Privacy Policy

1. Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how Voconiq collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, register for an account, purchase a product or service, undertake one of our surveys or use one of our expression of interest forms, contact us via telephone, email and/or web form, interact with our social media, or provide your details to any of our staff or representatives in person.

Voconiq operates globally, in regions with different regulations and privacy principles. Voconiq takes a ‘highest common denominator’ approach. Voconiq complies with the highest levels of integrity and regulatory compliance.

The Voconiq website and our surveys are not intended for children below 15 years of age and we do not knowingly collect data relating to children below 15 years of age. We collect an additional level of parental consent for any data we collect in our surveys that is from those aged 15 to 18.

It is important that you read this privacy policy together with any other privacy policy, fair processing policy or consent form we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Data Controller

Reflexivity Pty Ltd is the controller and responsible for your personal data, collectively referred to as "Voconiq", "we", "us" or "our" in this privacy policy.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Protection Officer.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer, or via Contact | Voconiq.

Full name of legal entity: Reflexivity Pty Ltd t/a Voconiq

Data Protection Officer

Mr. Michael Wood
Email: DPO@voconiq.com

If you are an EEA Resident

Please contact our EU Representative at EUrep@voconiq.com. Alternatively, they can be reached by:

• Post: DPO Centre Europe, BERLIN: Friedrichstrabe 88, Excellent Business Centre, Berlin, 10117, Germany;
• Phone: +49 304 0817 3000;
• Online: dpocentre.com/contact-us/

If you are a UK Resident

Please contact our UK Representative at UKrep@voconiq.com. Alternatively, they can be reached by:

• Post: The DPO Centre Ltd, 50 Liverpool Street, London, EC2M 7PY, United Kingdom;
• Phone: +44 203 797 6340;
• Online: dpocentre.com/contact-us/

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated on July 2026.

Voconiq may choose to use third party services not mentioned in this version of the Privacy Policy, and update the policy to incorporate these changes at a later date.

Inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

If you are reading this policy online, this website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. Who this policy applies to

This privacy policy applies to all users of our services, including website visitors, customers and service users.

This policy also applies, where relevant or required by law, to staff, contractors, suppliers, and other persons.

3. The Data We Collect About You

The information we collect is fit for purpose. The information that we collect relevant, accurate, and not excessive or intrusive. We allow people to not identify themselves to us, where practical.

We view or copy an identity document or identity number, such as a driver’s licence or passport, only if we are required or authorised by law to ask for it, or if our purpose in asking is directly related to the purpose for which that identity document or number was originally assigned to the person.

We only collect sensitive personal information if:

• the person has consented, or
• our collection of that information is required by law, or
• the information is necessary to lessen or prevent a serious and imminent threat

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address, telephone numbers and social media handles.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website and for our surveys.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, social media handles, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Survey participant personal data

• Data Collection and Use: Participant data is collected to conduct surveys and gain insights. This data may include contact details, responses, and any other information you voluntarily provide when doing one of our surveys. At the start of any survey, a detailed consent form will be presented to you, to inform you and allow you to opt-in or opt-out of participating. Personal participant data is stored separately, on the Qualtrics platform in Australia, from the processing of your opinion responses.
• Data Retention:
  • Participant data will be retained for as long as reasonably necessary to fulfil the purposes we collected it for and held for 12 additional months following the end of our relationship with you — unless we are legally required to retain it for longer, or unless you ask us to delete it sooner. For example, if you’re participating in a Local Voices survey series over the course of 3 years, it will be retained for the duration of that survey series (3 years) plus 12 months (so that we can contact you again if the survey series recommences). This will be the case unless you ask us to delete your personal data sooner or we have a legal obligation to retain it.
  • De-identified survey and participant data — data that cannot be linked to you specifically, or to any specific individual — is retained in our aggregate data pool indefinitely. An example of this type of ‘pooled’ or ‘aggregate’ data will be retained in our systems ongoing.
  • Paper surveys that you hand or mail to us are only retained for as long as it takes to enter them into our Qualtrics system. After data is entered, paper surveys are securely destroyed. The digital data is retained as above.
• Consent and Withdrawal: By agreeing to participate in our surveys, you are consenting to the use of your data for the survey, for your de-identified responses to go into our pooled database, and for us to potentially contact you for future surveys. Participants can withdraw their consent for the use of their personal identifiable data at any time by contacting us through our website, phone line or email address, and can withdraw their consent to be contacted about future surveys or marketing using UNSUBSCRIBE link in the survey invite emails.
• Data Accuracy: We will contact Participants every 3 years to confirm their contact details. If a Participant does not respond, we will make one additional attempt to contact them. If there is still no response, their identifiable personal data will be removed from our database. Any de-identified opinion data that’s been aggregated with all the other opinion data we’ve gathered will remain in our pooled database, and will no longer be linked to any individual or the person who provided it.

4. How Is Your Personal Data Collected?

We use different methods to collect data from and about you.

The methods we use to collect personal information are lawful, fair and not intrusive.

Direct interactions

You may be referred to us by a third party acting on our behalf but you will always provide data directly to us. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

Automated technologies or interactions

As you interact with our website or surveys, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third party data collectors

Voconiq may use third party data collectors to assist in delivery of services, including but not limited to:

• ACNexo based in Chile
• Arvanitis Marketing P/L based in Zimbabwe
• CBG Patagonia (Gaston Berardi) based in Argentina
• DatosClaros based in Argentina
• DEVEX based in Republic of Guinea
• Dynata based in New Zealand
• Frezzatti & Fadino Gestão Empresarial e Terceiro Setor Ltda based in Brazil
• Kantar based in Australia
• Keen Independent Research based in the United States of America
• Marknadskraft i Norden AB based in Sweden
• Mongolian Institute for Innovative Policies based in Mongolia
• Perfopis Perfiles de Opinion CIA. LTDA. based in Ecuador
• Polis Pesquisa E Consultoria based in Brazil
• Spirituc based in Portugal (Spirituc Investigação Aplicada, Lda.)
• Taverner Research Group based in Australia
• Topline Research Solution based in Zambia
• Transfert Environnement et Société based in Canada

Identity and Contact Data from publicly available sources

Such as:

• LinkedIn based in The United States of America
• Facebook based in The United States of America
• Twitter based in the United States of America
• Instagram based in The United States of America
• Websites and Google entries
• Media Publications

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

In the following table, we provide a general description of how we may use your information, depending upon circumstance, and the legal basis under which we process that information.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal bases we are relying on to process your personal data where more than one basis has been set out in the table below.

Cookies

A cookie is a data file that a website transfers to your computer when you visit that website. This enables the website to track the pages you have visited. A cookie only contains information you supply. It cannot read data on your computer. There are many types of cookies that may be used for different purposes. For example, some cookies help a website to remember information about your visit, like your preferred language and other settings while others may identify which pages are being
visited or offer security features.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our websites will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers.

For more information about the cookies we use, refer to our Cookie Policy.

Using personal information for direct marketing

We may use personal information for direct marketing if:

• we have obtained express or implied consent
• we collected the information from the person, and
• the information was not obtained when delivering services under a contract with a State or Territory government agency, unless consent was obtained, and
• the information is not sensitive personal information, and
• direct marketing would be within your reasonable expectations, and
• we have identified who we are, and
• we have offered a simple opt out mechanism, and
• you have not opted out.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Using or disclosing unique identifiers

Voconiq only assigns a unique identifier, such as a client or customer, to a person if it is reasonably
necessary for us to function efficiently.

Voconiq does not utilise or reference a person’s government-issued unique identifier, such as a tax file number or passport number, unless that identifier is required by law.

Voconiq only uses or discloses a person’s government-issued unique identifier if:

• it is reasonably necessary to verify their identity, or
• to fulfil obligations to a government agency, or
• if required or authorised by law.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below as described in the Purposes for which we will use your personal data table.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and in line with this Privacy Policy.

Internal Third Parties

• Other companies in the Voconiq Group acting as joint controllers or processors and who are based in Australia and provide IT and system administration services and undertake leadership reporting.
• Service Providers acting as processors in Zimbabwe, Brazil and Australia who collect data on our behalf as part of surveys.

External Third Parties

• Service providers acting as processors based in Australia, Zimbabwe, Brazil, Chile, Argentina, Ecuador, Portugal, Denmark, Sweden, who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Argentina, Australia, Brazil, Canada, Chile, Denmark, Ecuador, Germany, New Zealand, Portugal, Sweden, The United Kingdom, The United States of America, and Zimbabwe who provide consultancy, banking, legal, insurance and accounting services.
• Professional advisers acting as processors based in the Philippines who provide graphic design services.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
• The Australian Tax Office regulators and other authorities acting as processors based in Australia who require reporting of processing activities in certain circumstances.

Use of IT platforms

We use secure third-party hosting/storage providers to securely store personal information. These providers are contractually restricted from accessing or using the data except to provide contracted services.

Specific IT third parties

General

• Airwallex based in Australia (with data centres globally) to pay accounts and suppliers;
• Amazon Web Services based in The United States of America (with servers located globally) for RStudio hosting and data storage.
• Cloudcannon based in New Zealand is a website content management system (CMS)
• Crowdin based in Estonia allows localisation of website content to the audience
• Google based in The United States of America (with data centres globally including in Chile, Ireland, Netherlands, Denmark, Finland, Belgium, Taiwan, Singapore) for Google Analytics information for websites, APIs and cloud storage;
• HiBob based in the United Kingdom (with offices globally) for managing human resource information;
• HubDoc based in The United States of America to store documents;
• HubSpot based in The United States of America and Germany to manage business-related documents;
• Mailchimp based in The United States of America to send emails and newsletters on our behalf;
• Microsoft 365 Business Services based in The United States of America for data storage, as well as for our general business correspondence and management;
• OpenAI based in The United States of America to assist in the summarisation of data and report writing;
• Qualtrics based in Australia to collect and manage survey data;
• RStudio based in The United States of America is an integrated development environment (IDE);
• SiteGround based in The United States of America (with data locations globally including The United Kingdom, Bulgaria, Cyprus and Spain) to store and serve our Voconiq Local Voices website;
• TollFreeForwarding based in The United States of America to manage our phone services and voicemail;
• Xero based in New Zealand to manage our accounting.

Rewards program

• Airtable based in The United States of America to manage our Local Voices Rewards Program data and to send emails;
• DocsAutomator based in Germany to automate statements for community group rewards;
• GiftPay by Unified Incentives Pty Ltd based in Australia to allow us to provide incentives and rewards to survey takers and rewards groups;
• GiftCardStore by Cuscal Ltd/Zenith Payments Pty Ltd based in Australia to allow us to provide incentives and rewards to survey takers and rewards groups;
• Mail Merge Toolkit by MAPILab Ltd. based in Lithuania, with offices in Canada, to send emails and newsletters;
• Try-Local by Karratha & Districts Chamber of Commerce & Industry based in Australia to allow us to provide incentives and rewards to local survey takers.

Security

We disclose data to third-party service providers who assist us with endpoint security monitoring, device management, IT diagnostic support, and cyber threat detection.

Business transfer

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7. International Transfers

From Australia

Voconiq only discloses personal information outside Australia, or to recipients in South
Australia and Western Australia, if:

• the recipient is covered by a law or binding scheme which has enforceable privacy
  obligations equivalent to the Australian Privacy Principles (in the Privacy Act 1988),
  or
• the person has expressly consented, after being informed that if they consent they
  may not be able to enforce a privacy complaint against the recipient, or
• the disclosure is required or authorised by another law, or
• the disclosure is necessary to lessen or prevent a serious and imminent threat and it
  is impracticable to seek the person’s consent and we are not delivering services
  under a contract with either the Tasmanian or Northern Territory government.

Voconiq takes steps to ensure that the recipient does not breach the Australian Privacy
Principles.

Outside of Australia

We, and many of our external third parties are based outside the UK and the EU so their processing of your personal data will involve a transfer of data outside the UK or EU, as appropriate. The majority of our data processing takes place in Australia, and is also compliant with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act), available at: www.oaic.gov.au/privacy/australian-privacy-principles.

Whenever we transfer your personal data out of the UK or EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is present:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we may use specific contracts approved for use in the UK or EU, as appropriate, which give personal data the same protection it has in the UK or EU, as appropriate; or
• We will obtain your explicit consent to transfer your data to the country of storage/processing (which is typically Australia, where we are based), and maintain our internal processes and practices to honour all requests to enact your rights and handle your data in accordance with UK/EU/GDPR/RGPD standards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EU.

8. Data Security

We have appropriate and robust security measures to protect personal information from loss, unauthorised access, misuse, interference, unauthorised modification, and unauthorised disclosure. Our security measures prevent unauthorised use or disclosure by our contracted service providers, and other parties to which we provide personal information.

In the very unlikely event of a suspected personal data breach, Voconiq has a rapid response protocol that includes notification of persons potentially affected, detailed investigation, and collaboration with relevant data security and law enforcement authorities

9. Data Retention

How long will you keep my personal data?

Voconiq will only retain your personal data for as long as reasonably necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We will not retain your personal data for more than 12 months following the end of our relationship with you unless we are legally required to keep customer information (including Contact, Identity, Financial and Transaction Data) for tax purposes in which case we will keep that information for 6 years following the end of our relationship.

In some circumstances, you can access or modify data, as part of your legal rights.

Voconiq may anonymise and consolidate your data with other data, so that it can no longer be associated with you, for research or statistical purposes. This consolidated and anonymous data may be stored and used indefinitely without further notice to you.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access
• Request correction
• Request erasure
• Object to processing
• Request restriction of processing
• Request transfer
• Withdraw consent

More detail is given about these rights in the Glossary.

In addition, a copy of the Australian Privacy Principles and rights for Australians (and those who have consented to have their data transferred to Australia) may be obtained from the website of The Office of the Australian Information Commissioner at oaic.gov.au.

Data request

To access your data or exercise any of your rights, you can contact Voconiq’s Data Protection Officer or through any normal communication channel. Your request does not need to be in writing.

Voconiq will acknowledge your request and continue to communicate with you with regard to any additional information needed, decisions made, and timelines.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Where you are acting on behalf of someone else, Voconiq will need to confirm your authority to act before proceeding.

If a request is considered to break the law, is clearly unfounded, repetitive or excessive, Voconiq may not comply with the request.

No fee usually required

For most data access requests, we will not charge any fee for you to access your personal data, or exercise any of your rights.

However, requests that require accessing large quantities of data, or requiring significant technical work, may attract a management fee to cover the costs.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. How to make a complaint about a breach of your privacy rights

You have the right to make a complaint at any time to the regulator responsible for data protection issues in your country. We would, however, appreciate the chance to address with your concerns before you approach the regulator so please contact us in the first instance.

Complaints should be directed to the Data Protection Officer.

All complaints will be recorded and investigated by Voconiq. We may request additional information from you and consult with other relevant parties. You will be informed of the progress and outcome of investigations.

In the process of investigation, Voconiq may choose to not disclose certain information to you, as advised by regulatory authorities and to protect the information of other individuals.

Complaints to regulatory authorities

You may make a privacy complaint to the national authority responsible for managing data protection and privacy.

In Australia, please contact the Office of the Australian Information Commissioner (www.oaic.gov.au).

In the UK, you can contact the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk).

For individuals in the European Economic Area (EEA), you may submit a complaint to your national authority Our Members | European Data Protection Board

12. Glossary

Types of information

Personal information

Personal information is information that can be used to identify an individual. This includes name, address and birthday.

Sensitive personal information

Sensitive personal information means personal information about a person’s:

• health or disability
• current or past health services received, or wishes about future health services
  such as organ donation
• racial or ethnic origin
• religious beliefs or affiliations
• philosophical beliefs
• political opinions, membership of a political association
• membership of a professional or trade association, or trade union
• sexual orientation or practices
• criminal record
• genetic information
• biometric information for verification or identification, or biometric templates.

Lawful Basis

Voconiq identifies the lawful basis for the data processing that it undertakes. The Lawful Basis is the legal reason that we collect, store and process the different kinds of data. These are 6 different Lawful Bases that can be applied - Consent, Contract, Legal obligation, Vital interests (protecting someone's life), Public tasks (in the public interest), Legitimate interest.

Consent is a two-way communication. It asks an individual for their permission to use or disclose their personal information in a certain way, and the individual can respond with either a 'yes' or a 'no'.

There are different kinds of consent. Express consent is an active expression of consent verbally, in writing, or through an online form. Implied consent arises where consent may reasonably be inferred in the circumstances from the conduct of the individual.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties

• Other companies in the Voconiq Group acting as joint controllers or processors and who are based in Australia and provide IT and system administration services and undertake leadership reporting.
• Service Providers acting as processors in Zimbabwe, Brazil and Australia who collect data on our behalf as part of surveys.

External Third Parties

• Service providers acting as processors based in Australia, Zimbabwe, Brazil, Chile, Argentina, Ecuador, Portugal, Denmark, Sweden, who provide IT and system administration services.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Australia, Zimbabwe, Brazil, Chile, Argentina, Ecuador, Portugal, Denmark, Sweden, The United States of America, Canada and New Zealand who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
• The Australian Tax Office regulators and other authorities acting as processors based in Australia who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

13. Change Log

This section documents the changes made to our Privacy Policy.

July 2026

• Changes to the policy are as follows:
  • 11. Change log
    • Rearranged in reverse chronological order
  • 12. Glossary
    • Updated and additional definitions
  • Significant rewrite of content to:
    • Incorporate Voconiq’s best practice protocols
    • Specify our approach to automated decision making
    • Update third party and IT platform declarations to reflect current practices
    • Specifically highlight our complaint procedure and data requests procedure

30 Oct 2025: The previous Privacy Policy dated 03 Oct 2024 was replaced with an updated policy dated 30 Oct 2025.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
  • Section 5. Disclosures of your personal data
    • Modified list of Specific third parties personal data may be shared with, adding the following entries:
      • Airtable based in The United States of America to manage our Local Voices Rewards Program data and to send emails;
      • DocsAutomator based in Germany to automate statements for community group rewards.

03 Oct 2024: The previous Privacy Policy dated 21 Aug 2024 was replaced with an updated policy dated 03 Oct 2024.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
    • Added Privacy Officer information.

21 Aug 2024: The previous Privacy Policy dated 06 Mar 2024 was replaced with an updated policy dated 21 Aug 2024.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
  • Added a new Section 2 entitled "Survey participant personal data" and its content. The content added allows Voconiq’s survey participants to easily find a summary of privacy information related to their participation in our surveys. It also directs website visitors, customers and other service users to the rest of the document. The entire privacy policy is relevant to all service users, but this change tries to make that clearer for survey participants.
  • Other sections renumbered to account for new section 2, and index updated.

06 Mar 2024: The previous Privacy Policy dated 13 Dec 2023 was replaced with an updated policy dated 06 Mar 2024.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
    • Added the contact details of our UK Representative
    • Rearranged some information inside this section, but did not change any of it.

13 Dec 2023: The previous Privacy Policy dated 04 May 2023 was replaced with an updated policy dated 13 Dec 2023.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
    • Added the contact details of our EU Representative

04 May 2023: The previous Privacy Policy dated 16 May 2022 was replaced with an updated policy dated 04 May 2023.

• Changes to the policy are as follows:
  • Section 1. Important information and who we are
    • Modified date of last update.
  • Section 3. How is your personal data collected?
    • Modified list of Identity and Contact Data from data brokers or aggregators.
  • Section 5. Disclosures of your personal data
    • Modified list of Specific third parties personal data may be shared with.