Privacy & Data Privacy Policy
Effective Date: 04/06/2025
Introduction
Prosper EX Pty Ltd is a culture, employee engagement and performance management tech platform.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Prosper EX’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
Data Protection Officer
Prosper EX Pty Ltd is headquartered at 2/23 Foster Street, Surrey Hills, NSW 2010 in Australia. Prosper EX Pty Ltd has appointed an internal data protection officer for you to contact if you have any questions or concerns about Prosper EX’s personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Prosper EX’s data protection officer. Prosper EX’s data protection officer’s name and contact information are as follows:
Will Moorhouse
Prosper EX Pty Ltd
2/23 Foster Street
Surry Hills
NSW 2010
Australia
[email protected]
+61 417 453 763
Use of the Prosper EX Pty Ltd Website
As is true of most other websites, Prosper EX’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Prosper EX’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Prosper EX Pty Ltd has a legitimate interest in understanding how members, customers and potential customers use its website. This assists Prosper EX with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet member and customer needs.
1. Information We Collect
We collect personal information in the following ways:
Information you provide directly to us, including your name, email address, company name, phone number, job title and location.
Information our customers provide about their users, which may include names, contact details, job-related data, and performance information.
Information from third-party integrations (e.g., Google APIs) when explicitly authorized by you.
Google User Data
When you connect your Google account to our services, we may collect or access the following data, with your consent:
Your name and email address
Calendar events, if integration is enabled
Drive files metadata, if integration is enabled
We do not collect or access content of emails or documents unless explicitly authorized and necessary to provide a specific feature.
2. How We Use Your Information
We use the information we collect, including Google user data, only to provide and improve user-facing features. This includes:
Delivering and maintaining our services
Communicating with you regarding updates or service-related information
Sending notifications, reminders, or scheduled content (e.g., performance reviews, learning modules)
Providing customer support
Analytics to improve product functionality (only in aggregate and non-identifiable form)
We do not use your Google user data for:
Targeted advertising
Retargeting or personalized ads
Creating user profiles for marketing
Training AI models
Selling to third parties or data brokers
Credit, lending, or financial scoring purposes
3. Sharing and Disclosure
We do not sell Google user data or other personal data.
We only share personal information in the following limited circumstances:
With trusted subprocessors who help us deliver our services (e.g., cloud hosting, analytics). All subprocessors are contractually obligated to maintain confidentiality and comply with data protection laws.
When required by law, subpoena, or legal process.
In the event of a merger, acquisition, or sale of assets, with appropriate safeguards in place.
We do not transfer or disclose personal information for any prohibited purposes, including advertising, reselling, or profiling.
4. Data Protection and Security
We implement a variety of industry-standard security measures to protect your personal and Google user data:
Encryption in transit and at rest using modern cryptographic protocols
Access controls and authentication to ensure only authorized personnel can access data
Regular audits and penetration testing
Security policies and training for employees
We are committed to ensuring the confidentiality and integrity of your information.
5. Data Retention and Deletion
We retain personal information only for as long as needed to fulfill the purposes described in this policy or as required by law.
User data is retained for the duration of the customer agreement and deleted upon termination, unless otherwise legally required.
You may request deletion of your personal information at any time by contacting [insert email/contact method]. We will respond within a reasonable timeframe.
When data is no longer needed, it is securely deleted or anonymized.
6. Your Choices and Rights
You can review, update, or delete your data by accessing your account settings or contacting support.
You can revoke access to your Google account at any time via your Google account settings.
You have the right to lodge a complaint with a data protection authority if you believe your rights have been violated.
7. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised “Effective Date.” We recommend reviewing this policy periodically.
If the policy is updated in response to Google’s requirements, we will notify Google’s OAuth Verification team as required.
Transferring personal data to Australia.
Prosper EX has its headquarters in Australia. Information we collect about you will be processed in Australia. By using Prosper EX’s services, you acknowledge that your personal information will be processed in Australia. Australia has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Pursuant to Article 46 of the GDPR, Prosper EX is providing for appropriate safeguards by entering binding, standard data protection clauses, enforceable by data subjects in the EEA and the UK. These clauses have been enhanced based on the guidance of the European Data Protection Board and will be updated when the new draft model clauses are approved.
Depending on the circumstance, Prosper EX also collects and transfers to Australia personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Prosper EX in a manner that does not outweigh your rights and freedoms. Prosper EX endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Prosper EX and the practices described in this Privacy Statement. Prosper EX also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate. Since it was founded, Prosper EX has received zero government requests for information.
For more information or if you have any questions, please contact us at [email protected]
Questions, concerns or complaints
If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
Prosper EX Pty Ltd
2/23 Foster Street
Surry Hills
NSW 2010
Australia
[email protected] – CEO
Australia: +61 1300 529 909
UK: +44 161 768 5233
United States: +1888 901 6033
