Privacy Policy

Wholii Pty Ltd ("we", "us", "our") is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, store and disclose personal information when you interact with us — including through our website at wholii.com.au, our platform, and our registration or enquiry forms.

1. ABOUT THIS POLICY

This policy applies to all personal information we collect and handle, whether from visitors to our website, registered users of the Wholii platform, or individuals who contact us directly.

By using our website or platform, you agree to the collection and use of information as described in this policy.

2. WHAT INFORMATION WE COLLECT

From website visitors and marketing:

• Name, email address and phone number (when you enter a giveaway, register for an event, or submit an enquiry)
• Organisation or employer name (when provided voluntarily)
• Website usage data (through cookies and analytics tools such as Google Analytics)
• Information submitted through advertising platforms (Facebook/Meta, LinkedIn)

From platform users (registered accounts):

• Name, email address, job title and organisation
• Login credentials (email and encrypted password)
• Account activity, usage logs and feature interactions
• Any data you upload, create or manage within the Wholii platform
• Billing and payment information (processed securely via our payment provider)

We only collect sensitive information (including health or disability-related information) where you have provided explicit consent or where we are required or authorised to do so by law.

3. HOW WE USE YOUR INFORMATION

We use your personal information to:

• Create and manage your Wholii platform account
• Provide, maintain and improve the Wholii platform and its features
• Process giveaway entries or event registrations
• Send you information about the Wholii platform, updates and upcoming events
• Respond to your enquiries and provide customer support
• Process billing and payments
• Monitor platform security and prevent fraud
• Comply with our legal obligations
• Send relevant marketing communications (you can opt out at any time)

4. SENSITIVE AND HEALTH-RELATED INFORMATION

If your use of the Wholii platform involves the handling of sensitive information (including health information or disability-related data, such as information relevant to NDIS participants or services), we take additional care to:

• Only collect and use sensitive information for the specific purpose for which it was provided
• Apply stricter access controls and security measures to sensitive data
• Never use sensitive information for marketing purposes
• Handle sensitive information in accordance with the higher obligations under the Australian Privacy Principles

If you have questions about how sensitive information is handled within the platform, contact us at info@wholii.com.au.

5. MARKETING AND ADVERTISING

We use digital advertising platforms including Facebook/Meta and LinkedIn to promote Wholii. These platforms may use cookies and pixel tracking technology to deliver relevant advertisements.

You can opt out of personalised advertising through your Facebook, Instagram or LinkedIn account settings.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information.

We may share your information with:

• Our team members involved in delivering and supporting our services
• Third-party service providers who assist our operations (see Section 7 below), bound by confidentiality obligations
• Payment processors for billing purposes
• Regulatory bodies, where required by law

7. THIRD-PARTY SERVICE PROVIDERS (SUB-PROCESSORS)

To deliver our services, we use the following categories of third-party providers. These providers only access your data to the extent necessary to perform their services and are bound by confidentiality and data protection obligations.

Some of these providers may be located overseas, including in the United States and other countries. Where this occurs, we take reasonable steps to ensure they handle your information in a manner consistent with the Australian Privacy Principles.

8. OVERSEAS DATA TRANSFERS

Some of our third-party service providers (including cloud hosting, email, analytics and advertising platforms) are located or store data outside of Australia, including in the United States and European Union.

By using our website and platform, you consent to your personal information being transferred to and processed in these countries. We take reasonable steps to ensure that overseas recipients handle your information in a manner consistent with Australian privacy law.

9. DATA RETENTION

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Platform account data: retained for the duration of your account, and for up to 7 years after account closure (for legal and compliance purposes)
• Marketing and enquiry data: retained for up to 3 years from last contact, unless you request removal sooner
• Website analytics data: retained in accordance with the settings of the relevant analytics provider (typically 14–26 months)
• Billing records: retained for 7 years as required by Australian tax law

When your data is no longer required, we securely delete or de-identify it.

10. STORAGE AND SECURITY

We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. These steps include:

• Encrypted communications (HTTPS) on our website and platform
• Access controls limiting who can view personal information
• Secure, hosted infrastructure with industry-standard protections
• Regular review of our security practices

While we take these precautions, no data transmission or storage system is 100% secure. If you have concerns about the security of your information, contact us at info@wholii.com.au.

11. YOUR RIGHTS

You have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Delete your account and associated personal data (subject to legal retention obligations — see Section 9)
• Opt out of marketing communications at any time by clicking 'unsubscribe' or contacting us directly
• Make a complaint about how we handle your personal information

To exercise any of these rights, contact us at: info@wholii.com.au

We will respond to access and correction requests within 30 days. In some cases we may need to verify your identity before actioning a request.

12. ACCOUNT DELETION

If you wish to delete your Wholii account and associated data, you may:

• Submit a deletion request to info@wholii.com.au, or
• Use the account deletion option within your platform settings (if available)

We will action deletion requests within 30 days. Note that some data may be retained for the periods described in Section 9 where required by law.

13. COOKIES

Our website uses cookies to improve your experience and measure website traffic. Cookies we use include:

• Essential cookies: required for the website and platform to function
• Analytics cookies: used to measure traffic and usage (e.g. Google Analytics)
• Advertising cookies: used by third-party ad platforms (Facebook/Meta, LinkedIn) to deliver relevant ads

By using our website, you consent to the use of cookies. You can disable or manage cookies through your browser settings, though this may affect website functionality.

14. DATA BREACHES

We take data security seriously. In the event of a data breach that is likely to result in serious harm, we will:

• Notify affected individuals as soon as practicable
• Notify the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act 1988 (Cth)
• Take immediate steps to contain the breach and prevent further harm

If you believe your personal information has been compromised, please contact us immediately at info@wholii.com.au.

15. COMPLAINTS

If you believe we have breached the Australian Privacy Principles, you can:

1. Contact us directly at info@wholii.com.au — we will respond within 30 days
2. If you are not satisfied with our response, contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au

16. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be available on our website at wholii.com.au/privacy-policy. Where changes are material, we will notify registered users by email.

17. CONTACT US

Wholii Pty Ltd

Email: info@wholii.com.au

Website: wholii.com.au

Last updated: August 2026