PRIVACY NOTICE

This page was last changed on June 1, 2025

This privacy notice for Cloudvante Pty Ltd (“Company,” “we,” “us,” or “our”), trading as Promina, describes how and why we might collect, store, use and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at https://promina.ai or any site of ours that links to this privacy notice
• Sign in to or interact with the Promina web app (app.promina.ai)
• Engage with us in other ways, including support, sales, marketing or events

Questions or concerns? Reading this notice will help you understand your rights and choices. If you do not agree with our policies and practices, please do not use our Services. You can always reach us at support@promina.ai.

TABLE OF CONTENTS

1. PRIVACY NOTICE
2. SUMMARY OF KEY POINTS
3. WHAT INFORMATION DO WE COLLECT?
4. HOW DO WE PROCESS YOUR INFORMATION?
5. WHAT LEGAL BASES DO WE RELY ON?
6. INTERNATIONAL DATA TRANSFERS
7. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
8. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
9. HOW LONG DO WE KEEP YOUR INFORMATION?
10. HOW DO WE KEEP YOUR INFORMATION SAFE?
11. DO WE COLLECT INFORMATION FROM MINORS?
12. WHAT ARE YOUR PRIVACY RIGHTS?
13. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
14. CONTROLS FOR DO-NOT-TRACK FEATURES
15. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
16. DO WE MAKE UPDATES TO THIS NOTICE?
17. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
18. PRIVACY COMPLAINTS
19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

SUMMARY OF KEY POINTS

Below is a quick summary of the most important aspects of our privacy practice. For full details, follow the links in the table of contents.

• Personal information processed. We collect personal data you provide (e-mail, name, payment details, query data) plus limited technical information (IP, device, usage logs).
• Sensitive personal information. We do not process sensitive categories of personal data (e.g. health, biometrics) unless you expressly give consent.
• Third-party sources. We receive billing tokens from Stripe and diagnostic events from Sentry but no direct marketing lists from external parties.
• Processing purposes. To run and improve Promina, handle payments, detect fraud, secure the platform, and comply with law.
• Sharing. Your data may be shared with our sub-processors Stripe (payments), Cloudflare (security/analytics) and Sentry (error monitoring) or as required by law.
• Security. We apply reasonable organisational and technical measures (encryption in transit, least-privilege access, monitoring). No internet system is 100 % secure.
• Your rights. Depending on where you live, you may have rights of access, correction, erasure, complaint and data portability. Contact us to exercise them.

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In short: we collect information you provide directly, plus limited usage data.

We collect personal information that you voluntarily provide when you create an account, subscribe to a plan, request support or otherwise interact with the Services.

• Full name
• Email address
• Company name
• Payment information (card brand, last 4 digits, billing country) handled securely by Stripe; Promina never stores full card numbers.
• Search or brand queries you ask Promina to monitor
• Job title or role
• Marketing preferences
• Passwords and usernames
• Usage analytics & interaction data (page views, button clicks)
• Any other info you choose to give us (support tickets, survey responses)

Sensitive information

We do not intentionally collect sensitive personal data such as health records or religious beliefs. If you include such data in free-form fields, you consent to our processing it as described here.

Application data

When you use the web app we automatically log limited device data (IP address, browser type, referring pages) for security and performance monitoring via Cloudflare and Sentry.

HOW DO WE PROCESS YOUR INFORMATION?

• To create and manage user accounts
• To deliver Services and support
• To process payments and manage subscriptions
• To send administrative messages, invoices and service updates
• To request feedback and conduct research
• To send marketing communications (with your consent)
• To protect our Services (fraud detection, abuse monitoring)
• To identify usage trends and improve features
• To comply with legal obligations
• To protect vital interests in emergencies

WHAT LEGAL BASES DO WE RELY ON?

We process personal data under the legal bases provided by the GDPR (where applicable), the UK GDPR, the Privacy Act 1988 (Cth) and other national laws. These include consent, contract performance, legitimate interests, legal obligation and vital interests.

INTERNATIONAL DATA TRANSFERS

Stripe, Cloudflare and Sentry may store or process data in the United States, European Union and other jurisdictions. We take reasonable steps to ensure that any overseas recipient offers privacy protections comparable to Australian standards or that appropriate safeguards (e.g. SCCs) are in place.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We share personal information only when essential—for example, with:

• Stripe (payment processing & billing)
• Cloudflare (edge security, CDN, web analytics)
• Sentry (error monitoring)
• Regulators, courts or law-enforcement where legally required
• A successor entity in case of merger/acquisition (with notice to you)

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

Promina offers the option to register and sign in using third-party authentication providers such as Google and Apple. When you choose to connect using one of these accounts, we receive certain personal information from the provider, such as your name, email address, and a unique user ID. The exact data shared depends on your privacy settings with the provider.

We use this information solely to:

• Create and manage your Promina account
• Authenticate your identity
• Prevent fraudulent access
• Provide a smoother sign-in experience

We do not receive your password or access to your third-party account. Your use of social login is governed by the privacy policies of the respective providers:

• Google Privacy Policy
• Apple Privacy Policy

You can revoke Promina’s access via your Google or Apple account settings at any time. If you disconnect your social login, you may be required to set a password or use another method to access your account.

HOW LONG DO WE KEEP YOUR INFORMATION?

We retain personal data only as long as necessary for the purposes set out in this notice (or longer if required by law). Payment records are kept for at least seven years for tax compliance. When no longer needed, data is securely deleted or anonymised.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We employ encryption in transit (TLS 1.2+), role-based access control, periodic security audits and continuous monitoring through Sentry and Cloudflare. Nevertheless, no system is perfectly secure.

DO WE COLLECT INFORMATION FROM MINORS?

Our Services are not directed to individuals under 18. If we discover that a minor has provided personal data, we will remove it promptly.

WHAT ARE YOUR PRIVACY RIGHTS?

Depending on your locale, you may have rights to access, correct, delete, restrict or port your data, to object to certain processing and to lodge a complaint with a regulator. Contact support@promina.ai to start the process.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You may request a copy of the personal information we hold about you or ask us to correct inaccuracies at any time. Identity verification will be required.

CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to browser DNT signals because a uniform standard has yet to be adopted.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes. If you are a California resident, you have the rights provided by the CCPA and CPRA—such as the rights to know, delete and opt-out of the sale or sharing of personal information. Contact us to exercise these rights.

DO WE MAKE UPDATES TO THIS NOTICE?

We may update this notice periodically. The “Last changed” date at the top indicates when the latest revisions were posted.

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Email support@promina.ai or write to:

PRIVACY COMPLAINTS

We take privacy seriously. Lodge any concern at support@promina.ai and we will respond within a reasonable period.

If you are dissatisfied, you may complain to the Office of the Australian Information Commissioner (OAIC):

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au

HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Send a request to support@promina.ai. We will verify your identity and respond in accordance with applicable law.

© 2025 Cloudvante Pty Ltd