Foreword:

Greetings from Prodigi System, a creation of Magma Management PTY LTD.

Protecting your privacy is not just a policy for us; it's a commitment. At Prodigi System, we place the utmost importance on the confidentiality and security of the information shared with us by our valued users. This document serves as our promise to you, detailing how we collect, use, and safeguard your personal information across our digital services.

Understanding this Policy is crucial to ensure you are fully informed about your rights and our obligations. By utilizing our services, you consent to the processing of your information as outlined in this document.

Scope and Application:

This Privacy Policy is effective across all digital platforms and services operated by Prodigi System, encompassing our main website prodigisystem.com and any related subdomains, tools, and services we provide. It governs the relationship between you (the user) and us (Prodigi System) concerning your data on our platforms.

Contact Information of Prodigi System:

• Address: 101/2-8 Gordon St, Brighton Le Sands, NSW, 2216, Australia

• Email: [email protected]

1. Definitions and Interpretation

In the context of this Policy, the terms listed below shall be understood as follows:

• "Account" encompasses the collection of personal information, Payment Information, and credentials utilized by Users for accessing Material and/or various communication Systems on the Web Site.

• "Content" refers to any form of textual, graphical, auditory, video, software, data compilations, and other types of information that can be stored electronically and is accessible or forms a part of this Web Site.

• "Cookie" denotes a small text file that is placed on your computer by prodigisystem.com upon visiting specific sections of our Web Sites. This facilitates the recognition of repeat visitors and enables the analysis of their browsing patterns within the Web Site. Cookies may also be employed to retain your data where e-commerce functionalities are offered. Detailed information about this is provided in Clause 10 of this Policy.

• "Data" collectively refers to all information submitted to the Web Site by you. This category includes, but is not restricted to, Account specifics and data provided through the use of any Services or Systems.

• "prodigisystem.com" signifies prodigisystem.com and its parent entity, Magma Management PTY LTD.

• "Service" collectively describes any online facilities, tools, services, or information that prodigisystem.com makes accessible via the Web Site at present or in the future.

• "System" pertains to any online communication infrastructure made available by prodigisystem.com through the Web Site now or in the future. This includes, but is not limited to, web-based email, message boards, live chat facilities, and email links.

• "User" / "Users" are defined as any third party that accesses the Web Site and is not in the employ of prodigisystem.com or acting within their professional capacity.

• "Web Site" is the term used to describe the website currently being used by you, including any sub-domains of this site and all sites owned by prodigisystem.com, unless they are expressly excluded by their specific terms and conditions.

2. Data Collected

Prodigi System may collect, but is not limited to, the following types of Data:

2.1. Name

2.2. Date of birth

2.3. Gender

2.4. Job title

2.5. Profession

2.6. Contact information, including email addresses and telephone numbers

2.7. Demographic information, such as postcode, preferences, and interests

2.8. Financial information, including credit/debit card numbers

2.9. IP address (automatically collected)

2.10. Web browser type and version (automatically collected)

2.11. Operating system (automatically collected)

2.12. A list of URLs starting with a referring site, your activities on our Web Site, and the site you exit to (automatically collected)

2.13. Cookie information (referenced in Clause 10 and Schedule 1).

3. Our Use of Data

3.1. Prodigi System retains Personal Data as long as necessary to provide the Services and Systems accessible via the Web Site. Data submitted through any communications System may be kept for an extended period, up to six years.

3.2. Disclosure of Data to third parties occurs only as required by law or as outlined in Clause 4, not excluding affiliates and/or entities within our corporate group.

3.3. The security of personal Data aligns with the Data Protection Act 1998, with further security measures detailed in Clause 9.

3.4. Data collection serves multiple purposes, including:

3.4.1. Internal record keeping

3.4.2. Enhancement of products/services

3.4.3. Distribution of marketing and promotional materials via email

3.4.4. Market research communications for Web Site customization and updates

3.5. Users consent to receive ongoing communications, encompassing product updates, informational content, and marketing materials, under the premise of legitimate interest in company growth. Opt-out options are available at any time.

3.6. Data utilization extends to content delivery and advertisement relevancy, leveraging lawful grounds of legitimate interests for business expansion and user consent.

3.7. Sensitive Data, encompassing race, religious beliefs, sexual orientation, political opinions, health information, and genetic/biometric data, is not collected. Information regarding criminal convictions and offenses is also not gathered.

Rights and Data Management:

3a. Users may request access to their data held by Prodigi System via our support desk ([email protected]), with responses provided within 48 business hours.

3b. The right to be forgotten enables users to request the deletion of their data, with such requests actioned within 48 business hours.

3c. Upon transfer to third-party services, Prodigi System is no longer accountable for the data, underscoring the importance of third-party privacy policies.

3d. Site access and data submission imply consent and the assertion that the user is over 18 years of age.

3e. Data processing without explicit knowledge or consent may occur as permitted by law.

3f. Data collection methodologies include direct submissions and automatic methods, such as cookies, with potential data receipt from third parties, including analytics and advertising networks outside the EU and publicly available sources within the EU.

Additional Data Information

Marketing Communications

Prodigi System processes personal data for marketing communications based on either explicit consent from you or our legitimate interests, primarily to grow our business.

In accordance with the Privacy and Electronic Communications Regulations (PECR), we are entitled to send you marketing communications if:

(i) you have made a purchase or requested information about our goods or services, or

(ii) you have explicitly agreed to receive marketing communications, and have not opted out since.

For limited companies, marketing emails may be sent without explicit consent, though the option to opt out is always available.

Before sharing your personal data with third parties for their marketing purposes, we will obtain your express consent. You may withdraw from receiving marketing messages at any time by requesting the deletion of your information, clicking the opt-out links in any marketing message sent to you, or by submitting a support request at [email protected].

Opting out of marketing communications does not apply to personal data provided as a result of other transactions, such as purchases or warranty registrations.

Disclosures of Your Personal Data

Your personal data may be shared with the following entities:

• IT and system administration service providers.

• Professional advisers, including lawyers, bankers, auditors, and insurers.

• Government bodies for reporting processing activities.

• Third parties involved in a business transition such as a sale, transfer, or merger.

We ensure all third parties adhere to strict data protection and confidentiality principles. Your data is only processed for specified purposes and in line with our instructions.

International Transfers

Under the General Data Protection Regulations (GDPR), we take precautions to protect your data when transferring it outside the European Economic Area (EEA):

• Transfers to countries deemed by the European Commission to provide adequate data protection.

• Use of EU-US Privacy Shield-certified US-based providers.

• Engaging service providers outside the EEA under European Commission-approved contracts, codes of conduct, or certification mechanisms that ensure GDPR-equivalent protection.

Should none of these safeguards be applicable, we may seek your explicit consent for the transfer, with the right to withdraw consent at any time.

Data Security

Prodigi System has implemented robust security measures to protect your data against accidental loss, misuse, alteration, unauthorized disclosure, or access. Access to your data is strictly limited to personnel and partners with a legitimate business need, all of whom are obligated to keep your data confidential and follow our direct instructions regarding data processing.

In the event of a suspected data breach, we have established protocols to promptly address and mitigate the situation, including notification to you and relevant regulatory bodies as legally required.

4. Third-Party Websites and Services

Prodigi System engages with external parties to manage and execute various services, including but not limited to payment processing, delivery of goods, search engine operations, and marketing strategies. These third-party service providers may gain access to personal data shared by Users on our Web Site, strictly for the purpose of performing tasks on behalf of Prodigi System. The utilization of any data by these third parties is confined to the necessity of service provision as directed by Prodigi System and is not permitted for any other use. Moreover, third-party data handling is mandated to comply with this Policy's guidelines and the Data Protection Act 1998, ensuring data privacy and security.

Third-Party Links

Our Web Site may feature links to external sites, including third-party websites, plug-ins, and applications, for your convenience and information. Interacting with these links may allow third-party websites to collect or share your data. It is important to note that Prodigi System does not exercise control over the privacy practices of these external sites. Therefore, we bear no responsibility for the content or privacy policies of such sites. We strongly advise you to review the privacy statements of any third-party websites you visit through our site to understand their data handling practices.

5. Changes of Business Ownership and Control

5.1. Prodigi System, under the management of Magma Management PTY LTD, acknowledges that business dynamics may lead to the expansion or downsizing of our operations. Such changes could encompass the sale of specific divisions or the transfer of control of these divisions to other entities. In scenarios where user Data is relevant to the division being transferred, this Data will be passed along with the division. The new owner or entity assuming control will have the authorization to utilize this Data under the conditions outlined in this Privacy Policy, strictly for the original purposes for which it was collected.

5.2. Should there be a transfer of Data in the manner described above, affected Users will not be preemptively contacted or informed about these changes. It is advised that Users regularly review this Privacy Policy to stay informed about any potential changes that could affect their personal Data.

6. Controlling Access to Your Data

6.1. Prodigi System is committed to ensuring that Users have control over their personal Data. When it becomes necessary to submit Data to our Web Site, Users will be provided with options to manage the use of their Data effectively. These options include, but are not limited to:

6.1.1. Direct Marketing: This ensures that Users can opt-out of receiving marketing communications from Prodigi System.

6.1.2. Data Sharing with Third Parties: This measure is designed to protect Users' privacy and limit the use of their Data to services offered directly by Prodigi System.

7. Your Right to Withhold Information

7.1 Prodigi System offers the flexibility for Users to navigate certain sections of our Web Site without the necessity of disclosing any Data. Nevertheless, to fully engage with all the Services and Systems provided by the Web Site, submission of Account information or other relevant Data may become essential.

7.2 Users retain the option to limit the use of Cookies by their internet browsers. Detailed guidance on managing these settings can be found in Clause 10.4 of this Policy.

8. Accessing Your Own Data

8.1 At Prodigi System, we empower our Users with the ability to access their Accounts at any given time for the purpose of viewing or modifying their Data. Recognizing the dynamic nature of personal circumstances, we facilitate Users to update their Data as needed. This includes the capability to alter preferences related to marketing communications at any juncture.

8.2 Users are entitled to request a copy of their personal Data held by us. Such requests may be subject to an administrative fee in accordance with the prevailing regulations, ensuring the process aligns with legal and operational standards.

9. Security

9.1 Data security is of great importance to Prodigi System and to protect your Data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure Data collected online.

10. Cookies

10.1 Prodigi System may set and access Cookies on your computer.

10.2 A Cookie is a small file that resides on your computer's hard drive and often contains an anonymous unique identifier and is accessible only by the website that placed it there, not any other sites.

10.3 You may delete Cookies, however, you may lose any information that enables you to access the Web Site more quickly.

10.4 You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however, this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Web Site. See everything-you-need-to-know-about-cookies-in-one-article for additional information.

11. Changes to this Policy

Prodigi System reserves the right to modify this Privacy Policy as necessary over time or as dictated by legal requirements. Any amendments will be promptly published on our Web Site. By accessing and using the Web Site after such updates, you acknowledge and accept the revised terms of this Policy.

12. Assigned Data Protection Representative

Our designated representative for data protection matters is:

• Name: David Garcia

• Address: 101/2-8 Gordon St, Brighton Le Sands, NSW, 2216, Australia

• Email: [email protected]

Should you have any inquiries or concerns regarding your data, please reach out to David through our support desk at http://support.prodigisystem.com. We are committed to addressing your questions and providing the necessary information upon request.

Contact Us

For any questions or clarifications about this Privacy Policy, please connect with us through our dedicated support channel:

• Email: [email protected]

• Support Desk: http://support.prodigisystem.com

Our team is ready to assist with any inquiries or support needs related to our Privacy Policy or the handling of your personal information.

Last Updated: March 30, 2024.