Mine Privacy Policy

1. About Mine

Mine Technologies Pty Ltd (ABN 24 693 393 127, ACN 693 393 127) operates the Mine mobile application, the Mine website and the Mine brand platform.

In this Privacy Policy, “Mine”, “we”, “us” and “our” mean Mine Technologies Pty Ltd.

Mine allows eligible members to share limited website activity signals, participate in brand audiences and receive payments when they meet applicable eligibility requirements. Mine also provides brands with aggregated audience insights and, where an eligible commerce platform such as Shopify is connected, aggregated or modelled purchase-outcome insights.

This Privacy Policy explains how we collect, hold, use and disclose personal information.

Our contact details are:

Mine Technologies Pty Ltd

2/17 Penfold Road

Magill SA 5072

Australia

Email: brad@mineinsights.com.au

Website: https://mineinsights.com.au/

2. Who this policy applies to

This policy applies to:

• people who create or use a Mine member account;
• representatives of brands that create or use a Mine brand account;
• customers whose order or related commerce information is supplied to Mine through a brand’s connected commerce platform, whether or not they have a Mine account;
• people who visit our website;
• people who contact us; and
• other individuals whose personal information we handle in connection with Mine.

Mine is currently intended for use in Australia. Members must be at least 18 years old.

3. What personal information we collect

3.1 Member account information

When a member creates or uses a Mine account, we may collect:

• login email address;
• authentication information handled through Supabase;
• recovery email address;
• internal account and user identifiers;
• date of birth;
• sex or gender selection;
• residential country and state or territory;
• account status and onboarding status;
• login, password-reset and authentication information;
• legal-document and consent acceptance records; and
• support and account correspondence.

We collect date of birth to confirm age eligibility. We use location at a broad country and state or territory level rather than collecting a residential street address through normal app onboarding.

3.2 Share Signals information

When a member turns on Share Signals, Mine uses an Apple Network Extension and Packet Tunnel to process DNS requests made by the device.

DNS requests contain the domain names used by the device to locate online services.

While Share Signals is active:

• Mine may observe DNS requests passing through the Packet Tunnel;
• qualifying DNS activity may be used to record that Share Signals was active on a particular calendar day;
• Mine compares requested root domains against a limited watchlist of participating brand and competitor websites;
• when a watched root domain is detected, Mine may record the root domain and calendar day;
• Mine may store technical information such as detection type, confidence value and creation time; and
• signal records are linked internally to the member’s Mine user identifier.

Mine does not collect or store a member’s full browsing history. A member’s full browsing history is not uploaded to or stored by Mine.

Mine is not designed to store:

• complete URLs;
• page paths;
• page contents;
• search terms;
• form entries;
• passwords entered on other services;
• messages or communications; or
• a complete record of every website the member visits.

Mine stores limited visit events for selected participating brand and competitor websites, together with activity-day records used to determine eligibility and payments.

A record that a member visited a watched root domain is personal information in Mine’s systems because it is connected to an internal user identifier.

3.3 DNS resolver processing

While Share Signals is active, DNS requests are forwarded to a third-party DNS resolver so that requested websites and online services can be located.

Mine currently uses Cloudflare’s 1.1.1.1 DNS resolver for this purpose.

Cloudflare may process DNS information in accordance with its own terms and privacy practices. Mine only saves watched-domain matches in its own visit records, but the external DNS resolver may process broader DNS requests required to provide DNS resolution.

3.4 Activity and qualification information

We may collect or generate information about:

• calendar days on which qualifying Share Signals activity is observed;
• monthly activity totals;
• the proportion of eligible days on which activity was observed;
• monthly qualification outcomes;
• the version of the qualification rule applied; and
• the brands for which a member may be eligible to receive a payment.

The current qualification rule is qualifying Share Signals activity on at least 20% of the calendar days in the relevant month, rounded up to the next whole day.

A member does not need to visit a particular participating website on every qualifying day. A day may count when Share Signals is active and Mine observes qualifying DNS activity from the member’s device.

Mine uses automated rules to calculate qualification. Those rules may affect whether a member receives an earning for a particular month.

3.5 Brand audience information

We may collect or generate information about:

• brands whose audiences a member has joined;
• whether the membership is active, pending, removed or otherwise inactive;
• how the member joined the audience;
• when the audience relationship started or ended;
• whether the member was matched through Audience Builder; and
• related payment eligibility.

Members may join a brand through a brand invitation, or Mine may match a member with a brand audience based on eligible watched-domain activity.

This means a member may be added to a relevant brand audience without separately approving each brand, where this is permitted by the member’s Share Signals settings and the Mine service rules.

Members can view the brands currently accessing their signals and can use Mine’s available controls to leave an individual brand audience.

Membership of a brand audience does not, by itself, enable Purchase Matching. Purchase Matching operates only while the member has turned on Share Signals under the notice and consent process described in section 3.9. Once Share Signals is on, Purchase Matching may apply to current and future commerce-connected brands in the member’s Mine audiences without a separate approval for each brand. A member can leave an individual brand audience to stop new Purchase Matching for that brand.

3.6 Device and app information

We may collect:

• device push-notification tokens;
• device platform;
• app version and build;
• notification permission status;
• Packet Tunnel connection status;
• Share Signals preference;
• Share Signals status, consent version and acceptance time, including the status of Purchase Matching as part of Share Signals;
• local signal-session ownership information;
• app errors and operational diagnostics; and
• security and login information.

We do not use the Apple advertising identifier as part of the documented Mine signal system.

3.7 Earnings and payment information

We may collect or generate:

• current and historical earnings;
• brand payment allocations;
• withdrawal amounts;
• withdrawal status and dates;
• payment and transfer references;
• failed-withdrawal information;
• connected payout-account status;
• Stripe customer and connected-account identifiers; and
• billing, invoicing, tax and reconciliation records.

Members may be required to provide identification, contact, banking or other verification information directly to Stripe. Stripe may provide Mine with account status, payment capability, transaction and verification-status information.

Mine does not normally receive or store complete bank-account or card details entered directly into Stripe.

3.8 Brand and brand-representative information

For brand accounts, we may collect:

• brand name;
• representative’s work email address;
• authentication and account information;
• primary website;
• competitor website configuration;
• active-user cap;
• audience selections and criteria;
• billing contact and payment status;
• limited payment-method information, such as card type and last four digits;
• brand dashboard activity;
• campaign markers and notes;
• connected commerce-platform identity, store domain, store name and currency;
• commerce-integration status, authorised permissions, installation and disconnection information;
• synchronisation, webhook, reconciliation and connection-health records;
• communications with Mine;
• Brand Platform Terms and Privacy Policy acceptance records; and
• support, security and audit records.

A brand’s name, logo and primary website may be shown to Mine members. Competitor configuration, billing controls and internal brand-account information are not intended to be shown to members.

3.9 Commerce, purchase and Purchase Matching information

A “Store Customer” is a person whose information is contained in Purchase Data received from a brand’s connected store, whether or not that person has a Mine account.

A brand may choose to connect an eligible commerce platform, including Shopify, to Mine. In this policy, “Purchase Data” means the order, payment, refund, cancellation and related commerce information supplied to Mine through that connection. Mine may receive Purchase Data from the brand’s store through authorised application programming interfaces, webhooks, reconciliation processes and an initial historical import.

For the initial Purchase Matching feature, Purchase Data may include:

• a store, order, customer, transaction or refund identifier, which Mine may convert to an internal or keyed digest;
• the customer email address associated with an order;
• order, payment, cancellation, edit and refund dates;
• gross order value;
• discount amount;
• refund amount;
• net revenue;
• currency;
• financial or cancellation status; and
• information required to determine whether an order is a first or repeat purchase for a pseudonymous subject.

Mine does not ordinarily require or intend to retain Store Customer names, phone numbers, street addresses, shipping details, complete payment-card details, product-level line items or shipping instructions for the initial Purchase Matching feature. Mine will update this policy and provide any required notice before materially expanding the Purchase Data used for that feature.

Purchase Matching is part of Share Signals rather than a separate member setting. Share Signals is off by default. Before a member first turns it on, Mine displays a concise collection and consent notice beside the Share Signals control, with links to the Member Terms and this Privacy Policy. The notice explains the website signals collected, private purchase matching, the aggregated insights provided to brands and the effect of turning Share Signals off.

By turning on Share Signals, the member affirmatively:

• consents to the collection and use of website signals and the private matching of eligible purchases as described in the notice and this Privacy Policy;
• agrees to the current Member Terms; and
• acknowledges the current Privacy Policy.

Mine may record:

• whether Share Signals is enabled or disabled;
• the wording and version of the notice, Member Terms and Privacy Policy presented;
• the date and time of the member’s choice;
• the brands for which matching may occur; and
• the date Share Signals, and therefore new Purchase Matching, was disabled or otherwise ended.

If Mine materially changes the consented activities, Mine may require the member to review and accept a new consent version before Share Signals can continue.

While Share Signals is on:

• Mine may retrieve the member’s verified Mine sign-in email address from its authentication system;
• Mine normalises that email address, including by trimming spaces and converting it to lowercase;
• Mine uses a secret-keyed HMAC-SHA-256 process to generate a secure, non-readable matching code from the normalised email address;
• Mine stores the matching code, its key version, the applicable consent version and consent time in its commerce-matching system, but does not store the readable sign-in email in the commerce-matching table or return the email or matching code to the app;
• when an eligible order is received, Mine may transiently process and normalise the order email address, generate the corresponding secure matching code and compare the codes;
• Mine discards the raw order email address promptly after the matching step, except where limited temporary processing is reasonably required for security, reconciliation, privacy compliance or another disclosed lawful purpose;
• if a match is made, Mine may associate minimal purchase facts with a pseudonymous Mine subject for the relevant brand; and
• Mine may combine the pseudonymous purchase facts with that member’s brand-audience status, Member Earning records and privacy-safe website activity signals to calculate aggregated or modelled outcomes.

The secure matching code and associated pseudonymous identifiers are personal information in Mine’s systems while Mine can reasonably link or use them in relation to a member or Store Customer. They are not treated as anonymous merely because the readable email address is not displayed. The matching code may be used internally across participating brands for the limited matching purposes described in this policy, but it is not provided to brands or exposed as a universal customer identifier.

Where Purchase Data does not match an eligible consenting member, Mine may:

• discard the individual order after the matching and operational processing is complete;
• retain only a properly de-identified or aggregated store-level statistical fact; or
• retain a minimal record temporarily where reasonably required for deduplication, reconciliation, security, privacy compliance or another disclosed lawful purpose.

We may collect or generate Purchase Matching and commerce-outcome information including:

• whether an eligible member match occurred;
• a pseudonymous matching or subject identifier;
• matched purchase dates and net revenue;
• purchase rate;
• repeat-purchase rate;
• average order value;
• purchase frequency;
• observed revenue and sales change following Member Earnings;
• estimated incremental revenue;
• Audience Return or Audience ROI;
• audience participation or stickiness;
• the methodology and measurement period used;
• match coverage, evidence state and confidence indicators; and
• related error, reconciliation and audit information.

Unless Mine clearly states another treatment date for a particular measurement, the date a Member Earning is credited to the member’s Mine balance is used as the reward event. A later withdrawal date is not ordinarily used as the reward event.

Purchase Matching may be incomplete or inaccurate because of guest checkout, different or shared email addresses, missing or delayed records, refunds, cancellations, offline purchases, technical failures or platform limitations.

3.10 Communications and marketing information

We may collect:

• email addresses;
• marketing preferences;
• push-notification preferences;
• delivery, opening, bounce and unsubscribe information;
• sales and product-update preferences; and
• records of communications with us.

4. How we collect personal information

We may collect personal information:

• directly from a member or brand representative;
• automatically through the Mine app or website;
• through Share Signals when it is turned on;
• from Stripe, Apple, Supabase, Resend and other service providers;
• from Shopify and other commerce platforms connected by a brand;
• from a connected store’s authorised APIs, webhooks, initial import and reconciliation processes;
• from brands that supply or authorise the supply of Store Customer Purchase Data;
• through privacy, access, correction, deletion or redaction requests submitted by a brand, Store Customer or commerce platform;
• from brands inviting members to participate;
• through Audience Builder and Mine’s audience-management processes;
• through support communications; and
• where permitted, from publicly available business information.

Purchase Data is ordinarily collected indirectly from a brand or connected commerce platform rather than directly from the Store Customer. Mine requires brands to have authority to supply that information and to provide Store Customers with any notice required by applicable law. Where practicable, Mine may also provide or require layered notices explaining the source, circumstances and purpose of the collection.

Mine provides members with a specific inline notice before they first turn on Share Signals. If a member does not turn on Share Signals, or later turns it off, Mine will not intentionally use the member’s verified sign-in email address to match new purchases for participating brands during that period. Turning Share Signals off does not remove an earning already validly credited, but it may affect whether the member meets future Share Signals participation requirements.

Where practicable, we provide a collection notice before or when personal information is collected. If that is not practicable, we may provide notice as soon as practicable afterwards. A general Privacy Policy may be supplemented by a feature-specific collection notice.

5. How we use personal information

We may use personal information to:

• create and secure accounts;
• verify age and Australian eligibility;
• authenticate users and reset passwords;
• operate Share Signals;
• detect watched brand and competitor domains;
• record qualifying activity days;
• calculate monthly eligibility and earnings;
• create and manage brand audiences;
• automatically match members with relevant brand audiences;
• prepare aggregated audience insights;
• create, authenticate, maintain and disconnect commerce integrations;
• receive, validate, deduplicate and reconcile Purchase Data;
• privately match the secure, non-readable code of a member who has turned on Share Signals with the corresponding code generated from an eligible Store Customer email address;
• create and maintain pseudonymous purchase records for the relevant brand;
• calculate observed purchase outcomes and modelled commercial outcomes;
• calculate purchase rate, repeat-purchase rate, average order value, purchase frequency, estimated incremental revenue, Audience Return, Audience ROI and audience stickiness;
• measure changes following Member Earnings and explain those changes using privacy-safe website activity signals;
• show match coverage, evidence states, methodology and confidence indicators;
• respond to privacy, access, correction, deletion and redaction requests;
• comply with Shopify and other connected-provider requirements;
• process brand billing;
• allocate member earnings;
• process and reconcile withdrawals;
• send payment, account, security and service notifications;
• send marketing and product communications where permitted;
• provide support and respond to complaints;
• detect fraud, misuse and security incidents;
• monitor and improve Mine;
• maintain legal and accounting records;
• enforce our Terms; and
• comply with legal obligations.

We may also use information for another purpose where the person has consented or where the use is otherwise authorised or required by law.

Mine does not intend to use Purchase Matching or Purchase Data to make an individual decision that produces legal or similarly significant effects about a member or Store Customer. Brands are prohibited from using Mine insights to make prohibited individual-level decisions.

6. Information brands receive

Mine does not provide brands with members’ names, email addresses, contact details or Mine account identities.

Brands do not receive direct access to:

• complete URLs;
• page contents;
• raw DNS requests;
• individual domain-visit records;
• individual member signal records; or
• complete individual browsing histories;
• a member’s Share Signals consent record or individual Purchase Matching status;
• individual matched purchase records;
• individual purchase values, products, frequency or history; or
• a member-level export linking Mine participation with purchases.

Brands receive aggregated audience insights, which may include:

• active and pending member counts;
• website and competitor reach;
• visit-day totals;
• engagement and attention measures;
• repeat-visit categories;
• demographic distributions;
• audience trends;
• billing and qualified-member counts; and
• calculated scores or indicators.

Where a brand has connected an eligible commerce platform, it may also receive aggregated, statistical or modelled commerce insights, including:

• matched-member and purchaser counts;
• match coverage;
• observed net revenue;
• purchase rate;
• repeat-purchase rate;
• average order value;
• purchase frequency;
• observed sales change following Member Earnings;
• estimated sales uplift or incremental revenue;
• Audience Return;
• Audience ROI where the brand has supplied an appropriate contribution-margin or profit input;
• audience stickiness; and
• methodology, measurement-period, evidence-state and confidence information.

Mine may provide existing behavioural audience insights for audiences with as few as two active members. Where an audience is small, a percentage or aggregate result may be more revealing than the same result for a larger audience.

Commerce outcomes create a greater inference risk because a brand also holds its own order records. Mine will suppress cohort-level commerce outcomes where fewer than 30 matched members are included in the relevant reported cohort, unless a different threshold is adopted following privacy and legal review. Mine may apply a higher threshold, limit filters or overlapping comparisons, suppress narrow cells, delay a result or withhold an export where reasonably required to reduce re-identification or singling-out risk.

An “observed change” describes what Mine measured before or after a Member Earning or during another stated period. “Estimated incremental revenue” and related uplift metrics are modelled outcomes based on Mine’s stated methodology and comparison data. They do not establish that Mine or a Member Earning caused a particular purchase.

“Audience Return” ordinarily means estimated incremental net revenue divided by the applicable brand investment in Mine, excluding GST and subject to the basis displayed with the metric. “Audience ROI” is a profit-based estimate and is only available where an appropriate contribution margin or other profit input is supplied or confirmed. The dashboard may display an estimated statement such as “Every A$1 invested in your Mine audience returned an estimated A$15 in incremental revenue” only where supported by sufficient data, a disclosed methodology and an appropriate evidence state.

Brands are required not to:

• attempt to identify or re-identify a member;
• combine Mine insights with other information to identify a member;
• attempt to infer an individual member’s browsing behaviour;
• attempt to determine whether an individual member purchased, what they purchased, when they purchased or how much they spent;
• use filters, overlapping cohorts, exports or comparison techniques to infer an individual purchase or match;
• single out members using Mine results; or
• use Mine insights to make prohibited individual-level decisions.

These restrictions are also addressed in the Brand Platform Terms.

References to “anonymous insights” in Mine’s marketing describe brand-facing insights that do not include direct member identifiers, individual signal records or individual purchase matches. They do not mean that Mine itself holds no information connected to a member account. Pseudonymous information remains personal information where Mine can reasonably connect or use it in relation to an individual.

7. Who we disclose information to

7.1 Brands

We provide brands with the aggregated audience and commerce information described above. We do not provide brands with direct access to member account profiles, raw member signal records, Share Signals consent records, individual purchase matches or individual member purchase histories.

Where a Store Customer makes a valid privacy request through a connected store or commerce platform, Mine may provide the brand or store owner with information reasonably required to respond to that request. This does not permit the brand to use Mine’s response to identify a Mine member or for another unrelated purpose.

7.2 Service providers

We may use service providers including:

• Supabase for authentication, databases, storage and server functions. Mine’s two primary Supabase projects are hosted in Australia in the ap-southeast-2 region;
• Stripe for card payments, invoicing, identity verification, connected accounts and withdrawals;
• Apple for app distribution, Network Extension services and push notifications;
• Resend for account and email delivery;
• Cloudflare for DNS resolution;
• Shopify and other commerce platforms for store authorisation, APIs, webhooks, source commerce data, app operation and privacy-request handling;
• DigitalOcean for production hosting of Mine’s marketing website, brand dashboard, admin dashboard and related frontend assets;
• Replit for development and deployment tooling. Relevant Replit development or published resources may be hosted in North America;
• security, monitoring, professional and technical service providers; and
• accountants, lawyers, auditors and other professional advisers.

These providers may process personal information on our behalf, make information available to Mine at a brand’s direction or act as independent service providers under their own legal and privacy obligations.

7.3 Authorities and legal recipients

We may disclose personal information:

• where required or authorised by law;
• in response to a valid legal process;
• to protect the safety, rights or property of Mine, members, brands or others;
• to investigate fraud, misuse or security incidents; or
• in connection with a proposed sale, restructure, financing or transfer of Mine’s business, subject to appropriate protections.

8. Overseas processing

Mine’s two primary Supabase projects are hosted in Australia in the ap-southeast-2 region.

Some other service providers may process or support information outside Australia. Likely overseas processing locations include Canada and the United States, including through Shopify, email delivery and development or deployment services. Stripe, Apple, Cloudflare, Shopify and other providers or their subprocessors may also process information in other countries in which they operate.

Where practicable, Mine will maintain and update information about the countries in which overseas recipients are likely to be located.

Where required, we take reasonable steps to ensure overseas recipients handle personal information consistently with applicable Australian privacy requirements.

9. Marketing communications

Mine may send members and brand representatives:

• product updates;
• service announcements;
• educational content;
• sales communications;
• offers;
• surveys; and
• other marketing messages.

We will send electronic marketing only where the recipient has consented or where the communication is otherwise permitted by law.

Marketing communications are distinct from essential service communications. Mine may still send necessary messages about verification, passwords, invoices, payments, security, legal changes, service interruptions or account actions even where a person has opted out of marketing.

Marketing emails will include a way to unsubscribe. A person can also opt out by contacting brad@mineinsights.com.au.

Members can manage push notifications through the Mine app and iPhone settings. Where Mine offers separate marketing-notification controls, members may use those controls without preventing essential account, security, legal or transaction-related communications where permitted.

We will not sell contact lists to third-party marketers.

10. Security

Mine uses administrative, technical and organisational safeguards designed to protect personal information.

These may include:

• encrypted connections;
• encryption of stored protected customer data and backups;
• authentication controls;
• row-level database security;
• restricted administrator access;
• restricted staff access to Purchase Data and other protected customer data;
• short-lived authentication tokens;
• encrypted storage of commerce-platform access tokens and secrets;
• secret-keyed HMAC matching codes for Purchase Matching;
• separation of production and test data;
• separation between brand and Core systems;
• local signal-session ownership checks;
• access logging, monitoring and audit trails;
• data-loss prevention and incident-response processes;
• secure payment providers; and
• deletion or de-identification processes.

No internet or storage system is completely secure. We cannot guarantee that unauthorised access, loss or misuse will never occur.

If an eligible data breach occurs, we will respond in accordance with applicable notification requirements.

11. How long we retain information

We retain personal information only for as long as reasonably needed for the purposes described in this policy, including to operate Mine, calculate earnings, provide historical records, resolve disputes and meet legal obligations.

Our current retention approach is:

• raw watched-domain visit events are retained for 12 months from the visit date and are then permanently deleted;
• daily Share Signals activity records are retained for 12 months from the activity date and are then permanently deleted;
• raw Store Customer email addresses received with Purchase Data are intended to be processed transiently for matching and discarded promptly after the secret-keyed HMAC matching code is generated; they are not intended to be written to Mine’s long-term purchase records or ordinary application logs;
• complete commerce webhook payloads are retained only for the shortest period reasonably required to validate, process, reconcile and secure the event and are ordinarily deleted or reduced to the permitted minimal record within 30 days;
• an unmatched individual order is ordinarily discarded after matching and operational processing, while a minimal unmatched record required for deduplication, reconciliation, security or privacy compliance is ordinarily retained for no more than 30 days unless a longer period is required by law or a valid privacy request;
• matched pseudonymous purchase records are retained for up to 24 months from the relevant purchase, refund or last material reconciliation date and are then deleted or properly de-identified, unless a shorter period applies after Share Signals is turned off, following a privacy request or under a commerce-platform requirement, or a longer period is required by law;
• commerce-platform access tokens are retained only while the integration remains authorised and are deleted or rendered unusable after disconnection as soon as reasonably practicable;
• commerce-integration metadata, webhook receipts, consent evidence, privacy-request records and security audit records may be retained for the periods reasonably required to demonstrate authorisation, compliance, security and dispute handling;
• properly aggregated and de-identified analytics may be retained indefinitely for reporting and trend analysis;
• billing, earnings, withdrawal, payment, invoice, tax and accounting records are generally retained for seven years;
• account and profile information is retained while an account remains active and may be retained for up to 90 days after closure before being deleted or de-identified, unless a longer period is required by law or reasonably needed to resolve a payment, security, fraud or legal issue;
• legal acceptance evidence may be retained for seven years after the relevant account or contractual relationship ends;
• device notification tokens are retained until they are invalid, replaced, notifications are disabled or the account is deleted;
• unsynchronised local signals remain on the device until uploaded, cleared, the member signs out, Share Signals is turned off or the account is deleted;
• recently synchronised local visit records may remain on the device for up to three days as a technical safety measure; and
• temporary Audience Builder previews are generally retained for approximately 30 minutes.

For this policy, “de-identified” means that identifiers have been removed and Mine cannot reasonably reconnect the information to an identifiable individual. Merely labelling information as aggregated does not make it de-identified if it can still reasonably be connected to a person.

Raw signal information used to calculate a qualification or payment remains subject to the 12-month retention period. Mine may retain the resulting qualification, earning and financial ledger records for seven years without retaining the underlying raw signal records for that entire period.

Pseudonymous purchase information is not treated as de-identified while Mine can reasonably use a key, identifier or other information to reconnect it to a member or Store Customer. A retained commerce-outcome snapshot may be kept as de-identified analytics only where Mine cannot reasonably reconnect the result to an individual.

Where a valid Shopify or other commerce-platform privacy request requires earlier access, deletion or redaction, Mine will apply the applicable request process and legal exception rather than relying only on the ordinary retention periods above.

Deletion from active systems may not immediately remove encrypted backup copies. Backup copies are protected from ordinary use and are deleted or overwritten through Mine’s routine backup-rotation process, unless retention is required by law.

Information that is no longer required will be deleted or de-identified where practicable, unless retention is required or authorised by law.

12. Turning Share Signals off

A member can stop new website-signal collection and new Purchase Matching at any time by turning Share Signals off.

Turning Share Signals off:

• stops future signal collection through Mine;
• stops new purchase matching for participating brands prospectively;
• disables Mine’s Packet Tunnel and On Demand connection;
• clears applicable local signal-session information;
• clears local visit and activity records from the device; and
• updates the member’s Share Signals and Purchase Matching status.

Turning Share Signals off does not, by itself, immediately delete records previously uploaded to Mine’s servers. Those records remain subject to the retention periods in section 11.

Turning Share Signals off does not require deletion of properly de-identified or aggregated insights already produced and may not require immediate deletion of limited records Mine must retain for legal, security, fraud, dispute, audit, reconciliation or privacy-compliance purposes.

If a member later turns Share Signals on again, website-signal collection and Purchase Matching may resume. Mine may rely on the member’s previously recorded acceptance of the current consent version. If the Member Terms, Privacy Policy or consented activities have materially changed, Mine may require the member to review and accept a new version before Share Signals can resume.

A member may request account deletion or contact Mine about existing information.

13. Share Signals choice, Purchase Matching and withdrawal

A member chooses whether to enable Share Signals. Purchase Matching is included within Share Signals and is not controlled by a separate toggle.

Purchase Matching will not be enabled merely because the member:

• accepts the Member Terms or this Privacy Policy;
• joins or is added to a brand audience;
• qualifies for a monthly earning; or
• receives or withdraws a Member Earning.

Purchase Matching is enabled only when the member affirmatively turns on Share Signals after being shown the applicable collection and consent notice. While Share Signals remains on, Purchase Matching may apply to current and future commerce-connected brands in the member’s Mine audiences. Mine will identify participating brands through the available member interface.

A member may withdraw from new Purchase Matching by turning Share Signals off. Turning Share Signals off:

• stops new purchase matching for participating brands prospectively;
• does not remove the member from a brand audience;
• does not remove an otherwise valid Member Earning already credited;
• may affect whether the member meets future Share Signals participation requirements;
• does not require deletion of properly de-identified or aggregated results already produced; and
• may not require immediate deletion of limited records Mine must retain for legal, security, fraud, dispute, audit, reconciliation or privacy-compliance purposes.

Mine will delete or de-identify underlying pseudonymous purchase information that is no longer required in accordance with section 11 and applicable law. Leaving an individual brand audience also stops new Purchase Matching for that brand prospectively.

A member does not need to make a purchase or have a purchase matched to qualify for a standard Member Earning. The member must still meet Mine’s applicable audience-membership and Share Signals participation requirements.

14. Account, integration and commerce-data deletion

Members may initiate account deletion from within the Mine app.

Brand representatives may request closure of a brand account through Brand Settings or by contacting Mine.

When a member deletes their account, Mine will take steps to:

• stop Share Signals;
• disable the member’s purchase-matching identity;
• remove local signal information;
• end active brand-audience relationships;
• remove device notification tokens;
• pay any available member balance, including a balance below the ordinary A$5 withdrawal minimum;
• delete or de-identify account, signal and pseudonymous purchase information that is no longer required; and
• close authentication access.

Mine will ordinarily complete deletion or de-identification of account and profile information within 90 days after closure, subject to the exceptions below.

Deletion may not be immediate where:

• a withdrawal is still processing;
• identity or authority must be verified;
• there is an unresolved payment, dispute or security issue; or
• information must be retained for accounting, tax, fraud, dispute or legal purposes.

Financial and payment records retained after account closure are kept only for the permitted retention purposes described in section 11.

Deleting a Mine member account does not require a brand or Shopify to delete the brand’s own lawful sales, tax or customer records. Mine will remove or de-identify the Mine-side member link and pseudonymous purchase information where required, subject to the permitted retention exceptions above.

When a brand closes its Mine account or disconnects a commerce integration, Mine will take steps to:

• stop intentionally collecting new Purchase Data from that integration;
• revoke, delete or render unusable the applicable access token;
• disable the connection and related webhooks;
• delete or de-identify Store Customer Purchase Data that is no longer required;
• retain only information permitted under section 11, applicable law, a valid privacy request or a binding commerce-platform requirement; and
• retain properly de-identified or aggregated outputs where lawful.

Mine receives and responds to Shopify’s mandatory privacy and compliance requests, including:

• customer data-access requests;
• customer deletion or redaction requests; and
• shop deletion or redaction requests.

Mine intends to complete a valid Shopify privacy action within the timeframe required by Shopify, ordinarily within 30 days after receiving the request, unless Mine is legally required or authorised to retain particular information. A Store Customer may also contact the relevant brand or Mine directly using the details in section 18.

15. Access and correction

A person may ask to access personal information Mine holds about them or request that inaccurate, incomplete, out-of-date or misleading information be corrected.

Requests can be sent to:

brad@mineinsights.com.au

We may need to verify the requester’s identity before providing access or making changes.

We may refuse or limit access where permitted by law. Where appropriate, we will explain the reason.

A Store Customer whose Purchase Data was supplied through Shopify or another connected commerce platform may make a request through the relevant store or directly to Mine. Mine may need the store identity, order reference, customer email address or other limited information reasonably required to locate and verify the record. Mine will avoid requesting unnecessary personal information.

Access to pseudonymous Purchase Matching information may require Mine to verify the requester and recreate or compare the applicable secret-keyed HMAC matching code. Mine will not disclose another person’s information or reveal whether another person is a Mine member.

16. Privacy complaints

Questions or complaints about privacy may be sent to:

Privacy Contact

Mine Technologies Pty Ltd

2/17 Penfold Road

Magill SA 5072

Australia

Email: brad@mineinsights.com.au

Please include enough information for us to understand and investigate the issue.

Mine will acknowledge and investigate privacy complaints within a reasonable period.

Where the Privacy Act 1988 (Cth) applies and a person is not satisfied with our response, they may be entitled to contact the Office of the Australian Information Commissioner.

17. Changes to this policy

We may update this Privacy Policy when Mine, our technology, our providers or legal requirements change.

We will publish the updated version and change the “last updated” date.

Where a change is material, we may provide notice through the Mine app, website or email. Where required, we will ask for renewed consent.

18. Contact

Questions about this Privacy Policy can be sent to:

brad@mineinsights.com.au

Mine Technologies Pty Ltd

ABN 24 693 393 127

ACN 693 393 127

2/17 Penfold Road

Magill SA 5072

Australia