Privacy Policy

Effective from: 1 August 2025

Felix Group Holdings Limited ACN 159 858 509 and its related bodies corporate (Felix) are committed to complying with the Australian Privacy Principles as contained in the Privacy Act 1988 (Cth) (Privacy Act).

The purpose of this policy is to inform individuals about the manner in which Felix collects and manages personal information. By providing personal information to us, you consent to the use and disclosure of that information in accordance with this policy.

Copies of this policy will be made available free of charge to any person who requests it.

What is personal information?

Personal information is defined in the Privacy Act to mean information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Personal information can include sensitive information. Sensitive information is defined in the Privacy Act as information or an opinion about a person's race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.

What kinds of personal information are collected and held by Felix?

Examples of the kinds of personal information that may be collected by Felix include:

name and username;
email address and other contact details such as street address, postal address and telephone number;
details of any sourcing events (e.g. Request for Quotation) through the Felix platform;
details of project/job history;
responses to questionnaires;
information about your activity on the Felix platform;
information about the IP address and device that you use to access the Felix platform;
credit card details and banking details;

How does Felix collect and hold personal information?

Felix collects personal information from:

individuals directly, for example when you register for an account on the Felix platform, communicate with us through our platform or email or telephone our staff;
content provided through, or uploaded to, the Felix platform by you or other users of the platform;
our suppliers, contractors and related entities; and
from public records and other publicly accessible sources.

Upon request, we will provide you with the source of your personal information, unless it is impracticable or unreasonable to do so.

We may use "cookies", traffic measurement software or similar technologies to collect data. Please see our Cookie Policy for further information, available at https://felix.net/cookie-policy.

The purposes for which Felix collects, holds, uses and discloses personal information

Felix may collect, hold, use and disclose personal information for the following purposes: · to operate the Felix platform;

to allow users of the Felix platform to search for vendors (which provides users with access to the name and email address of contacts provided for vendors even if that user has not otherwise previously interacted with the relevant vendor) in order to allow vendors to be discovered and receive opportunities from users;
to verify your identity;
to supply our products and services and to conduct our other business activities;
to facilitate the delivery of any third party products or services that you may purchase through the Felix platform;
to provide you with news and information about products or services offered by us or third parties;
to respond to requests and inquiries;
to contact individuals, via email, regular mail, telephone or otherwise in relation to our platform or our business;
to provide you with information that we believe may be of interest to you or that you have requested;
direct marketing and business development by us including direct marketing of products we or our partners are offering that we believe may be of interest to users of the platform;
to audit and monitor our services;
to undertake research and to develop and improve our platform, products, services and content;
to protect our rights and property;
for security and occupational health and safety purposes;
to investigate or report suspected unlawful activity;
to protect someone's life, health, safety or welfare;
to comply with a law or regulation, or a court order or other legal process.

Felix does not collect any sensitive information through its platform and never uses any sensitive information for direct marketing purposes.

Credit card details

If you provide us with your credit card details for payment of products and services, we will only use that information for the purpose of processing your payment, which includes disclosing the information to our third-party credit card gateway provider. Information relating to electronic transactions entered into via this website will be protected by encryption technology.

Disclosure to other parties

Felix may disclose personal information to:

other users of our platform including other customers and subscribers as described above;
our related entities and affiliates;
our agents, contractors and partners we use to support our business (including IT support and other IT services, payment processors, marketing and analytics services and financial institutions);
our suppliers of goods or services;
your authorised representatives and agents;
our lawyers, accountants and other business advisers;
law enforcement officers, regulators, courts and government agencies - if required by law or regulation, court order or other legal process, to assist in the prevention or detection of crime, in order to protect Felix's or any user of the platform's rights or property, or if necessary to prevent a threat to any person's life, health or safety; and
to any purchaser or prospective purchaser of our business including in conjunction with a corporate sale, merger, dissolution, acquisition or other similar event.

Disclosure outside of Australia

Our servers are hosted in Sydney, Australia

The Felix platform is accessible globally and accordingly any personal information that you choose to share with other users may be disclosed anywhere in the world.

In addition, we are likely to disclose personal information to our supporting operations in the Philippines.

Government related identifiers

Felix does not use any government related identifiers, such as passport number or driver's licence number, as its own identifier of any individual.

Felix will not use or disclose any government related identifiers other than in accordance with the Privacy Act.

Data integrity and security

Felix takes reasonable steps to ensure that the personal information that it collects, uses and discloses is accurate, up-to-date and complete. We encourage individuals to assist us with this by contacting us if you are aware that any of your personal information is not accurate, up-to-date or complete.

Felix takes reasonable steps to protect personal information it holds from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

When Felix no longer needs personal information for any purpose for which the information may be used or disclosed under the Australian Privacy Principles, we take reasonable steps to destroy the information or ensure that it is de-identified, except if the information is part of a Commonwealth record or Felix is required by law or a court or tribunal order to retain the personal information.

We cannot guarantee the security of information transmitted over the internet. We recommend that you take all necessary precautions to protect your personal information while you are online, including installing appropriate operating system updates, browser updates, virus protection software and firewall software.

Sensitive information

If you provide us with sensitive information about other individuals, please ensure that the individual or the individual's representative is aware of the disclosure and that he or she consents to the disclosure to Felix as well as to the handling of their personal information in accordance with this policy. Otherwise you must not provide us with any sensitive information about other individuals.

De-identified data

You consent to us using and disclosing your de-identified data (information that no longer identifies you) for any purpose including without limitation statistical analysis, product or service development, marketing and business planning or any other commercial purpose. We undertake technical measures to ensure that this data cannot be associated back to you.

Automated decision making systems

No personal information collected by us will be used by us in conjunction with the operation of a computer program or artificial intelligence to make a decision, or do a thing that is substantially and directly related to making a decision, that could reasonably be expected to significantly affect the rights or interests of an individual.

Access and correction

Individuals have a right to request access to their personal information and to request its correction. To do so, please contact Felix's Privacy Officer. Contact details are provided below.

Felix does not impose a charge for making a request for access, however we may charge for reasonable administrative costs incurred in providing access.

Felix encourages individuals to advise our Privacy Officer if your personal information requires correction or updating. Felix does not impose any charge with respect to requests for correction or updates.

Before correcting or providing access to personal information in response to a request, Felix will require your identity to be confirmed.

Requests for access or correction may be refused upon the grounds contained in the Privacy Act. If we refuse to provide access, or to correct personal information, Felix will provide you with reasons for the refusal.

Complaints

A person who wishes to complain about a breach of the Australian Privacy Principles by Felix should contact our Privacy Officer.

Felix will not impose any charge for making a complaint, or for dealing with the complaint. Once a complaint has been lodged, our Privacy Officer will acknowledge its receipt to you as soon as possible.

We will do our best to ensure that our investigation is completed, and a decision on your complaint is communicated to you, within 30 days from our receipt of the complaint. We will contact you if we need more time.

You may also contact the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001
Telephone: 1300 363 992
Fax: 02 9284 9666 Website: www.oaic.gov.au

Felix's Privacy Officer

Felix's Privacy Officer's contact details are:

Privacy Officer
Felix Group Holdings Limited
24 Macquarie Street
Teneriffe QLD 4005
Australia

Email: help@felix.net

GDPR

In this section:

the terms Data Controller, Data Processor, Data Subject and Personal Data have the meanings ascribed to them in the GDPR; and
GDPR means, when used in the context of:
- United Kingdom residents—the UK General Data Protection Regulation as implemented by the Data Protection Act 2018; and
- when used in the context of European Union residents—Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC.

We are required to comply with the GDPR in relation our processing of Personal Data in providing our products or services to residents in the United Kingdom or European Union (as applicable).

If you are resident of the United Kingdom or European Union, then in addition to the other provisions in this privacy policy, the provisions in this section also apply to you. (If you do not ordinarily reside in one of those jurisdictions, these provisions will not apply to you.)

Under the GDPR, Felix is:

a Data Controller for Personal Data that we collect about you, for our own use; or
a Data Processor for Personal Data that our customers (as users of our platform) may collect about you,

and that role determines the purposes and means which apply to our processing of your Personal Data.

In addition to your rights of access and correction as set out earlier in this Policy, as a Data Subject you may:

(access) request access to your Personal Data held by us;
(rectification) request to update or rectify any of the Personal Data that we hold about you by contacting us at the details specified above and request Personal Data updates;
(erasure) withdraw your consent to Felix's use of your Personal Data as described in this policy by deletion or erasure of your Personal Data that we hold where that data is no longer required for the purpose for which it was collected;
(restriction on processing) obtain from Felix a restriction on processing of your Personal Data where:
- accuracy of that Personal Data is contested;
- the processing of your Personal Data is unlawful and you oppose erasure but request restriction of use;
- Felix no longer needs your Personal Data; or
- you have objected to processing pursuant to your right to object under Article 21 of the GDPR;
(portability) request that Felix:
- provide you with a copy of the Personal Data that Felix holds about you in a portable and machine readable form; or
- share your Personal Data with a nominated third party.

If you wish to exercise any of your Data Subject rights, then please send your request in writing to our Privacy Officer at the contact details above. We endeavour to process your request promptly and within one month of receipt of receiving it.

Where we are a Data Processor for your Personal Data (meaning we hold your Personal Data only on behalf of our user), we will redirect your request to the Data Controller for instructions, before we or they may respond to you. Accordingly, we encourage you make your request to the Data Controller in the first instance.

If you have any concerns in relation to Felix's collection or processing of your Personal Data, you have a right to complain to a supervisory authority (within the meaning of the GDPR).

Status of this Policy

This policy may be varied by Felix from time to time. Changes will be published on our website prior to the changes becoming effective.

This policy was last updated on 21 March 2025.

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