efforts to promptly respond and resolve any problem or question.