Privacy Policy

Effective Date: 18/02/2026 Last Updated: 18/02/2026 Version: 1.0

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1. Introduction

1.1 About This Policy

This Privacy Policy explains how RTO MATE PTY LTD (ABN 41 684 275 401) ("QUALTICKS", "we", "us", or "our") collects, uses, discloses, and protects your personal information.

1.2 Our Commitment

QUALTICKS is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We are an Australian-owned and operated company.

1.3 Scope

This policy applies to:

• Visitors to our website (qualticks.com.au);
• Users of our Platform;
• Subscribers to our newsletter;
• Anyone who contacts us.

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2. Australian Privacy Principles Compliance

We comply with all 13 Australian Privacy Principles. This policy addresses each principle as follows:

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3. Information We Collect (APP 3)

3.1 Information You Provide

We collect personal information that you provide directly, including:

Account Information:

• Full name
• Email address
• Phone number (optional)
• Job title/role
• Organisation name
• RTO registration number (if applicable)

Payment Information:

• Billing address
• Payment method details (processed by our third-party payment provider)

Communications:

• Contact form submissions
• Support requests
• Newsletter subscriptions
• Demo requests

3.2 Information Collected Automatically

When you use our Platform, we automatically collect:

Technical Information:

• IP address
• Browser type and version
• Operating system
• Device information
• Access times and dates

Usage Information:

• Pages viewed
• Features used
• Clickstream data
• Session duration

3.3 Information from Third Parties

We may receive information from:

• Training.gov.au (public RTO and qualification data)
• Third-party analytics providers
• Our CRM provider (HubSpot)

Training.gov.au Data Synchronisation: We periodically synchronise data from Training.gov.au including RTO information, qualification specifications, and VET product details. This synchronisation:

• Occurs at scheduled intervals (not in real-time)
• May result in temporary discrepancies with current Training.gov.au data
• Does not guarantee accuracy or currency of information
• Is subject to Training.gov.au system availability

We cannot guarantee that Training.gov.au data displayed in the Platform is current, accurate, or complete. See Section 9.2 of our Terms of Service for detailed information about Training.gov.au integration and its limitations.

3.4 Sensitive Information

We do not intentionally collect sensitive information (such as health information, racial or ethnic origin, political opinions, or religious beliefs). If you provide sensitive information to us, you consent to its collection and use for the disclosed purposes.

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4. How We Collect Information (APP 3 & 5)

4.1 Direct Collection

We collect information directly when you:

• Register for an account
• Subscribe to our newsletter
• Submit a contact or demo request form
• Communicate with us via email or phone
• Use our Platform

4.2 Cookies and Tracking

We use cookies and similar technologies to:

• Maintain your session and preferences
• Analyse Platform usage
• Improve our services

Types of Cookies:

You can manage cookies through your browser settings. Disabling cookies may affect Platform functionality.

4.3 Collection Notice

At the time of collection, we will notify you of:

• The information being collected;
• The purposes of collection;
• Who we may disclose it to;
• How you can access and correct it;
• The consequences of not providing the information.

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5. Unsolicited Personal Information (APP 4)

If we receive personal information that we did not solicit, we will:

• Determine whether we could have collected it under APP 3;
• If not, destroy or de-identify the information as soon as practicable (unless required by law to retain it).

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6. Anonymity and Pseudonymity (APP 2)

6.1 When You Can Remain Anonymous

You may browse our public website without identifying yourself. However, certain activities require identification:

• Creating an account
• Subscribing to the Platform
• Contacting us for support
• Subscribing to our newsletter

6.2 Pseudonyms

You may use a pseudonym when contacting us for general enquiries. However, you must use your real name when registering for an account to ensure accurate compliance records.

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7. Use of Personal Information (APP 6)

7.1 Primary Purposes

We use your personal information to:

• Provide access to the Platform and Services;
• Process payments and manage subscriptions;
• Respond to your enquiries and support requests;
• Send service-related communications (e.g., account updates, maintenance notices);
• Verify your identity;
• Maintain security and prevent fraud.

7.2 Secondary Purposes

With your consent or where permitted by law, we may also use your information to:

• Send marketing communications about our products and services;
• Conduct research and analytics to improve our services;
• Personalise your experience;
• Comply with legal obligations.

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8. Disclosure of Personal Information (APP 6)

8.1 Who We Disclose To

We may disclose your personal information to:

Service Providers:

• Hosting providers (Australian-based)
• Payment processors
• Customer support tools
• Analytics services

Our CRM Provider:

• HubSpot Inc. (United States) - see Section 10 for cross-border disclosure details

Professional Advisors:

• Lawyers, accountants, and auditors as necessary

Regulatory Authorities:

• ASQA, OAIC, or other authorities when required by law

8.2 When We Disclose

We will only disclose your personal information:

• For the purposes for which it was collected;
• Where you have consented;
• Where required or authorised by law;
• To protect our legitimate interests (e.g., legal proceedings).

8.3 No Sale of Personal Information

We do not sell your personal information to third parties.

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9. Direct Marketing (APP 7)

9.1 When We May Market

We may use your personal information to send you marketing communications about our products and services if:

• You have consented to receive marketing; OR
• You would reasonably expect us to use your information for marketing; AND
• We provide a simple opt-out mechanism.

9.2 What We Send

Marketing communications may include:

• Product updates and new features;
• Industry news and compliance updates;
• Webinar and event invitations;
• Special offers and promotions.

9.3 Opt-Out

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email;
• Updating your preferences in your account settings;
• Contacting us at support@qualticks.com.au.

We will process your opt-out request within 5 business days. Note that opting out of marketing does not affect service-related communications.

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10. Cross-Border Disclosure (APP 8)

10.1 International Transfers

We disclose personal information to HubSpot Inc., located in the United States, for customer relationship management purposes.

10.2 Safeguards

Before disclosing personal information overseas, we take reasonable steps to ensure the recipient:

• Is bound by a law or contract that provides comparable protection to the APPs;
• Maintains appropriate security measures;
• Will only use the information for the disclosed purposes.

10.3 HubSpot

HubSpot Inc. is:

• Certified under the EU-US Data Privacy Framework;
• Bound by a data processing agreement with us;
• Required to protect personal information in accordance with the APPs.

10.4 Your Consent

By providing your personal information, you consent to its transfer to the United States via HubSpot. You acknowledge that US laws may differ from Australian privacy laws, but we have taken reasonable steps to ensure your information is protected.

10.5 Countries

Personal information may be disclosed to recipients in:

• United States (HubSpot CRM)

We do not currently disclose personal information to recipients in any other countries.

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11. Government Identifiers (APP 9)

11.1 Collection

We may collect government identifiers such as:

• ABN (Australian Business Number)
• ACN (Australian Company Number)
• RTO registration numbers

11.2 Use and Disclosure

We will only use or disclose government identifiers:

• For the purposes for which they were collected (e.g., verifying RTO registration);
• As required or authorised by law;
• To verify identity.

We will not adopt government identifiers as our own identifiers for you.

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12. Data Quality (APP 10)

12.1 Our Commitment

We take reasonable steps to ensure personal information is accurate, up-to-date, complete, and relevant for the purposes for which it is used.

12.2 Your Responsibility

You are responsible for:

• Providing accurate information at collection;
• Updating your information if it changes;
• Ensuring the accuracy of compliance-related data you enter into the Platform.

12.3 Verification

We may verify information you provide against:

• Training.gov.au (for RTO data);
• ABN Lookup (for business details).

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13. Data Security (APP 11)

13.1 Security Measures

We implement robust security measures to protect your personal information, including:

Technical Measures:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Multi-factor authentication for administrative access
• Regular security assessments and penetration testing
• Automated vulnerability scanning

Physical Measures:

• Australian-based data centres with ISO 27001 certification
• 24/7 physical security and access controls
• Redundant power and network infrastructure

Organisational Measures:

• Role-based access controls
• Staff privacy and security training
• Incident response procedures
• Regular policy reviews

13.2 Data Hosting

All customer data is stored in Australian data centres, except for contact information shared with HubSpot (United States) as disclosed in Section 10.

13.3 Data Breach Response

In the event of a data breach, we will:

• Contain the breach immediately;
• Assess whether it is an "eligible data breach" under the Privacy Act;
• Notify the OAIC and affected individuals if required;
• Take steps to prevent future breaches.

See our Security Policy for more details.

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14. Access to Personal Information (APP 12)

14.1 Your Right

You have the right to request access to the personal information we hold about you.

14.2 How to Request Access

To request access, contact our Privacy Officer:

• Email: support@qualticks.com.au
• Subject line: "Personal Information Access Request"

14.3 What We Need

To process your request, we may need to:

• Verify your identity;
• Understand what information you are seeking;
• Determine the format you prefer.

14.4 Timeframe

We will respond to your request within 30 days. If we need more time, we will notify you of the reason for the delay.

14.5 Exceptions

We may refuse access if:

• Providing access would pose a serious threat to health or safety;
• Access would have an unreasonable impact on others' privacy;
• The request is frivolous or vexatious;
• Access would prejudice legal proceedings;
• Access would be unlawful;
• Denying access is required or authorised by law.

If we refuse access, we will provide written reasons (unless doing so would be unreasonable).

14.6 Fees

We may charge a reasonable fee for providing access (e.g., administrative costs). We will inform you of any fees before processing your request.

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15. Correction of Personal Information (APP 13)

15.1 Your Right

You have the right to request correction of personal information we hold about you if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading.

15.2 How to Request Correction

To request a correction:

• Update your information directly in your account settings; OR
• Contact our Privacy Officer at support@qualticks.com.au.

15.3 Our Obligations

If we are satisfied that information needs correction, we will:

• Correct the information within a reasonable time;
• Not charge a fee for correction;
• Notify third parties to whom we disclosed the information (if you request and it is practicable).

15.4 Refusal to Correct

If we refuse to correct information, we will:

• Provide written reasons;
• Inform you of your right to complain;
• At your request, attach a statement to the information noting that you believe it is inaccurate.

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16. Data Retention

16.1 Retention Periods

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including:

16.2 Extended Retention for RTO Compliance

For Registered Training Organisations (RTOs), we maintain extended retention periods for compliance-critical data in accordance with Standards for RTOs 2025 and the VET Quality Framework:

Rationale: RTOs must produce evidence of compliance in regulatory audits. These extended retention periods enable QUALTICKS to support RTOs in meeting their obligations under:

• Standards for Registered Training Organisations 2015 (and subsequent updates)
• VET Quality Framework
• State training authority requirements (including VRQA, TAC, and others)
• ASQA audit requirements

16.3 Security During Extended Retention

Data retained for extended periods under Section 16.2 remains subject to the encryption and security measures outlined in our Security Policy.

16.4 Access to Retained Data After Account Closure

Upon account deactivation or termination:

• Account holders may request copies of retained data within 30 days of account closure
• After 30 days, access to retained RTO compliance data is limited to:
  • The former account holder (upon verification for audit purposes)
  • Regulatory authorities when legally required
  • Law enforcement or courts with appropriate legal orders

16.5 Deletion After Extended Retention

Extended retention data will be securely deleted after the retention periods specified in Section 16.2 have elapsed, unless:

• The data is subject to legal hold for litigation or investigation
• Regulatory authorities require continued retention
• The account holder requests continued retention in writing

16.6 Deletion

When personal information is no longer needed (and is not subject to extended retention under Section 16.2), we will:

• Securely destroy the information; OR
• De-identify it so it is no longer personal information.

16.7 Data Export

If you close your account, you may request a copy of your data. We will make data available for export for 30 days after account closure.

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17. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will delete it promptly.

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18. Notifiable Data Breaches Scheme

18.1 Our Obligations

We comply with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth).

18.2 What is an Eligible Data Breach?

An eligible data breach occurs when:

• There is unauthorised access, disclosure, or loss of personal information;
• A reasonable person would conclude that serious harm is likely to result; and
• We have not been able to prevent the likely risk of serious harm through remedial action.

18.3 Notification

If an eligible data breach occurs, we will:

• Notify the OAIC as soon as practicable;
• Notify affected individuals as soon as practicable;
• Include a description of the breach, types of information involved, and recommended steps.

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19. Complaints

19.1 How to Complain

If you believe we have breached the APPs or this policy, you may complain to our Privacy Officer:

Email: support@qualticks.com.au Subject: Privacy Complaint

19.2 What to Include

Please include:

• Your name and contact details;
• A description of your complaint;
• Any relevant documents;
• What outcome you are seeking.

19.3 Our Response

We will:

• Acknowledge your complaint within 7 days;
• Investigate and respond within 30 days;
• Keep you informed of progress.

19.4 OAIC

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au Phone: 1300 363 992 Email: enquiries@oaic.gov.au Address: GPO Box 5218, Sydney NSW 2001

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20. Changes to This Policy

We may update this policy from time to time. We will notify you of material changes by:

• Posting the revised policy on our website;
• Updating the "Last Updated" date;
• Sending an email notification for significant changes.

Your continued use of our services after changes take effect constitutes acceptance of the revised policy.

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21. Contact Us

Privacy Officer RTO MATE PTY LTD

Email: support@qualticks.com.au Address: PO BOX 101 Craigieburn VIC 3064 Phone: support@qualticks.com.au

We aim to respond to all enquiries within 7 business days.