Privacy Policy

1.1 Welcome

Welcome to Tool-O.

Tool-O Pty Ltd ("Tool-O", "we", "our" or "us") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, hold, use, disclose and protect your personal information when you use the Tool-O website, mobile applications and related services (collectively, the "Platform").

1.2 Compliance

Tool-O is committed to complying with:

• the Privacy Act 1988 (Cth);

• the Australian Privacy Principles (APPs);

• the Spam Act 2003 (Cth);

• any other applicable Australian privacy legislation.

Where Tool-O operates in other jurisdictions, we will also comply with applicable privacy laws to the extent required.

1.3 Scope

This Privacy Policy applies to personal information collected when you:

• visit the Platform;

• create an Account;

• list a Tool;

• rent a Tool;

• communicate with other Users;

• submit Claims;

• contact customer support;

• interact with Tool-O through any online or offline channel.

1.4 Acceptance

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

If you do not agree with this Privacy Policy, you should not use the Platform.

1.5 Changes to this Policy

Tool-O may amend this Privacy Policy from time to time.

Where changes are material, Tool-O will provide notice through the Platform or by another appropriate communication method.

The latest version published on the Platform replaces all previous versions.

1.6 Definitions

Unless the context otherwise requires, capitalised terms used in this Privacy Policy have the meanings given in the Tool-O Terms of Use.

Where a term is not defined in the Terms of Use, it has its ordinary meaning under applicable privacy legislation.

2.1 General

Tool-O collects personal information that is reasonably necessary to operate the Platform, provide our services, comply with legal obligations and protect our Users.

The type of information collected depends on how you use the Platform.

2.2 Identity Information

We may collect information including:

• full name;

• date of birth;

• government-issued identification details;

• photographs used for identity verification;

• verification status;

• signatures where required;

• any other information reasonably required to verify identity.

2.3 Contact Information

We may collect:

• email address;

• mobile telephone number;

• residential or business address;

• postal address;

• emergency contact details where provided;

• communication preferences.

2.4 Account Information

We may collect information relating to your Account, including:

• username;

• encrypted password;

• account settings;

• profile photograph;

• profile description;

• verification status;

• account activity;

• preferences.

2.5 Payment Information

When you make or receive payments through Tool-O, we may collect or receive information including:

• payment transaction identifiers;

• payment status;

• payment history;

• Security Deposit information;

• payout information;

• billing address;

• partial payment method information;

• payment provider reference numbers.

Complete payment card details are generally collected and stored by our third-party payment providers rather than Tool-O.

2.6 Booking Information

We collect information relating to Bookings, including:

• Booking dates;

• collection arrangements;

• delivery arrangements;

• return arrangements;

• rental pricing;

• Security Deposit details;

• Booking status;

• cancellation history;

• Booking history.

2.7 Listing Information

Where you list a Tool, we may collect:

• Listing title;

• descriptions;

• photographs;

• videos;

• pricing;

• location;

• category;

• availability;

• specifications;

• serial numbers where voluntarily provided;

• maintenance information where provided.

2.8 Communications

We collect communications made through the Platform, including:

• messages;

• customer support requests;

• dispute communications;

• Claim communications;

• notifications;

• feedback.

Communications may be retained for operational, legal and security purposes.

2.9 Claims Information

Where a Claim is submitted, we may collect:

• photographs;

• videos;

• invoices;

• repair quotations;

• receipts;

• replacement quotations;

• written statements;

• expert reports;

• police reports where applicable;

• any other supporting documentation.

2.10 Device Information

When you use the Platform, we may automatically collect technical information including:

• IP address;

• browser type;

• operating system;

• device identifiers;

• application version;

• language settings;

• time zone;

• crash reports;

• diagnostic information.

2.11 Usage Information

We may collect information regarding how the Platform is used, including:

• pages visited;

• searches performed;

• Listings viewed;

• features used;

• session duration;

• click activity;

• navigation behaviour;

• referral sources.

2.12 Location Information

Where permitted by your device settings or where required for Platform functionality, we may collect location information including:

• approximate location;

• GPS location;

• collection locations;

• delivery locations;

• return locations.

To help protect the privacy and security of Owners, Tool-O may display an intentionally approximate or offset location for public Listings. Public map markers are not intended to represent the exact collection address.

Exact collection, delivery or return location details are shared only with the relevant Users where reasonably necessary for a confirmed Booking or to facilitate Platform services.

You may be able to disable certain location permissions through your device settings, although some Platform features may no longer function correctly.

2.13 Cookies and Similar Technologies

We may collect information using:

• cookies;

• pixels;

• software development kits (SDKs);

• local storage;

• web beacons;

• analytics technologies;

• similar tracking technologies.

These technologies help us operate, secure and improve the Platform.

2.14 Information from Third Parties

We may receive personal information from third parties including:

• payment providers;

• identity verification providers;

• fraud prevention providers;

• analytics providers;

• advertising providers;

• government agencies where authorised by law;

• law enforcement agencies;

• other Users;

• publicly available sources.

2.15 Sensitive Information

Where permitted by law and reasonably necessary, Tool-O may collect limited sensitive information, including information required for identity verification or legal compliance.

Sensitive information will only be collected, used and disclosed in accordance with applicable privacy legislation.

2.16 Information You Choose to Provide

You may voluntarily provide additional personal information when using the Platform.

If you choose to provide information that is not requested by Tool-O, that information may still be collected, stored and used in accordance with this Privacy Policy where reasonably necessary for Platform operations or legal compliance.

3.1 Information You Provide

We collect personal information that you voluntarily provide when you:

• create an Account;

• complete your profile;

• verify your identity;

• list a Tool;

• make a Booking;

• communicate with another User;

• submit a Claim;

• contact customer support;

• respond to surveys;

• provide feedback;

• otherwise interact with the Platform.

3.2 Information Collected Automatically

When you use the Platform, certain information is collected automatically through our systems and third-party service providers.

This may include:

• device information;

• browser information;

• IP address;

• session information;

• usage analytics;

• diagnostic information;

• cookies;

• location information where permitted;

• security logs.

3.3 Booking Activity

We collect information generated through your use of the Platform, including:

• Listings created;

• Booking requests;

• Booking confirmations;

• cancellations;

• completed rentals;

• payment history;

• Security Deposit activity;

• Claims;

• reviews;

• ratings;

• customer support interactions.

3.4 Communications

We collect information contained in communications made through the Platform, including:

• messages between Users;

• customer support correspondence;

• emails;

• notifications;

• complaint submissions;

• Claim communications.

Telephone conversations with customer support may also be recorded where permitted by law for training, quality assurance, fraud prevention or dispute resolution purposes.

3.5 Identity Verification

Where identity verification is required, Tool-O may collect information directly from you or through authorised third-party identity verification providers.

Verification may include:

• identity documents;

• photographs;

• facial comparison technology;

• verification results;

• verification status.

3.6 Payment Providers

Payment-related information may be collected by third-party payment providers acting on Tool-O's behalf.

Those providers may share information with Tool-O including:

• payment confirmations;

• payment failures;

• refund information;

• payout information;

• fraud indicators;

• transaction identifiers.

3.7 Third-Party Service Providers

We may receive personal information from service providers assisting us with:

• identity verification;

• fraud prevention;

• payment processing;

• analytics;

• cloud hosting;

• customer support;

• communication services;

• artificial intelligence services.

3.8 Other Users

Information about you may be provided by another User, including where:

• a Claim is submitted;

• a review is written;

• photographs are uploaded;

• messages reference you;

• customer support enquiries relate to your Account.

3.9 Public Sources

Where permitted by law, Tool-O may obtain information from publicly available sources for purposes including:

• fraud prevention;

• identity verification;

• regulatory compliance;

• business administration.

3.10 Cookies

Tool-O uses cookies and similar technologies to:

• remember preferences;

• maintain secure sessions;

• improve website performance;

• understand Platform usage;

• personalise user experiences;

• support security and fraud prevention.

You may disable cookies through your browser settings, however some Platform features may not operate correctly.

3.11 Mobile Applications

When using a Tool-O mobile application, additional information may be collected depending on your device permissions, including:

• push notification settings;

• device identifiers;

• operating system information;

• application diagnostics;

• approximate or precise location where permission has been granted.

You may manage many of these permissions through your device settings.

3.12 Artificial Intelligence

Where Users upload photographs, videos, documents or other content, Tool-O may process that information using artificial intelligence technologies for purposes including:

• image recognition;

• damage assessment;

• fraud detection;

• document analysis;

• customer support;

• Platform improvements;

• safety monitoring.

AI-assisted processing forms part of Tool-O's operational systems but does not necessarily determine outcomes without human oversight where appropriate.

3.13 Legal Requirements

Tool-O may collect personal information where required or authorised by law, including for the purposes of:

• complying with court orders;

• responding to regulatory requests;

• complying with law enforcement requests;

• meeting taxation obligations;

• complying with anti-fraud obligations;

• protecting the legal rights of Tool-O or other Users.

4.1 General

Tool-O uses personal information only where reasonably necessary to operate the Platform, provide our services, comply with legal obligations, protect Users and improve our business.

4.2 Providing the Platform

We use personal information to:

• create and manage User Accounts;

• verify identity;

• facilitate Bookings;

• enable Listings;

• process payments;

• administer Security Deposits;

• process Owner payouts;

• facilitate communications between Users;

• provide customer support.

4.3 Operating the Marketplace

We use personal information to:

• match Owners and Borrowers;

• display Listings;

• manage availability;

• administer Bookings;

• facilitate deliveries and collections;

• process cancellations;

• administer Claims;

• manage reviews and ratings.

4.4 Payment Processing

Personal information may be used to:

• process Rental Amounts;

• authorise Security Deposits;

• process refunds;

• process Owner payouts;

• detect payment failures;

• investigate payment disputes;

• comply with financial reporting obligations.

4.5 Claims and Dispute Resolution

We use personal information to:

• investigate Claims;

• review uploaded evidence;

• communicate with Users;

• assess liability;

• determine appropriate outcomes;

• administer Security Deposits;

• prevent fraudulent Claims.

4.6 Artificial Intelligence

Tool-O may use artificial intelligence technologies to assist with:

• image analysis;

• damage detection;

• document analysis;

• fraud detection;

• customer support;

• safety monitoring;

• Platform improvements;

• operational efficiency.

AI-assisted systems support our decision-making processes and may be supplemented by human review where appropriate.

4.7 Fraud Prevention

We use personal information to:

• detect suspicious activity;

• verify identity;

• prevent payment fraud;

• detect Account misuse;

• investigate security incidents;

• identify duplicate Accounts;

• protect Users and Tool-O.

4.8 Platform Security

Personal information may be used to:

• maintain Platform security;

• investigate unauthorised access;

• monitor system performance;

• detect cyber threats;

• prevent abuse of the Platform;

• enforce these Terms.

4.9 Customer Support

We use personal information to:

• respond to enquiries;

• resolve complaints;

• investigate issues;

• provide technical support;

• improve customer service.

4.10 Communications

We may use personal information to send:

• Booking confirmations;

• payment notifications;

• Security Deposit updates;

• Claim updates;

• security alerts;

• verification requests;

• policy updates;

• legal notices;

• customer support communications.

4.11 Marketing

Where permitted by law, Tool-O may use personal information to:

• send promotional communications;

• inform Users about new features;

• announce special offers;

• provide newsletters;

• invite participation in surveys.

Users may opt out of marketing communications at any time.

Essential service communications will continue where reasonably necessary.

4.12 Analytics

We use personal information and usage information to:

• understand how the Platform is used;

• improve functionality;

• identify technical issues;

• improve user experience;

• develop new features;

• measure Platform performance.

Where reasonably practicable, analytics information may be aggregated or de-identified.

4.13 Legal Compliance

Tool-O may use personal information where reasonably necessary to:

• comply with applicable laws;

• respond to lawful requests from regulators;

• comply with court orders;

• satisfy taxation obligations;

• prevent unlawful conduct;

• protect legal rights.

4.14 Business Operations

Personal information may be used for legitimate business purposes including:

• internal administration;

• auditing;

• accounting;

• financial reporting;

• insurance;

• risk management;

• staff training;

• quality assurance.

4.15 Business Transactions

If Tool-O undergoes a merger, acquisition, investment, business sale, restructuring or similar corporate transaction, personal information may be used and transferred as reasonably necessary to facilitate that transaction, subject to applicable privacy laws.

4.16 De-Identified Information

Where permitted by law, Tool-O may de-identify or aggregate information so that it no longer identifies an individual.

De-identified information may be used for:

• research;

• statistical analysis;

• product development;

• business planning;

• service improvements;

• reporting.

4.17 Other Purposes

Tool-O may use personal information for any other purpose:

\(a\) with the User's consent;

\(b\) where required or authorised by law; or

\(c\) where reasonably necessary for purposes compatible with those described in this Privacy Policy.

5.1 General

Tool-O may disclose personal information where reasonably necessary to operate the Platform, provide our services, comply with legal obligations or protect our legitimate interests.

We do not sell personal information.

5.2 Other Users

To facilitate Bookings, we may disclose limited personal information between Owners and Borrowers, including:

• first name;

• profile photograph where applicable;

• verification status;

• communication through Tool-O Messages;

• collection or delivery details necessary to complete a Booking;

• reviews and ratings;

• any other information reasonably necessary to facilitate the Booking.

5.3 Payment Providers

We may disclose personal information to payment service providers for purposes including:

• payment processing;

• Security Deposit authorisation;

• refunds;

• Owner payouts;

• fraud prevention;

• payment verification;

• regulatory compliance.

5.4 Identity Verification Providers

Where identity verification is required, personal information may be disclosed to identity verification providers for purposes including:

• identity verification;

• document authentication;

• fraud detection;

• age verification where applicable;

• regulatory compliance.

5.5 Service Providers

Tool-O may disclose personal information to trusted service providers assisting with:

• cloud hosting;

• data storage;

• analytics;

• customer support;

• messaging services;

• email delivery;

• SMS services;

• push notifications;

• artificial intelligence services;

• fraud prevention;

• cybersecurity;

• software development;

• business operations.

Service providers are required to use personal information only for authorised purposes and in accordance with applicable privacy laws.

5.6 Professional Advisers

We may disclose personal information to our:

• lawyers;

• accountants;

• auditors;

• insurers;

• consultants;

• financial advisers,

where reasonably necessary for legal, commercial or operational purposes.

5.7 Legal Requirements

Tool-O may disclose personal information where required or authorised by law, including to:

• courts;

• tribunals;

• regulators;

• government agencies;

• taxation authorities;

• law enforcement agencies;

• anti-fraud organisations.

5.8 Protection of Rights

We may disclose personal information where reasonably necessary to:

\(a\) protect the rights of Tool-O;

\(b\) protect Users;

\(c\) investigate fraud;

\(d\) investigate security incidents;

\(e\) enforce our Terms of Use;

\(f\) respond to legal claims;

\(g\) protect public safety.

5.9 Business Transactions

If Tool-O undergoes:

• a merger;

• acquisition;

• business sale;

• corporate restructure;

• refinancing;

• investment transaction,

personal information may be disclosed to prospective or actual purchasers, investors, advisers or successor entities, subject to appropriate confidentiality obligations and applicable privacy laws.

5.10 Artificial Intelligence Providers

Where AI technologies are used to support Platform operations, personal information may be disclosed to trusted AI service providers for purposes including:

• image analysis;

• document analysis;

• fraud detection;

• customer support;

• operational improvements.

Such disclosures are subject to contractual and legal safeguards designed to protect personal information.

5.11 De-Identified Information

Tool-O may disclose aggregated or de-identified information that no longer identifies an individual for purposes including:

• research;

• analytics;

• reporting;

• product development;

• business planning;

• statistical analysis.

5.12 With Your Consent

Tool-O may disclose personal information to other persons or organisations where you have expressly authorised or directed us to do so.

5.13 International Disclosure

Some service providers may be located outside Australia.

Where personal information is disclosed overseas, Tool-O will take reasonable steps to ensure that such disclosures comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable privacy laws.

6.1 General

Tool-O takes reasonable administrative, technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

While we take reasonable steps to safeguard personal information, no method of electronic transmission or storage can be guaranteed to be completely secure.

6.2 Storage

Personal information may be stored:

• electronically;

• in secure cloud infrastructure;

• on servers operated by trusted third-party service providers;

• in encrypted databases;

• in secure backup systems;

• in limited physical records where reasonably necessary.

6.3 Security Measures

Tool-O may implement security measures including:

• encryption of data in transit;

• encryption of sensitive data at rest where appropriate;

• secure authentication systems;

• multi-factor authentication for administrative access where

appropriate;

• access controls;

• activity logging;

• intrusion detection;

• network monitoring;

• firewalls;

• regular software updates;

• vulnerability management.

Security measures may change over time as technology and risks evolve.

6.4 Access Controls

Access to personal information is limited to personnel, contractors and service providers who require access to perform authorised business functions.

Such persons are subject to confidentiality obligations and appropriate access controls.

6.5 Password Security

Users are responsible for maintaining the confidentiality of their Account credentials.

Users should:

• choose strong passwords;

• avoid sharing passwords;

• protect authentication devices;

• notify Tool-O immediately if they suspect unauthorised access to their

Account.

6.6 Payment Information

Payment card information is generally processed and stored by our third-party payment providers.

Tool-O does not ordinarily store complete payment card numbers, CVV numbers or similar payment credentials.

6.7 Monitoring

Tool-O may monitor Platform activity for purposes including:

• fraud prevention;

• cybersecurity;

• unauthorised access detection;

• operational integrity;

• system maintenance;

• legal compliance.

6.8 Data Breaches

Where Tool-O becomes aware of a data breach involving personal information, we will investigate the incident promptly.

Where required by law, Tool-O will notify affected individuals and relevant regulatory authorities in accordance with the Privacy Act 1988 (Cth) and the Notifiable Data Breaches scheme.

6.9 Third-Party Service Providers

Where personal information is stored or processed by third-party service providers, Tool-O takes reasonable steps to ensure those providers maintain appropriate security measures consistent with applicable privacy laws.

6.10 International Storage

Some personal information may be stored or processed outside Australia by trusted service providers.

Where this occurs, Tool-O will take reasonable steps to ensure that personal information continues to receive protections substantially similar to those required under Australian privacy law.

6.11 Retention

Tool-O retains personal information only for as long as reasonably necessary to:

• provide the Platform;

• administer Bookings;

• process payments;

• resolve Claims;

• comply with legal obligations;

• investigate fraud;

• enforce our legal rights;

• maintain appropriate business records.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

6.12 Destruction and De-identification

When personal information is no longer reasonably required and Tool-O is not legally required to retain it, we will take reasonable steps to:

\(a\) securely destroy the information; or

\(b\) permanently de-identify the information,

in accordance with applicable privacy legislation and industry practices.

7.1 General

Subject to applicable law, you may have rights in relation to the personal information Tool-O holds about you.

These rights may vary depending on the circumstances and applicable legislation.

7.2 Access

You may request access to personal information that Tool-O holds about you.

Where permitted by law, Tool-O will provide access within a reasonable time.

Access may be refused where permitted or required by law.

7.3 Correction

If you believe personal information held by Tool-O is inaccurate, incomplete, misleading or out of date, you may request that it be corrected.

Tool-O will take reasonable steps to correct personal information where appropriate.

7.4 Updating Your Information

Many personal details can be updated directly through your Tool-O Account.

Users are encouraged to keep their information current to ensure the Platform operates correctly.

7.5 Identity Verification

Before providing access to or correcting personal information, Tool-O may require reasonable evidence to verify the identity of the person making the request.

This helps protect the privacy and security of our Users.

7.6 Withdrawal of Consent

Where Tool-O relies on your consent to collect, use or disclose personal information, you may withdraw that consent at any time.

Withdrawal of consent does not affect processing that occurred before consent was withdrawn.

Withdrawal of consent may limit or prevent your ability to use some Platform features.

7.7 Marketing Communications

You may opt out of receiving marketing communications by:

• clicking the unsubscribe link in marketing emails;

• changing your communication preferences within your Account where

available;

• contacting Tool-O directly.

Essential service communications relating to Bookings, payments, Claims, security or legal obligations cannot be opted out of while you continue using the Platform.

7.8 Cookies

Most internet browsers allow Users to:

• refuse cookies;

• delete cookies;

• restrict tracking technologies.

Disabling cookies may reduce Platform functionality or prevent certain features from operating correctly.

7.9 Location Services

Where the Platform uses location information, you may manage location permissions through your device settings.

Disabling location services may prevent certain Platform features from functioning correctly.

7.10 Account Closure

You may request closure of your Tool-O Account at any time.

Closure of your Account does not require Tool-O to immediately delete all personal information.

Certain information may continue to be retained where reasonably necessary to:

• comply with legal obligations;

• resolve disputes;

• investigate fraud;

• enforce our legal rights;

• maintain appropriate business records.

7.11 Data Portability

Where required by applicable law and technically practicable, Tool-O may provide certain personal information in a commonly used electronic format.

Nothing in this section requires Tool-O to provide information where an exemption applies under applicable law.

7.12 Complaints

If you believe Tool-O has breached applicable privacy laws, you may submit a privacy complaint using the contact details published on the Platform.

Tool-O will investigate complaints in a reasonable and timely manner.

If you are not satisfied with our response, you may have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or another relevant regulatory authority.

7.13 No Fee

Tool-O generally does not charge a fee for requests to access or correct personal information.

However, where permitted by law, Tool-O may charge a reasonable administrative fee for repeated, excessive or manifestly unfounded requests.

Any applicable fee will be communicated before the request is processed.

8.1 General

Tool-O uses cookies and similar technologies to operate, secure and improve the Platform.

By continuing to use the Platform, you acknowledge that Tool-O may use cookies and similar technologies in accordance with this Privacy Policy, subject to any choices available through your browser or device settings.

8.2 What Are Cookies?

Cookies are small text files stored on your device when you visit a website or use certain online services.

Cookies help websites recognise your device, remember your preferences and improve your browsing experience.

8.3 Types of Cookies We Use

Tool-O may use:

• essential cookies;

• functionality cookies;

• preference cookies;

• analytics cookies;

• performance cookies;

• security cookies;

• authentication cookies;

• session cookies;

• persistent cookies;

• advertising cookies where permitted.

Not every type of cookie will necessarily be used at all times.

8.4 Essential Cookies

Essential cookies help the Platform function correctly.

These cookies may be used for purposes including:

• user authentication;

• maintaining login sessions;

• fraud prevention;

• Platform security;

• payment processing;

• load balancing;

• remembering essential preferences.

Without certain essential cookies, parts of the Platform may not function correctly.

8.5 Analytics Cookies

Analytics technologies may be used to understand how Users interact with the Platform.

Information collected may include:

• pages visited;

• features used;

• time spent on pages;

• navigation patterns;

• device type;

• browser type;

• general geographic region;

• referral sources.

Analytics information helps Tool-O improve Platform performance and user experience.

8.6 Performance Cookies

Performance technologies help Tool-O:

• identify technical issues;

• improve loading times;

• monitor Platform stability;

• optimise system performance;

• improve reliability.

8.7 Preference Cookies

Preference cookies may remember User choices including:

• language preferences;

• display preferences;

• login preferences;

• other personalised settings.

8.8 Advertising Technologies

Where permitted by applicable law, Tool-O may use advertising technologies to:

• measure advertising effectiveness;

• improve marketing campaigns;

• understand user engagement.

Users may be able to control certain advertising preferences through browser settings or third-party preference tools.

8.9 Third-Party Technologies

Some cookies and tracking technologies may be placed by trusted third-party service providers assisting Tool-O with:

• analytics;

• payment services;

• fraud prevention;

• customer support;

• cloud services;

• security monitoring;

• performance monitoring.

The use of those technologies may also be subject to the privacy policies of the relevant third parties.

8.10 Managing Cookies

Most web browsers allow Users to:

• accept or reject cookies;

• delete stored cookies;

• restrict tracking technologies;

• configure browser privacy settings.

Blocking certain cookies may reduce Platform functionality or prevent some services from operating correctly.

8.11 Mobile Applications

Tool-O mobile applications may use technologies similar to cookies, including software development kits (SDKs), device identifiers and local storage, to support Platform functionality, security and analytics.

Users may manage certain permissions through their mobile device settings.

8.12 Updates

Tool-O may update its use of cookies and tracking technologies as the Platform evolves.

Material changes will be reflected in this Privacy Policy or otherwise communicated where required by applicable law.

9.1 General

The Platform is intended for use by adults who are legally capable of entering into binding agreements.

Tool-O does not knowingly permit children to create Accounts or enter into Bookings.

9.2 Age Requirement

Users must satisfy the minimum age requirements specified in the Tool-O Terms of Use.

Where identity verification is required, Tool-O may take reasonable steps to verify a User's age.

9.3 Information About Children

Tool-O does not knowingly collect personal information directly from children for the purpose of creating User Accounts.

If Tool-O becomes aware that personal information has been collected from a child in circumstances where such collection was not authorised or permitted by law, Tool-O will take reasonable steps to delete or de-identify that information as soon as reasonably practicable.

9.4 Information Provided by Adults

Users may voluntarily provide information relating to children where reasonably necessary for legitimate purposes connected with a Booking or customer support request.

Examples may include:

• emergency contact information;

• information required to facilitate a Booking;

• information contained in customer support enquiries.

Users should only provide such information where they have the legal authority to do so.

9.5 Parental or Guardian Requests

Where permitted by applicable law, a parent or legal guardian who believes that Tool-O holds personal information relating to their child may contact Tool-O to:

• request access;

• request correction;

• request deletion where appropriate;

• raise a privacy concern.

Tool-O may request reasonable evidence of identity and legal authority before responding.

9.6 Educational Use

The Platform is not designed for use by schools or educational institutions unless expressly approved by Tool-O.

9.7 Safety

If Tool-O reasonably believes that an Account has been created by a person who does not meet the minimum age requirements, Tool-O may:

• suspend the Account;

• terminate the Account;

• remove associated Listings;

• cancel pending Bookings;

• take any other reasonable action necessary to protect Users and comply

with applicable law.

9.8 Compliance

Nothing in this section limits any obligations imposed on Tool-O by the Privacy Act 1988 (Cth), the Australian Privacy Principles or any other applicable law relating to the protection of children's personal information.

10.1 General

Tool-O is based in Australia, however some of our service providers may store or process personal information in countries outside Australia.

By using the Platform, you acknowledge that your personal information may be transferred, stored or processed outside Australia in accordance with this Privacy Policy and applicable law.

10.2 Overseas Service Providers

Tool-O may engage overseas service providers to assist with:

• cloud hosting;

• data storage;

• payment processing;

• identity verification;

• customer support;

• fraud detection;

• artificial intelligence services;

• analytics;

• email delivery;

• messaging services;

• software development;

• cybersecurity.

10.3 Countries

As our business and technology providers change over time, personal information may be processed in Australia and in other countries where our trusted service providers operate.

Tool-O does not guarantee that processing will occur only within Australia.

10.4 Privacy Safeguards

Where personal information is disclosed overseas, Tool-O will take reasonable steps to ensure that recipients:

\(a\) are subject to contractual confidentiality obligations;

\(b\) implement appropriate security measures;

\(c\) process personal information only for authorised purposes;

\(d\) comply with applicable privacy obligations where required.

10.5 Australian Privacy Principles

Tool-O takes reasonable steps to comply with the Australian Privacy Principles when disclosing personal information outside Australia, to the extent required by the Privacy Act 1988 (Cth).

10.6 International Payments

Payment information may be processed by international payment providers or financial institutions where necessary to complete payment transactions.

Such processing is governed by the relevant payment provider's privacy and security practices in addition to this Privacy Policy.

10.7 Artificial Intelligence Providers

Where Tool-O uses artificial intelligence technologies provided by international service providers, information submitted by Users may be processed outside Australia for purposes including:

• image analysis;

• document analysis;

• fraud detection;

• customer support;

• Platform improvements.

Tool-O takes reasonable steps to ensure that such providers maintain appropriate privacy and security protections.

10.8 Business Operations

International transfers may occur where reasonably necessary to:

• maintain Platform availability;

• improve service reliability;

• protect Platform security;

• provide customer support;

• investigate fraud;

• comply with legal obligations.

10.9 Your Rights

Nothing in this section limits any rights you may have under the Privacy Act 1988 (Cth), the Australian Privacy Principles or any other applicable privacy legislation.

10.10 Updates

As Tool-O's technology providers and business operations evolve, the countries in which personal information is processed may change.

Material changes affecting international disclosure practices will be reflected in this Privacy Policy or otherwise communicated where required by law.

11.1 General

Tool-O retains personal information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce our rights and operate the Platform.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

11.2 Account Information

Personal information associated with a User Account may be retained while the Account remains active.

Where an Account is closed, certain information may continue to be retained where reasonably necessary for legitimate business purposes or legal compliance.

11.3 Booking Records

Information relating to Bookings may be retained, including:

• Booking requests;

• Booking confirmations;

• rental history;

• cancellations;

• collection records;

• return records;

• payment records;

• Security Deposit records.

These records may be retained for auditing, taxation, legal compliance and dispute resolution purposes.

11.4 Payment Information

Payment transaction information may be retained for purposes including:

• financial reporting;

• taxation;

• fraud prevention;

• auditing;

• regulatory compliance;

• dispute resolution.

Complete payment card details are generally retained by our authorised payment providers rather than Tool-O.

11.5 Claims Information

Information relating to Claims may be retained, including:

• photographs;

• videos;

• invoices;

• repair quotations;

• reports;

• communications;

• investigation records;

• AI assessment records;

• manual review records.

Claim records may be retained after the completion of a Booking where reasonably necessary.

Photographs, videos and associated metadata (such as timestamps, device information and location data where available) may be analysed by Tool-O, including through AI-assisted systems and manual review, for the purposes of investigating Claims, preventing fraud, resolving disputes, improving Platform security and complying with legal obligations.

11.6 Communications

Messages exchanged through the Platform and communications with customer support may be retained to:

• administer Bookings;

• investigate disputes;

• detect fraud;

• improve customer support;

• comply with legal obligations;

• protect the rights of Tool-O and Users.

11.7 Verification Information

Identity verification information may be retained for as long as reasonably necessary to:

• comply with legal obligations;

• prevent fraud;

• verify previous Account activity;

• respond to lawful requests from authorities.

11.8 Security Logs

Technical logs and security information may be retained for purposes including:

• cybersecurity;

• fraud detection;

• system monitoring;

• incident investigation;

• legal compliance;

• operational integrity.

11.9 Legal Obligations

Tool-O may retain personal information for longer periods where required or authorised by law, including to:

• comply with court orders;

• satisfy regulatory obligations;

• comply with taxation requirements;

• respond to law enforcement requests;

• enforce legal rights.

11.10 De-identification

Where personal information is no longer reasonably required, Tool-O may permanently de-identify the information.

De-identified information is no longer considered personal information and may be retained for purposes including:

• statistical analysis;

• business reporting;

• research;

• product development;

• Platform improvements.

11.11 Secure Destruction

Where personal information is no longer required and Tool-O is not legally required to retain it, Tool-O will take reasonable steps to securely destroy or permanently de-identify the information in accordance with applicable privacy legislation and industry standards.

11.12 Ongoing Obligations

The retention, de-identification and destruction of personal information will be carried out in a manner that is consistent with the Privacy Act 1988 (Cth), the Australian Privacy Principles and any other applicable laws governing the handling of personal information.

12.1 Contacting Tool-O

If you have any questions about this Privacy Policy or the way Tool-O handles personal information, you may contact us using the contact details published on the Platform.

Tool-O will use reasonable efforts to respond to enquiries within a reasonable period.

12.2 Privacy Complaints

If you believe that Tool-O has breached the Privacy Act 1988 (Cth), the Australian Privacy Principles or any other applicable privacy law, you may submit a written privacy complaint.

Your complaint should include, where possible:

• your name and contact details;

• a description of the privacy concern;

• relevant dates;

• supporting documents;

• the outcome you are seeking.

12.3 Investigation

Upon receiving a privacy complaint, Tool-O will:

\(a\) acknowledge receipt within a reasonable period where practicable;

\(b\) investigate the complaint fairly and objectively;

\(c\) request additional information where reasonably necessary;

\(d\) provide a written response once the investigation has been completed.

12.4 Assistance

Tool-O may contact you during the investigation to obtain further information or clarification.

You agree to reasonably cooperate with requests for information that are relevant to the investigation.

12.5 External Complaint Rights

If you are not satisfied with Tool-O's response, or if applicable law permits, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or another competent privacy regulator.

Information regarding the OAIC can be found at:

https://www.oaic.gov.au

12.6 Changes to Contact Details

Tool-O may update its contact details from time to time.

The current contact details published on the Platform will apply.

12.7 Effective Date

This Privacy Policy takes effect from the Effective Date published on the Platform and continues until replaced by an updated version.

12.8 Relationship with Terms of Use

This Privacy Policy should be read together with the Tool-O Terms of Use and any other policies published on the Platform.

Where this Privacy Policy is inconsistent with the Terms of Use in relation to the handling of personal information, this Privacy Policy prevails to the extent of that inconsistency.

END OF PRIVACY POLICY