Privacy Policy – Old

The Privacy Act 1988 (Cth) (Privacy Act) seeks to protect individuals against interferences with their privacy by regulating the way in which personal information is collected, handled, disclosed, used and stored.

SmartAI Pty Ltd (SMARTAI) understands the importance of, and is committed to, protecting the privacy of an individual’s personal information. In handling personal information, SMARTAI is committed to complying with the Privacy Act and the 13 Australian Privacy Principles in the Privacy Act.

This policy sets out how SMARTAI aims to protect the privacy of your personal information, your rights in relation to your personal information managed by SMARTAI and the way SMARTAI collects, holds, uses and discloses your personal information. This policy may be updated from time to time.


Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of SMARTAI’s services, SMARTAI may collect your personal information. Generally, the kinds of personal information SMARTAI collects may include:

  • general contact and identification details (e.g. name, address, email address and phone number); and
  • other information relevant in the circumstances.

In some circumstances SMARTAI may also hold other personal information provided by you or by either or both your employer and our client.


Generally, personal information will be collected from you directly when a SMARTAI ‘BOT’ requires you to verify your details, or other means, whether at SMARTAI’s request or at your own initiative.

In most instances our ‘BOT’ will ask you for your email address and then send a verification code to this email address to verify it belongs to you. Once you have provided the correct verification code back to the ‘BOT’, SMARTAI will request for further information like your name, phone number and email address from the source application and store it in our database to enable the ‘BOT’ to render services to you.

If you do not provide the verification code no personal information will be collected or stored by SMARTAI.

There may be other occasions when SMARTAI collects your personal information from other sources such as an information services provider, your employer or ex-employer or a publicly maintained record, including records publicly available through social media. Generally, SMARTAI will only collect your personal information from sources other than you if it is unreasonable, impracticable or depreciates user experience of our service to collect your personal information from you.

You can choose not to provide SMARTAI with any information about you, although it may be needed to receive the services provided by SMARTAI.


SMARAI collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of ensuing its ‘BOT’ optimises it service to you.

SMARTAI may also collect, hold, use or disclose your personal information for:

  • administrative and business management purposes;
  • marketing purposes and to identify and inform you of products, services and training courses that may be of interest to you;
  • notifying you either by email, SMS or push notification; and/or
  • any other legal requirement.

Where personal information is used or disclosed, SMARTAI takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.

You are under no obligation to provide your personal information to SMARTAI. However, without certain information from you, or where information provided is inaccurate or irrelevant, SMARTAI may not be able to provide its services to you or may be limited in its ability to provide its services to you.


SMARTAI discloses your personal information for the purpose for which SMARTAI collects it. That is, generally, SMARTAI will only disclose your personal information for a purpose related to the provision of services by its ‘BOT’ or otherwise as set out in this policy. This may include disclosing your personal information to:

  • clients of SMARTAI who may be your employer;
  • other organisations within the SMARTAI Group, for development of SMARTAI’s products and services;
  • SMARTAI’s insurers;
  • a professional association or registration body if relevant to the provision of SMARTAI’s services or otherwise with your consent;
  • SMARTAI’s contractors and suppliers;
  • SMARTAI’s professional advisors;
  • any other entity, with your consent, or to whom disclosure is required or authorised by law; and/or
  • any other third parties engaged to perform administrative or other services.

This disclosure is always on a confidential basis or otherwise in accordance with law.


SMARTAI may disclose personal information to overseas recipients in order to provide its services and for administrative or business management purposes. Recipient of such disclosures is located in the United States and India, but may also be located in other countries.

Before disclosing any personal information to an overseas recipient, SMARTAI takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law.


SMARTAI may use and disclose your personal information to inform you of products and services that may be of interest to you. If you do not wish to receive such communications, you can opt-out by contacting SMARTAI via the contact details set out below or through any opt-out mechanism contained in a marketing communication to you. SMARTAI does not disclose your information for facilitating direct marketing by another organisation.


SMARTAI takes all reasonable steps to ensure personal information it holds is protected against misuse, interference and loss and from unauthorised access, modification or disclosure. SMARTAI holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.

SMARTAI will destroy or de identify personal information in circumstances where it is no longer required, unless SMARTAI is otherwise required or authorised by law to retain the information.


SMARTAI takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up to date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by SMARTAI. If at any time you would like to access or correct the personal information that SMARTAI holds about you, or you would like more information on SMARTAI’s approach to privacy, please contact SMARTAI via the contact details set out below. SMARTAI will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

  • you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
  • SMARTAI requests that you be reasonably specific about the information you require; and
  • SMARTAI may charge you a reasonable administration fee, which reflects the cost to SMARTAI for providing access in accordance with your request.

SMARTAI will endeavour to respond to your request to access or correct your personal information within 30 days from your request.

If SMARTAI refuses your request to access or correct your personal information, SMARTAI will provide you with written reasons for the refusal and details of complaint mechanisms. SMARTAI will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of SMARTAI.


Please direct all privacy complaints to SMARTAI’s Privacy Officer via the contact details below.

At all times, privacy complaints:

  • will be treated seriously;
  • will be dealt with promptly;
  • will be dealt with in a confidential manner; and
  • will not affect your existing obligations or affect the commercial arrangements between you and SMARTAI.

SMARTAI’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.


For further information or enquiries regarding personal information that SMARTAI holds about you, or if you would like to opt out of receiving any promotional communications, please write to:

SMARTAI Privacy Officer:

SmartAI Pty Ltd
15 San Domino Avenue
Point Cook VIC 3030
or email to