This Privacy Policy of FOBOH Pty Ltd ACN 668 157 739 (us, we, our) sets out how we treat the personal information that we collect, use and disclose and our procedures regarding the handling of personal information, including the collection, use, disclosure and storage of information, as well as the right of individuals to access and correct that information. We operate the platform called FOBOH, which includes the website with domain name https://www.foboh.com.au/, our web-based AI admin agent (“Al”) app.foboh.ai and our mobile application AI-powered sales coworker (“Sal”), and any ancillary platforms which facilitate the operation of the FOBOH application (Platform).

From time to time, we may revise or update this Privacy Policy or our information handling practices. If we do so, the revised Privacy Policy will be published on the Platform. We may collect personal information in order to conduct our business, to provide and market our services and to meet our legal obligations. By using the Platform or our services, or by providing any personal information to us, you consent to the collection, use and disclosure of your personal information as set out in this Privacy Policy.

The types of personal information we collect and hold

The types of personal information we may collect, and hold includes (but is not limited to) personal information about:

• your name, business address, contact telephone number and other contact details such as an email address;

• payment information (such as credit card or bank details);

• other personal information required to provide our services in specific cases; and

• details of your use of our products or services;

• voice recordings, audio, and transcriptions of meetings and calls captured through Sal;

• content generated from those recordings, including summaries, notes and action items produced by Sal's AI features.

You are not obliged to provide personal information to us. However, in many cases, if you do not provide personal information to us, we may not be able to supply the relevant functionality of the Platform. In some circumstances, you may provide to us, and we may collect from you, personal information about a third party. Where you provide the personal information of a third party, you must ensure that the third party is aware of this Privacy Policy, understands it and agrees to accept it.

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

Because Sal records and transcribes the natural course of meetings and calls, sensitive information may occasionally be captured incidentally within meeting audio, transcripts or notes, for example, if a participant refers to their own or another person's health, religious beliefs or similar matters during a conversation. We do not seek to collect sensitive information in this way, and where it is inadvertently captured we will not use or disclose it other than as reasonably necessary for the purpose for which the meeting content was created, as required or authorised by law, or as otherwise permitted under this Privacy Policy.

How personal information is collected and held by us

We collect personal information in the following ways:

• when you fill in and return to us a signed client form;

• when you submit personal information through the Platform (such as when you send us a message or fill out an online form);

• in person, for example, when you engage with our employees, agents, or customer service representatives; and

• in the course of providing services to you.

• We store personal information in computer storage facilities and paper-based files. We take steps to protect your personal information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your personal information include

• ensuring there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;

• imposing restrictions on physical access to paper files;

• requiring any third parties engaged by us to provide appropriate assurances to handle your personal information in a manner consistent with Australian law; and

• taking reasonable steps to destroy or de-identify personal information after we no longer need it for our business or to comply with the law.

Collection of personal information through activity

Information that may identify you as a user may be gathered during your access with the Platform. The Platform may include pages that use ‘cookies’. A cookie is a unique identification number that allows the server to identify and interact more effectively with your computer or device. The cookie assists us in identifying what our users find interesting on the Platform. A cookie may be allocated each time you use the Platform. The cookie does not identify you as an individual in our data collection process, however it does identify your Internet Service Provider. You can configure your access to the Platform to refuse cookies. If you do so, you may not be able to use all or part of the Platform.

We use the following categories of cookies:

• Essential Cookies – required to provide the Platform functionality you request, such as logging into secure areas of the Platform;

• Functional Cookies – used to remember your choices and settings and personalise your experience;

• Performance/Analytical Cookies – used to understand how users access and use the Platform so we can improve it; and

• Advertising/Marketing Cookies – used, where applicable, to make our marketing communications more relevant to you.

Analytics and anonymisation

We may use Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics uses cookies (see above), to help us analyse how users use the Platform. Although Google Analytics records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you with us.

The information generated by the cookie about your use of the Platform will be transmitted to and stored by Google on servers in your country of residence. Google will use the information on behalf of us for the purpose of evaluating your use of the Platform, compiling reports on activity for us and providing us with other services relating to activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of these cookies. You can also opt out of being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser: http://tools.google.com/dlpage/gaoptout?hl+en

Sal mobile application: recordings, AI and data

This section applies to your use of Sal, our AI-powered mobile sales application, including its voice capture, AI and location-enabled features.

What Sal collects

When you use Sal to record a voice note or capture a visit, we collect the audio, together with any transcript, summary, notes and action items generated from it. 

Location data

Sal requires access to your device's geolocation in order to provide its features. You must enable location access for the mobile app in your device settings to use Sal; if location access is not enabled, Sal's features will not be available. Where you enable location access, we collect your device's geolocation data in connection with your use of Sal. You can withdraw location access at any time through your device settings, which will stop further collection.

Participants who are not FOBOH users

Sal may capture the voices and statements of participants who are not FOBOH account holders and have not otherwise agreed to this Privacy Policy. If you use Sal to record a voice note, you are responsible for ensuring that all participants are notified that the voice note is being recorded and, where required by applicable law (including state-based recording-consent laws in Australia and equivalent laws in other jurisdictions), for obtaining their consent before recording begins. 

Retention of recordings

Audio captured by Sal is used for the purpose of generating a transcript, summary and related meeting content. Once that transcription has been generated, we retain or store the underlying audio recording for 90 days before the audio recording is purged.

Artificial intelligence and automated processing

Sal uses artificial intelligence to transcribe, summarise and structure meeting content into outputs such as notes and action items. 

AI-generated content

Outputs produced by Sal's AI features-  including transcripts, summaries and notes are AI-generated and may contain inaccuracies. You should review AI-generated outputs for accuracy before relying on them.

Use of your data to train AI models

We do not permit third-party AI providers to use your identifiable personal information, including meeting audio, transcripts or notes, to train their AI models. Where we or our service providers use content to evaluate or improve AI features, we use de-identified and aggregated data only. Where we offer an option to opt out of this use, we will make that option available within your account settings.

The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information for a variety of business purposes including:

• to provide the products or services you have requested from us;

• to improve our business, products and services;

• to promote our business to you;

• to market our other services or products to you;

• to handle and respond to your enquiries, complaints or concerns; and

• to provide personal information to third parties as set out in this Privacy Policy.

Direct marketing

We also collect, hold, use and disclose your personal information to:

• notify you about the details of new services and products offered by us;

• send you our newsletters and other marketing publications;

• administer our databases for client service, marketing and financial accounting purposes; and

• to comply with our legal requirements regarding the collection and retention of information concerning the products and services that we provide.

If you do not wish to disclose your personal information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting us using the contact details set out below, or by following the instructions to unsubscribe which are contained in a communication that you receive from us.

Device and usage information

We automatically collect certain information about the devices you use to access the FOBOH Platform and about your use of our services, including device type, operating system, browser type and version, IP address, unique device identifiers, network connection type, and log data such as access times, pages viewed, features used, and crash or performance diagnostics. We collect this information to operate, secure, and improve the Platform, to troubleshoot technical issues, and to understand how our services are used. This information is generally not sufficient on its own to identify you personally, but we may combine it with other personal information we hold about you as described elsewhere in this Privacy Policy.

Children's data

The Platform, including Sal, is intended for business use and is not directed at children. We do not knowingly collect personal information from children under 16 years of age. If we become aware that we have collected personal information from a child under 16, we will take reasonable steps to delete that information.

Third Party Service Providers

We may disclose your personal information to third parties who work with us in our business to promote, market or improve the services that we provide, including:

• providers of customer relations management database services and marketing database services;

• marketing consultants, promotion companies and website hosts;

• partnered businesses; and

• consultants and professional advisers.

We may also combine your personal information with information available from other sources to help us provide better services to you.

Where we do share information with third parties, we require that there are contracts in place that only allow use and disclosure of personal information to provide the service and that protect your personal information in accordance with Australian law. Otherwise, we will disclose personal information to others if you've given us permission, or if the disclosure relates to the main purpose for which we collected the information, and you would reasonably expect us to do so.

How we handle requests to access your personal information

You have a right to request access to your personal information which we hold about you and to request its correction. You can make such a request by contacting us using the contact details set out in this policy. We will respond to any such request for access as soon as reasonably practicable.

Where access is to be given, we will provide you with a copy or details of your personal information in the manner requested by you where it is reasonable and practicable to do so. We will not charge you a fee for making a request to access your personal information. However, we may charge you a reasonable fee for giving you access to your personal information. In some cases, we may refuse to give you access to the information you have requested or only give you access to certain information. If we do this, we will provide you with a written statement setting out our reasons for refusal, except where it would be unreasonable to do so.

How long we keep your personal information

We retain personal information for the period necessary to provide our services, meet our contractual obligations, and comply with legal, accounting, and regulatory requirements, in accordance with this privacy policy. Customer account data is retained while the account remains active. Where an account is closed or you request deletion of your account (see "Deleting your account" below), customer data will be retained for up to 30 days in the account system and 90 days in backup before secure deletion.

Audio recordings captured by Sal are retained only for 90 days and are then deleted, as described in the “Recordings, transcripts and meeting content (Sal)” section above. Transcripts, summaries and notes generated by Sal are retained on the same basis as other customer account data described in this section, unless you delete them earlier.

However, certain records such as financial, HR, and contractual documents may be retained for up to 7 years or longer where required by law or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes. Once the applicable retention period has expired, we will securely delete or permanently de-identify personal information.

Deleting your account

You may request deletion of your account and associated personal information at any time by contacting us at admin@foboh.com.au or through your organisation's administrator. Once confirmed, your account will be closed and personal information deleted or de-identified in line with the retention periods set out above. Some information may be retained where required by law, and business records created under an organisation-provisioned account may be retained by that organisation.

How we handle requests to correct your personal information

We will take such steps (if any) as are reasonable in the circumstances to make sure that the personal information we collect, use or disclose is accurate, complete, up to date and relevant. If you believe the personal information we hold about you is inaccurate, irrelevant, out of date or incomplete, you can ask us to update or correct it. To do so, please contact us using the contact details listed below.

Storage and security

We are committed to ensuring that the personal information we collect 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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

International data transfers

Personal information we collect, including through Sal, may be stored and processed on servers located in Australia or in other countries where we or our service providers operate, including the United States. Where we transfer personal information outside Australia, we take reasonable steps to ensure the overseas recipient handles that information consistently with the Australian Privacy Principles, including, where applicable, by entering into contractual protections such as standard contractual clauses with recipients in the European Union, European Economic Area, United Kingdom or Switzerland.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to correct or update information we hold about you, request access or correction of your personal information, make a complaint about a breach by us of our privacy obligations (including the way we have collected, disclosed or used your personal information) or report a privacy incident, please contact: FOBOH Pty Ltd via admin@foboh.com.au

We will acknowledge and investigate any complaint about the way we manage personal information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations.

Disclosures

FOBOH's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements. Google Workspace APIs are not used to develop, improve or train generalized AI and/or ML models.