Dual-Jurisdiction Privacy Policy (Australia & New Zealand)

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website www.smartplanner.io (“Site”) and any current or future web or mobile applications that is part of the Smart Planner platform.

This Policy outlines how Smart Planner Software Solutions Limited trading as Smart Planner (we, our, us) collects, uses, stores and discloses personal information in the course of its business from employees, applicants, contractors, clients, suppliers and other individuals (referred to as “you” or “your”).

This policy is designed to comply with:

• The Privacy Act 2020 and Information Privacy Principles (IPPs) - New Zealand

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) - Australia

1. Scope and Application

   This Privacy Policy applies to all operations conducted in New Zealand and Australia, including cross‑border data processing, SaaS platforms, AI systems, analytics environments and cloud‑hosted solutions operated by Smart Planner.

   
   

2. Legal Bases for Processing Personal Information

   We process personal information under the following lawful bases:
   • Consent
   • Performance of a Contract
   • Legitimate Interests
   • Legal Obligations
   • Vital Interests

   
   

3. Collection of Personal Information

   We will:
   • Only collect personal information necessary for our functions or activities
   • Collect information by lawful and fair means
   • Provide notice of collection purposes
   • Collect directly where practicable
   • Avoid unreasonably intrusive collection practices

   
   

4. Types of Personal Information Collected

   We may collect:
   • Name and email addressIdentity and contact information
   • Employment and contractor data
   • Financial and billing data
   • Service usage data
   • Device, browser and analytics data
   • Survey responses
   • Marketing preferences
   • Any additional data voluntarily provided

   
   

5. Sensitive Information

   Sensitive information is afforded higher protection and includes personal data, biometrics and similar categories under both APPs and IPPs.

   We only collect sensitive information where:
   • Consent is obtained, or
   • Required or authorised by law

   
   

6. Use and Disclosure of Personal Information

   We use personal information for:
   • Service delivery
   • Contract administration
   • Recruitment and workforce management
   • Client engagements
   • Platform access and authentication
   • Analytics and product improvement
   • Legal and regulatory compliance

   We may disclose information to:
   • Clients and partners
   • Contractors and suppliers
   • Government authorities
   • Law enforcement bodies
   • Verification agencies
   • Cloud and SaaS providers

   
   

7. Cross‑Border Data Transfers

   Australia:
   Under APP 8, we remain accountable for overseas disclosures unless an exception applies.

   New Zealand:
   Under IPP 12, we only transfer data to Australia where the recipient country provides comparable safeguards or contractual protections are in place.

   
   

8. Data Storage and Hosting

   Data is primarily hosted in Australia using the provider Microsoft Azure and other enterprise SaaS platforms. Data may be replicated to New Zealand and the United States for redundancy and resilience.

   
   

9. Data Security

   We implement administrative, technical and physical safeguards including:
   • Encryption (TLS)
   • Identity and access controls
   • Secure cloud hosting
   • Network monitoring
   • DDoS protection
   • Secure authentication

   
   

10. Data Retention

    We retain personal information for a minimum of 7 years or as required by law, after which it is securely destroyed or de‑identified.

    
    

11. Direct Marketing

    We only conduct direct marketing where permitted under APP 7 and equivalent NZ rules. Individuals may opt out at any time.

    
    

12. Access and Correction Rights

    You may request:
    • Access to your personal information
    • Correction of inaccurate data

    We respond within statutory timeframes (72 hours) under both jurisdictions.

    
    

13. Data Breach Notification

    Australia:
    We comply with the Notifiable Data Breaches Scheme and notify the OAIC and affected individuals where required.

    New Zealand:
    We notify the Privacy Commissioner and affected individuals where a breach could cause serious harm.

    
    

14. Cookies and Tracking Technologies

    We use cookies, analytics tools and web beacons to improve user experience, site, platform performance and marketing effectiveness.

    
    

15. Complaints

    Complaints may be lodged with our Privacy Officer. If unresolved, you may contact:

    Australia:
    Office of the Australian Information Commissioner (OAIC)

    New Zealand:
    Office of the Privacy Commissioner

    
    

16. Policy Updates

    We may update this Privacy Policy from time to time by publishing updates on our Website.

    
    

17. Contact Details

    Smart Planner Software Solutions Limited
    NZBN 9429053277473
    Email: contact@smartplanner.io