Purple TIC

PRIVACY POLICY

Purple TIC Enterprises Pty Ltd

1 June 2026 | Version 1.0

Purple TIC Enterprises Pty Ltd (ACN 695 883 213 / ABN 54 695 883 213) (we, us or our) is committed to protecting your privacy and handling your Personal Information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Privacy Policy explains how we collect, hold, use, disclose, and protect your Personal Information when you access or use our website at www.purpeticenterprises.com, and any related services (together, the Platform).

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent to collect or use your Personal Information, you may withdraw that consent at any time by contacting us using the details in clause 15.

OPERATIVE PROVISIONS

1. ABOUT THIS PRIVACY POLICY

  1. This Privacy Policy applies to all Personal Information we collect about you through the Platform, whether collected directly from you or from third party sources.

  2. This Privacy Policy should be read together with our Website Terms of Use, Website Disclaimer, and Cookie Policy.

  3. We may update this Privacy Policy from time to time. Any changes will be posted on the Platform with an updated effective date. Where the changes are material, we will use reasonable endeavours to notify you before the changes take effect.

2. DEFINITIONS AND INTERPRETATION

Definitions

In this Privacy Policy, the following definitions apply:

APPsmeans the Australian Privacy Principles set out in Schedule 1 to the Privacy Act.
Notifiable Data Breachhas the meaning given to "eligible data breach" in Part IIIC of the Privacy Act.
OAICmeans the Office of the Australian Information Commissioner.
Personal Informationhas the meaning given in section 6 of the Privacy Act, being 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.
Platformmeans the website at www.purpeticenterprises.com, and any related services operated by us.
Privacy Actmeans the Privacy Act 1988 (Cth) and any regulations or subordinate instruments made under it, as amended from time to time.
Privacy Policymeans this Privacy Policy, as amended from time to time.
Sensitive Informationhas the meaning given in section 6 of the Privacy Act.

Interpretation

In this Privacy Policy, unless the context otherwise requires:

  1. headings are for convenience only and do not affect interpretation;

  2. the singular includes the plural and vice versa;

  3. a reference to a person includes a corporation, partnership, joint venture, association, government body, or other entity;

  4. a reference to a statute, regulation, or other law includes all amendments, consolidations, and replacements;

  5. a reference to writing includes email; and

  6. where a word or expression is given a particular meaning, other parts of speech and grammatical forms of that word or expression have a corresponding meaning.

3. INFORMATION WE COLLECT

  1. The types of Personal Information we collect about you depend on how you interact with the Platform. We may collect and hold the following categories of Personal Information.

  2. Information you provide to us includes:

    1. account registration information, including your name, email address, username, and password;

    2. if you sign up through our referrer or influencer portal: identity and contact details, social media handles and audience information, content samples, tax and payment details (such as ABN, BSB and account number) where required to facilitate payments by the relevant operating entity, and any verification information we reasonably require; this information may be processed by, or shared with, the operating entity for the relevant app (such as Awaykon Pty Ltd or Lumen App Pty Ltd);

    3. profile information you choose to provide, including display name, profile picture, biographical information, and preferences;

    4. enquiry submissions, support requests, and other communications you choose to send us through the Website;

    5. communications you send to us, including support requests, feedback, and correspondence; and

    6. any other information you voluntarily provide to us through the Platform.

  3. Information we collect automatically includes:

    1. device and browser information, including your IP address, device type, operating system, browser type, and unique device or advertising identifiers;

    2. usage data, including pages and features accessed, time spent on the Platform, referring URLs, search terms, and clickstream data;

    3. approximate location data derived from your IP address or, where you have provided consent, precise location data from your device; and

    4. cookie and tracking technology data, as described in our Cookie Policy.

  4. Information we receive from third parties: we may receive Personal Information about you from third party sources, including analytics providers (such as Google Analytics), payment processors, advertising networks, and publicly available sources or business partners.

  5. Sensitive Information: we do not generally collect Sensitive Information about you. Where we do collect Sensitive Information, we will only do so with your consent and where the collection is reasonably necessary for, or directly related to, one or more of our functions or activities, unless an exception under APP 3.4 applies.

4. HOW WE COLLECT YOUR INFORMATION

  1. We collect Personal Information:

    1. directly from you, when you register for an account, use the Platform, make a payment, contact us, or otherwise provide information to us;

    2. automatically, through cookies, analytics tools, and similar technologies when you access or interact with the Platform; and

    3. from third parties, as described in clause 3 above.

  2. Where it is reasonable and practicable to do so, we will collect Personal Information directly from you. We will not collect Personal Information by unlawful or unfair means.

  3. If we receive Personal Information about you that we did not solicit, we will deal with that information in accordance with APP 4, including by destroying or de-identifying the information where it is lawful and reasonable to do so.

5. HOW WE USE YOUR INFORMATION

  1. We use your Personal Information for the primary purposes for which it was collected. These include:

    1. providing, operating, maintaining, and improving the Platform and the services made available through it;

    2. creating and managing accounts on our Website, including referrer and influencer portal sign-ups, and processing related onboarding;

    3. verifying your identity and administering your use of the Platform;

    4. communicating with you, including sending service-related notices, responding to your enquiries, and providing customer support;

    5. sending you marketing or promotional communications where you have consented or where we are otherwise permitted to do so by law;

    6. conducting analytics, research, and product development to understand and improve user experience, and managing the operation of the Purple TIC brand including referrer and influencer programs that promote our affiliated apps;

    7. detecting, preventing, and responding to fraud, security incidents, and breaches of our terms; and

    8. complying with our legal obligations, enforcing our terms, and protecting our rights and the rights of others.

  2. We may also use your Personal Information for secondary purposes that are related to a primary purpose, where you would reasonably expect us to do so, or where we have your consent.

  3. We will not use your Personal Information for a purpose materially different from the purpose for which it was collected, unless we have obtained your consent or are otherwise permitted or required by law.

6. DIRECT MARKETING

  1. We may use your Personal Information (including your name and contact details) to send you direct marketing communications about our products, services, promotions, or events, where you have consented or where we are otherwise permitted to do so under the Privacy Act and the Spam Act 2003 (Cth).

  2. You may opt out of receiving direct marketing communications from us at any time by:

    1. using the unsubscribe link included in each marketing email;

    2. updating your communication preferences in your account settings; or

    3. contacting us using the details in clause 15.

  3. If you opt out of direct marketing communications, we will continue to send you service-related communications that are necessary for us to provide the Platform and the services made available through it.

7. DISCLOSURE OF YOUR INFORMATION

  1. We may disclose your Personal Information to the following categories of recipients for the purposes described in clause 5:

    1. Service providers: third party providers who perform services on our behalf, including hosting, cloud infrastructure, payment processing, analytics, customer support, email delivery, and marketing;

    2. Related entities: other entities operating under the Purple TIC brand (including Awaykon Pty Ltd, Lumen App Pty Ltd, The Hug App Pty Ltd, The Fox App Pty Ltd, and Impressa Atelier Pty Ltd), where necessary to provide and support the services those entities offer or to manage referrer or influencer arrangements relating to those services;

    3. Professional advisors: our lawyers, accountants, auditors, and insurers, where necessary for the provision of their services;

    4. Law enforcement and regulators: government authorities, law enforcement agencies, courts, tribunals, or regulators, where required or authorised by law, or to protect our legal rights and the rights of others; and

    5. Business transfers: a potential buyer, transferee, investor, or merger partner in the event of a sale, merger, restructure, or other transfer of all or part of our business or assets.

  2. Before disclosing your Personal Information to a third party, we take reasonable steps to ensure that the third party is contractually obliged to handle your Personal Information in accordance with the APPs and this Privacy Policy, and only uses your Personal Information for the specified purposes.

  3. We do not sell your Personal Information.

8. OVERSEAS DISCLOSURE

  1. We are based in Australia. Some of our service providers are located outside Australia, including in various overseas jurisdictions, which may include the United States, the European Union, Singapore, and other countries in which our service providers operate. Where we disclose your Personal Information to an overseas recipient, we will take reasonable steps in the circumstances to ensure that the recipient does not breach the APPs in relation to the information, consistent with our obligations under APP 8.

  2. By using the Platform, you consent to the disclosure of your Personal Information to overseas recipients for the purposes described in this Privacy Policy.

9. DATA RETENTION

  1. We retain your Personal Information only for as long as is reasonably necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements, or to resolve disputes and enforce our agreements.

  2. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the information, whether we can achieve those purposes through other means, and applicable legal and contractual requirements.

  3. When your Personal Information is no longer required, we will take reasonable steps to destroy or de-identify it in accordance with our information handling procedures. Where de-identification is used, the de-identified information may be retained indefinitely for analytical and research purposes.

10. DATA SECURITY

  1. We take reasonable steps to protect your Personal Information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These steps include:

    1. encryption of Personal Information in transit and, where appropriate, at rest;

    2. access controls that limit access to Personal Information to authorised personnel on a need-to-know basis;

    3. regular security assessments and testing of our systems and processes;

    4. staff training on privacy and data handling obligations; and

    5. incident response procedures for investigating and responding to actual or suspected data breaches.

  2. While we take reasonable steps to protect your Personal Information, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your Personal Information.

  3. In the event of a Notifiable Data Breach, we will notify the OAIC and affected individuals in accordance with Part IIIC of the Privacy Act (the Notifiable Data Breaches scheme).

11. YOUR RIGHTS

  1. Under the Privacy Act and the APPs, you have the right to:

    1. Access: request access to the Personal Information we hold about you (APP 12);

    2. Correction: request correction of any Personal Information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13); and

    3. Complaint: make a complaint to us or to the OAIC if you believe we have breached the APPs or mishandled your Personal Information.

  2. To make an access or correction request, please contact us using the details in clause 15. We may require you to verify your identity before actioning your request.

  3. We will respond to your request within a reasonable period and, in any event, within 30 days of receiving the request. We will not charge you for making a request, but we may charge a reasonable fee for providing access if the request requires substantial effort. We will explain the basis of any charge before responding.

  4. There are circumstances in which we may decline an access or correction request (for example, where giving access would have an unreasonable impact on the privacy of other individuals or where we are required or authorised by law to refuse access). If we decline a request, we will explain our reasons in writing and let you know how to complain.

12. COOKIES AND TRACKING TECHNOLOGIES

  1. We use cookies and similar tracking technologies on the Platform. For detailed information about the cookies we use, the purposes for which we use them, and how you can manage your cookie preferences, please refer to our Cookie Policy.

13. THIRD PARTY LINKS

  1. The Platform may contain links to third party websites, services, or applications that are not operated or controlled by us. This Privacy Policy does not apply to those third party services, and we are not responsible for their privacy practices.

  2. We encourage you to review the privacy policies of any third party services before providing your Personal Information to them.

14. CHILDREN'S PRIVACY

  1. The Platform is not directed at, and we do not knowingly collect Personal Information from, children under the age of 18 (or the applicable age of majority in your jurisdiction), except where the Platform is specifically designed for use by or for children and appropriate parental consent mechanisms apply.

  2. If we become aware that we have collected Personal Information from a child without appropriate parental consent, we will take reasonable steps to delete that information as soon as practicable. If you believe that we may have collected information from a child, please contact us immediately using the details in clause 15.

15. CONTACT US AND COMPLAINTS

  1. If you have any questions about this Privacy Policy, wish to exercise your rights, or wish to make a complaint about how we handle your Personal Information, please contact us at Purple TIC Enterprises Pty Ltd, Privacy Contact Privacy Officer, support@purpleticenterprises.com, Level 10, 369 Royal Parade, Parkville, VIC 3052.

  2. We will acknowledge your complaint within 5 business days of receipt and aim to resolve it within 30 days. If we need more time, we will let you know the reason for the delay and the expected timeframe for resolution.

  3. If you are not satisfied with our response, or if you consider that we have not handled your complaint appropriately, you may refer your complaint to the Office of the Australian Information Commissioner:

    1. Website: www.oaic.gov.au;

    2. Phone: 1300 363 992; and

    3. Post: GPO Box 5218, Sydney NSW 2001.

16. CHANGES TO THIS PRIVACY POLICY

  1. We reserve the right to amend this Privacy Policy at any time. Any changes will be effective when we post the revised Privacy Policy on the Platform with an updated effective date.

  2. Where the changes are material, we will use reasonable endeavours to notify you by email (where we have your email address) or by posting a prominent notice on the Platform before the changes take effect.