Vottee Privacy Policy

Section 1 — Scope of this Policy

This Privacy Policy applies to personal information collected through the Platform, including where a person:

• creates an account;
• creates, manages or participates in a poll;
• completes a guest, verification or consent form;
• uploads content to a poll, including text or images;
• contacts us about the Platform; or
• otherwise interacts with the Platform.

In this policy, personal information has the meaning given in the Privacy Act 1988 (Cth), and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Section 2 — Information We Collect

We may collect the following categories of personal information.

Account registration

When a user creates an account, we collect:

• full name; and
• email address.

Guest and verification forms

Where a user completes a guest form or verification form in connection with a poll, we may collect:

• name; and
• email address.

Poll participation and poll administration

When a user creates, manages or participates in a poll, we may collect:

• account and participation details;
• information submitted in connection with a poll;
• poll administration records;
• audit and activity logs relating to use of the Platform; and
• information needed to verify participation or investigate reports.

Poll options and user-submitted content

Poll creators may enter poll option text and other content into the Platform. That content may, in some cases, include personal information, including the names of individuals and, in limited cases, minors.

Poll creators may also upload an image for use with a poll. Uploaded images may contain personal information, including an individual's likeness, name, school, team, club or other identifying details.

Poll creators must only enter or upload content where they are authorised to do so, and must not include personal information relating to a minor or any person unable to provide their own consent unless the required authority or consent has been obtained.

Parental or guardian consent records

Where consent is required for the inclusion of a minor's personal information, we may collect and retain:

• parent or guardian full name;
• parent or guardian email address;
• the date and time consent was provided, confirmed or withdrawn;
• associated audit log records; and
• records of the consent workflow, including confirmation and withdrawal events.

Subscription and billing information

Where a user subscribes to a paid plan, payment information is processed by our third-party payment providers. We receive subscription-related information such as:

• subscription status;
• plan type; and
• renewal or expiry details.

We do not store full payment card details on our own systems.

Technical and usage information

We may collect technical and usage information necessary to operate, secure and improve the Platform, such as:

• login and session information;
• device or browser information;
• IP address or approximate location information;
• error, security and diagnostic logs; and
• records of interactions with the Platform.

Section 3 — How We Use Personal Information

We may use personal information for the following purposes:

• to create and manage user accounts;
• to operate polls and enable users to create, share, administer and participate in polls;
• to verify the identity of users completing guest, verification or consent forms;
• to process and record parental or guardian consent where required;
• to maintain audit trails for security, compliance and dispute handling;
• to provide transactional and service-related communications;
• to manage subscriptions and payments through our payment providers;
• to respond to enquiries, complaints and requests;
• to investigate reported polls, misuse of the Platform, or suspected breaches of this policy;
• to protect the safety of users, including minors;
• to maintain, secure and improve the Platform; and
• to comply with legal and regulatory obligations.

We will not use personal information for a purpose that is unrelated to these purposes unless permitted or required by law, or unless consent has been obtained.

Section 4 — How Poll Information is Visible

Poll participation on Vottee is not public by default in the way described below.

Where a person participates in a poll:

• their information is collected for participation, verification, administration and related Platform purposes;
• poll results and voting information are generally visible only to the poll creator or authorised poll administrators; and
• a participant's personal information is not made visible to other voters by default unless the relevant poll setup or feature expressly provides otherwise.

Poll creators are responsible for configuring and using polls appropriately and for ensuring they only include or upload content they are authorised to use.

Section 5 — Minor Data and Consent Requirements

Where a poll creator wishes to include the name, image or other personal information of a person under the age of 16, or any person unable to provide their own consent, the poll creator must ensure the required consent or authority has been obtained.

Where our consent workflow is used, the following process applies:

1. the poll creator must identify or flag the relevant content at the time of poll creation;
2. a consent email may be sent to the relevant parent or guardian;
3. the parent or guardian may confirm consent by completing the consent process; and
4. the relevant content may remain available only once consent has been confirmed, where consent is required.

We retain records of the consent process for audit, compliance and safety purposes.

If a parent or guardian withdraws consent, we will take reasonable steps to remove or restrict the relevant content as soon as reasonably practicable.

A parent or guardian may withdraw consent by:

• using the withdrawal link provided in the relevant email, where available;
• contacting the poll owner; or
• contacting us at admin@snowyden.com.au.

If a poll includes personal information about a minor or another individual in a way that may breach this policy, it may be reported through the Platform or by contacting us. We may pause, restrict, review or remove the poll while the matter is assessed.

If we become aware that personal information about a person under 16 has been collected, used or disclosed without the required consent or authority, we will take reasonable steps to investigate and take appropriate action, which may include restricting access to, removing, or deleting the relevant information.

Section 6 — Image Uploads

Poll creators may upload images for use with a poll.

Images uploaded to the Platform may contain personal information. This may include a person's image, likeness, name, uniform, school, club, team or other identifying details.

By uploading an image, the poll creator represents that they:

• are authorised to upload and use the image in connection with the poll;
• have obtained any consent required from the individuals shown or from a parent or guardian, where applicable;
• will not upload unlawful, misleading, offensive or infringing content; and
• understand that we may remove, disable or restrict access to an image if we believe it may breach this policy, another person's rights, or applicable law.

We may store uploaded images and associated metadata for the purposes of operating the Platform, administering the poll, handling reports or complaints, maintaining audit records, and complying with legal obligations.

Section 7 — Third-Party Service Providers

We use third-party service providers to help operate the Platform. These may include providers that support hosting, infrastructure, authentication, email delivery and payment processing.

Current providers may include:

• Vercel, for frontend and backend hosting and deployment;
• Supabase, for authentication, database and related infrastructure services;
• Resend, for transactional email delivery, including consent emails and account notifications; and
• Stripe, for subscription and payment processing.

These providers may handle personal information on our behalf in connection with the services they provide to us. They may also be subject to their own privacy policies and contractual terms.

Section 8 — Data Storage and Cross-Border Disclosure

We store Platform data in Australia, including our database and core hosted application environment where configured in Australia.

However, some third-party providers may process or access limited personal information outside Australia in connection with the services they provide. For example:

• emails sent through Resend may be processed through infrastructure located in Japan; and
• payment-related processing by Stripe or related providers may involve overseas processing.

Where we disclose personal information to overseas service providers, we take reasonable steps to ensure that the information is handled in a manner consistent with applicable Australian privacy law, having regard to the nature of the service and the information involved.

By using the Platform, you acknowledge that some disclosures or processing may occur outside Australia where this is reasonably necessary for the operation of the Platform and related services.

Section 9 — Cookies and Similar Technologies

We may use cookies, session technologies and similar technical tools where reasonably necessary to operate, secure and improve the Platform.

These technologies may be used for purposes such as:

• maintaining user login sessions;
• supporting authentication and account security;
• remembering functional preferences; and
• monitoring performance, reliability and basic usage of the Platform.

We will update this Privacy Policy if we introduce additional tracking, analytics or advertising technologies that materially change how personal information is collected or handled.

Users can usually manage certain browser-based cookies through their browser settings. Disabling some technical features may affect how parts of the Platform operate.

Section 10 — Subscriptions and Payments

Vottee offers optional subscription plans. Subscription management and payment processing are handled through third-party providers, including Adapty and Stripe.

When a user subscribes:

• payment information is collected and processed by the relevant payment provider;
• we receive limited subscription and billing status information; and
• we do not store full payment card details on our own systems.

For billing enquiries, contact admin@snowyden.com.au.

Section 11 — Data Security

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification and disclosure.

These steps may include:

• encrypted data transmission using HTTPS;
• access controls limiting internal access to personal information;
• secure authentication and credential management;
• logging and monitoring of relevant system events; and
• audit records relating to consent, account and poll activity.

No method of transmission over the internet, or method of electronic storage, is completely secure. Because of this, we cannot guarantee absolute security.

Section 12 — Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, and as otherwise required or permitted by law.

Unless a longer retention period is required for legal, security, dispute, audit or compliance reasons:

• account data is retained for the duration of the account and for up to 14 days after account closure;
• guest and verification form data is retained for up to 14 days after the relevant poll closes or the verification purpose is completed;
• poll update opt-in information is retained until the earlier of consent withdrawal or 14 days after the relevant poll closes;
• parental or guardian consent records and related audit logs are retained for the duration of the relevant poll and for up to 14 days after the poll closes, unless a longer period is reasonably required for compliance, safety, complaint handling or dispute resolution;
• uploaded images and related poll content are retained for the duration of the relevant poll and for up to 14 days after poll closure, unless earlier removed or a longer retention period is required for review, reporting, legal or safety reasons.

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it, unless we are required or permitted by law to retain it.

Section 13 — Access and Correction

A person may request access to the personal information we hold about them, or request correction of inaccurate, incomplete or out-of-date information, by contacting us at admin@snowyden.com.au.

We may need to verify the identity of the person making the request before providing access or making a correction.

We will respond within a reasonable period and in accordance with applicable privacy law. In some cases, we may refuse access or decline a correction request where permitted by law. If that occurs, we will provide reasons where required.

Section 14 — Complaints

If you believe we have handled personal information in a way that does not comply with the Privacy Act 1988 (Cth) or the APPs, you may lodge a complaint by contacting us at admin@snowyden.com.au.

When handling a complaint, we may:

• ask for further information to verify identity or understand the complaint;
• review relevant records, audit logs and communications;
• investigate the issue internally; and
• provide a written response within a reasonable time.

We aim to respond to privacy complaints within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) through oaic.gov.au or by calling 1300 363 992.

Section 15 — Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes to the Platform, our practices, our service providers, or our legal obligations.

When we make a material change, we will update the "Last updated" date at the top of this policy. Continued use of the Platform after an updated policy takes effect is taken as acceptance of the updated policy, to the extent permitted by law.

Section 16 — Contact Us

For privacy-related questions, requests or concerns, please contact:

Snowyden Software (JTC Software Pty Ltd)
Email: admin@snowyden.com.au