BLUEWATER USER DATA POLICY

Effective 1 June 2023

This User Data Policy applies to your use of the Bluewater Service (the Service) as a User of Bluewater Control Pty Ltd (ABN 14 614 164 519) ("Bluewater") or our Service Resellers. This User Data Policy applies to the data Bluewater processes on behalf of our Users (User Data) in our capacity of providing the service. This User Data Policy does not apply to any information or data collected by Bluewater for other purposes, such as information collected on our websites or through other channels for marketing purposes. Please see the Bluewater Privacy Policy (found at: https://www.bluewatercontrol.com/privacy-policy/) that covers this information.

Bluewater processes User Data under the direction of our Users and has no direct control or ownership of the personal data we process. Users are responsible for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data to Bluewater for processing purposes. Terms not otherwise defined herein shall have the meaning as set forth in the Bluewater Terms of Service (the "Agreement"). In the event of conflict between this User Data Policy and the Agreement, the terms of the Agreement will prevail.

Bluewater respects your right to privacy and is committed to safeguarding the privacy of our Users and their data. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the "Act").

Use of the service

Our Users use the Service to manage their mobility workflow and telecom expense management and reporting.

At the direction of the User Bluewater uploads User information (telecom catalogues, billing data, employee names and details, company cost centres) into the Service on a regular basis in accordance with our agreements with our Users, and we store it in our service provider's & apos servers. In addition to Bluewater, the User and/or its representatives may upload information into the Service. Bluewater does not control the content of the information that our Users or their representatives input into the system. Any information uploaded into the User Service, by Bluewater or the User, is collectively the User Data.

Our agreements with our Users prohibit us from using any User Data, except as necessary to provide and improve the Service, as permitted by this User Data Policy, and as required by law.

We use the information collected through our Service for the following purposes: to provide the Service; to respond to User support requests; and to otherwise fulfill the obligations under the Bluewater Terms of Service.

Log files

When you use our Service, we automatically collect information about your computer hardware and software, for the purposes of providing and improving the Service. This information can include your IP address, browser type, domain names, the files viewed on our portal (e.g. HTML pages, graphics), operating system, clickstream data and access times. For the purposes it is collected, we do link this automatically collected data to Personal Information (as defined in the Act) such as names, emails, Company details and phone numbers.

Data retention

The User Data collected and retained in our Service is retained according to the relevant agreements between you and Bluewater. User Data is retained in accordance with the Agreement as long as you remain an active User. Your data is deleted upon your written request or after an established period following the termination of all User agreements. In general, User Data is deleted after your paid Service ends and your portal becomes inactive.

Security of your User data

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.

Changes to User Data Policy

Please be aware that we may change this User Data Policy in the future. We will post any changes on this page, and if the changes are significant, we will provide an update to the User Contact in your agreement with Bluewater. We will also keep prior versions of this User Data Policy in an archive for your review.