Privacy Policy | Muggino

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Last updated: 06-01-2023 (REV 2.1 – DRAFT)

This policy was prepared by Otared Pty. Ltd. (ACN: 610 127 627) the owner of “Muggino®”

brand and applies to all individuals or organisations who deal with us for any business

purpose.

Please note this policy may be updated from time to time to ensure compliance to

applicable laws. You can always find the most up-to-date version on our website. We use

some specific terminology throughout this policy, which are explained in the Definitions

table for your reference.

1. Definitions

Term

Definition

Personal

Information

Any information or opinion about an identified individual, or an

individual who is reasonably identifiable:

• whether the information or opinion is true or not; or

• whether the information or opinion is recorded in a material

form or not.

“Process”,

“Processing” or

“Processed”

Anything that is done with any Personal Information, whether or not

by automated means, such as collection, recording, organisation,

structuring, storage, adaptation or alteration, retrieval, consultation,

use, disclosure by transmission, dissemination or otherwise making

available, alignment or combination, restriction, erasure or

destruction.

Site

Any related web pages located under the following domain names:

• otared.com.au

• muggino.com

• *.muggino.com

and any integration with third party systems or websites which

provide data to us through the web pages listed above.

A small file that is placed on your device when you visit a website

(including our websites).

2. About Muggino®

2.1 Who are we: We use ‘we’ (or ‘our’ or ‘us’) to refer to Otared Pty. Ltd. (ACN: 610 127

627) t/a Muggino®. We are committed to delivering innovative and elegant solutions that

solve real problems for real people. Our goal is to eliminate single use plastic coffee cup

and reduce wastage footprint by shifting to an innovative and eco-friendly smart mug.

2.2 What do we do: We have created Muggino®, an innovative and eco-friendly smart mug

that can quickly adjust a beverage’s temperature to the optimal level from steaming hot to

freezing cold via smartphone app.

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3. Your privacy is very important to us

3.1 Our privacy stance: At Otared, the protection of your data is of critical importance.

This policy is laid out in an easy to understand way so that you can quickly understand our

position on data privacy and our commitment to protecting the data and personal

information we collect.

3.2 Your agreement to this policy: By using this site and/or our services, you agree to

the terms and conditions of this Privacy Policy.

4. Information we may collect from you

Information we collect from you may include some personal information, which is

information which can be used to directly or indirectly identify an individual. This section

details how we collect and create personal information, what categories of personal

information we may process, as well as our stance on sensitive personal information.

4.1 Categories of information we may collect, create or process: We may collect,

create or process the following categories of personal information about you:

• Identity information: name, date of birth, address;

• Device hardware identifiers: including access to Bluetooth adapter to communicate

with Bluetooth enabled devices; read more

• Location services: location data needs to be enabled to scan for Bluetooth devices and

that the user’s location is not being used in the app or recorded anywhere;

• Contact details: email address, phone number;

• Consent records: records of any consents you give to us;

• Purchase details: records of purchases and prices;

• Payment details: invoice records, payment records, de-identified credit card

information;

• Data relating to our sites: your device type, operating system, browser type and

settings, IP address, dates and times of connecting to a site, pixel tags, and other

technical communications information which we need in order to optimise the

quality of our service offering for you; and

• Views, opinions, enquiries, feedback and problems: any views, opinions, enquiries,

feedback and problems that you choose to send to us, or publicly post about us on

social media platforms.

In addition to collecting personal information directly from you, we may collect or obtain

your personal information from third parties who provide it to us (e.g. retailers/resellers).

4.2 Sensitive personal information: We will not collect sensitive personal information

about you, such as information about your religion, ethnicity, health or biometrics.

5. How we use information about you

We use information we collect and create to provide a service to you. This section details

which services and mediums require or are involved in the processing of your personal

information.

We may use personal information about you for the following purposes:

5.1 Providing services to you, such as:

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• To ship your Muggino to you;

• To enable Muggino control via smartphone app “MuggiApp™”;

• To enable you to set your personalised hot and cold drink temperature through

MuggiApp;

• To enable you to use services associated with Muggino;

• To provide customer support to you;

• To continue to improve and develop our services, including by developing new

services we could offer to you;

5.2 Offering our sites to you: We may collect information about the device you use to

access our sites, which may include your IP address, operating system and browser type.

This helps us to manage our sites and improve the quality of our service.

5.3 Communicating with you, in the context of:

• Service updates and news about our services;

• News items and other information in which you may be interested;

• Maintaining and updating your contact information where appropriate;

• Respond to enquiries, feedback or problems you have sent to us;

• Obtaining your prior, opt-in consent;

• Conducting surveys;

• IT operations management of our communications systems, our IT security

systems, and/or IT security audits.

Of course, we will always ensure that such communications are provided to you in

compliance with applicable laws.

5.4 Business partner management: If you are our retailer or business partner, we may

process information relating to sales, finance, billing, corporate audit, and vendor/supplier

management (including contractors).

5.5 Security: No other third parties will have access to your personal information when you

disclose to us.

5.6 Legal compliance: With your consents, we may process information about you to

comply with our legal and regulatory obligations under applicable law.

5.7 Legal proceedings: With your consents, we may process information about you to

establish, exercise and defend legal rights.

6. Disclosure of your information

The provision of our service to you may require us to share your personal information with

other parties. This section details which third parties we may need to disclose your

personal information to, including those outside Australia.

6.1 Disclosure of information to third parties: We may disclose your personal

information to other entities for legitimate business purposes and in accordance with

applicable law. These include:

• Retailers that you shop which may receive de-identified demographic information

about you;

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• Third party service providers to whom we may outsource certain organisational

functions e.g. information technology support, direct marketing etc., may need to

process or store your information, subject to binding contractual obligations of

confidentiality;

• Accountants, auditors, lawyers and other outside professional advisors we employ

may also require access to your information, subject to binding contractual

obligations of confidentiality;

• Third party acquirer(s) may also require access to your information, in the event

that we sell or transfer all or any relevant portion of our business or assets.

6.2 International transfer of personal information: Some of the third parties to whom we

disclose your personal information (as set out above) may be located outside of Australia.

If we disclose your personal information to a third party located outside of Australia, we will

take reasonable steps to ensure that the recipient complies with the Australian Privacy Act

in respect of that information. Nonetheless, other jurisdictions may have different privacy

laws and data protection compliance requirements to those that apply in Australia.

7. Keeping your data secure and maintaining accuracy of your data

Protecting your privacy and maintaining the accuracy of the data we use to serve you is

vitally important to us. This section details the measures we take to achieve this.

7.1 Securing Data: We have implemented appropriate technical and organisational

security measures designed to protect your personal information against unauthorised or

unlawful destruction, loss, alteration, disclosure, and other unlawful or unauthorised forms

of processing. A selection of these measures are listed below:

• Staff education: We train and remind our staff of their obligations with regard to

your personal information and data.

• System security: When you transact with us on the internet via our website, mobile

apps and APIs we encrypt data sent from your computer to our systems.

• Building security: We have protection in our buildings against unauthorised access

such as alarms and cameras.

• Disposal of data which is no longer required: We have defined policies to ensure

that we only keep personal information for as long as required (for example, to meet

user, legal requirements or our internal needs).

7.2 Maintaining Data Accuracy: On an ongoing basis, we take every reasonable step to

ensure that:

• Your personal information is accurate and has been kept up to date (where

necessary);

• Any of your personal information that we process that is inaccurate (having regard

to the purposes for which it is processed) is erased or rectified if we become aware

of the inaccuracy.

From time to time we may ask you to confirm the accuracy of your personal information.

8. Cookies and similar technologies

We use cookies to provide our service to you. You can opt out, though this may impact our

ability to provide our service to you.

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8.1 How we use cookies: When you visit our site, we may place cookies onto your device,

or read cookies already on your device, subject always to obtaining your consent, where

required. We use cookies to record information about your device, your browser and, in

some cases, your preferences and browsing habits. We may process your personal

information through cookies.

8.2 How you can stop cookies: Your browser should give you the ability to control

cookies. How you do so, depends on your browser and the type of cookie. Certain

browsers can be set to reject all browser cookies. If you configure your computer to block

all cookies, you may disrupt certain web page features, and limit the functionality we can

provide when you visit or use our sites. If you continue without changing your settings, we

will assume that you are happy to receive all cookies on this site. You can change your

cookie settings at any time.

9. Accessing, updating and correcting your personal information

We will help you to access, update and correct your personal information.

9.1 Accessing your data: You can ask for access to your personal information (for

example what transactions you’ve made) by contacting us. We try to make your information

available within 30 days of your request. Before we give you the information, we’ll need to

confirm your identity.

9.2 Denying or limiting your request for access: In certain circumstances and where

permitted by law, we may need to deny your request, or limit the access we provide. For

example, we might not provide access to commercially sensitive information. Whatever the

outcome, we’ll write to you explaining our decision.

9.3 Correcting your personal information: You can ask us to correct any inaccurate

personal information we hold or have provided to others by contacting us. If the personal

information that is corrected is personal information we have provided to others, you can

ask us to notify them of the correction. If we’re able to correct your personal information,

we’ll inform you when the process is complete.

9.4 Disagreement on personal information correction required: If we disagree with you

that personal information should be corrected, we’ll let you know our reasons in writing.

You can then respond to further indicate your view that the personal information is

inaccurate, misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps

to comply with your request.

10. Contact us or find out more

10.1 Contacting us: If you have any questions regarding this privacy policy or our

treatment of your personal information, or complaints, or if you would like to access or

amend your personal information, please contact us at info@otared.com.au or

info@muggino.com.

10.2 Complaints: If you contact us to raise a complaint, we will consider your complaint

promptly and contact you to seek to resolve the matter. We shall assign a reference

number and we will keep you updated on the progress we’re making towards fixing the

problem. If we’re unable to provide a final response within 45 days, we’ll contact you to

explain why and discuss a timeframe to resolve the complaint.

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10.3 Office of the Australian Information Commissioner: Under the Privacy Act, you are

also entitled to make a complaint to the Australian Privacy Commissioner if you have

concerns about how we handle your personal information. For more information about the

Australian Privacy Principles, or if we are unable to satisfactorily resolve your concerns

about our handling of your personal information, you can contact the Office of the

Australian Information Commissioner:

GPO Box 5218, Sydney NSW 2001

Email: enquiries@oaic.gov.au

Tel: 1300 363 992