Privacy Policy

Last updated 1 March 2025

1. We respect your privacy

(a)  Snowy Owl Networks Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.

(b)  We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR).

(c)  "Personal information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.

(d)  You may contact us or our Data Protection Officer via the 'Contact Us' link on our homepage or via email at contact@hootnotes.io. You may also send mail to Snowy Owl Networks Pty Ltd at the below address for further information about this Privacy Policy:

Snowy Owl Networks Pty Ltd
Ground Floor
470 St Kilda Road
Melbourne Vic 3004
Australia.

2. What personal information is collected

(a)  Snowy Owl Networks Pty Ltd will, from time to time, receive and store personal information you submit to our website, provided to us directly or given to us in other forms.

(b)  You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.

(c)  We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, communicate with our customer support, internet or electronic network activity information such as browsing history, search history, interactions with our website, geolocation data where applicable, and Professional or employment-related information, if provided in a business context.

(d)  Additionally, we may also collect any other information you provide while interacting with us.

(e)  Note that we do not sell personal information. Should our data practices change in the future to include the sale of personal information, we will update this policy and ensure compliance with applicable privacy act opt-out requirements.

3. How we collect your personal information

(a)  Snowy Owl Networks Pty Ltd collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

(b)  By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

4. How we use your personal information

(a)  Snowy Owl Networks Pty Ltd may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.

(b)  Snowy Owl Networks Pty Ltd will use personal information only for the purposes that you consent to. This may include to:

(i)  provide you with products and services during the usual course of our business activities;

(ii)  administer our business activities;

(iii)  manage, research and develop our products and services;

(iv)  provide you with information about our products and services;

(v)  communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail; and

(vi)  investigate any complaints.

If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.

(c)  We will not discriminate against you for exercising any of your privacy rights, including denying services, charging different prices, or providing a different quality of service.

(d)  We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.

(e)  If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

5. AI & Automated Processing

(a)  Snowy Owl Networks Pty Ltd may use AI-powered features to enhance user experience, including automated summaries, content recommendations, and interactive collaboration tools.

(b)  These AI-driven features may analyze user input to provide relevant suggestions but do not make binding decisions on behalf of users.

(c)  By using Hootnotes, you acknowledge that AI-generated content is automated and may not always be accurate, reliable, or free from bias. AI-generated outputs should not be relied upon as fact or as the sole basis for decision-making. You are responsible for verifying and modifying AI-generated content before use, and Hootnotes disclaims all liability for any reliance on AI-generated content.

(d)  AI-generated outputs may be stored as part of user data and processed in accordance with this Privacy Policy. Hootnotes may use anonymized AI interactions to improve our automated tools, but we do not use AI to profile users or make binding decisions. We do not use AI for profiling or automated decision-making that produces legal or significant effects on users, unless explicitly stated.

6. Shared Content & User Responsibility

(a)  Hootnotes allows users to share their content with others through collaboration features. If you grant access to your content, the recipient may have the ability to view, modify, or delete that content.

(b)  You are responsible for managing your sharing permissions and ensuring that only trusted individuals have access to your data.

(c)  Hootnotes does not guarantee content recovery if it is deleted by another user. If shared content is deleted, altered, or modified, Hootnotes is not responsible for restoring lost data.

(d)  If you suspect unauthorized access or deletion of content, you should revoke sharing permissions immediately and contact Hootnotes support.

7. Disclosure of your personal information

(a)  Snowy Owl Networks Pty Ltd may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.

(b)  If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.

8. General Data Protection Regulation (GDPR) for the European Union (EU)

(a)  Snowy Owl Networks Pty Ltd will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

(b)  We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.

(c)  We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.

(d)  We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.

(e)  You have the right to withdraw your consent at any time, where consent is the legal basis for processing your personal data. To withdraw your consent, please contact us as set out in clause 1(d) above. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

(f)  We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.

(g)  We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest, or if the function has a clear basis in law.

(h)  We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.

(i)  You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

9. Your rights under the GDPR

(a)  Age Requirement. If you are located in the European Economic Area (EEA), the United Kingdom, or any jurisdiction with child data protection laws, you must not provide us with your personal information if you are under 13 years old, or the minimum legal age required in your country, without the consent of a parent, legal guardian, or another authorized adult (such as a teacher).

(b)  Except as otherwise provided in the GDPR, you have the following rights:

•  to be informed how your personal information is being used;
•  access your personal information (we will provide you with a free copy of it);
•  to correct your personal information if it is inaccurate or incomplete;
•  to restrict processing of your personal information;
•  to retain and reuse your personal information for your own purposes;
•  to object to your personal information being used; and
•  to object against automated decision making and profiling.

(c)  You have the right to request the deletion of your personal data (also known as the “right to be forgotten”) under GDPR. We will process deletion requests within one month, unless an extension is required due to complexity or volume of requests, in which case we will inform you of the delay and the reasons for it. In some circumstances, we may be required to retain certain personal data even after a deletion request, including for:

•  Compliance with legal, regulatory, or tax obligations.
•  Security, fraud prevention, or dispute resolution.
•  Anonymized, non-identifiable data for research or analytics purposes.

(d)  We will process deletion requests within one month, unless an extension is required due to complexity or volume of requests, in which case we will inform you of the delay and the reasons for it.

(e)  Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.

(f)  We may ask you to verify your identity before acting on any of your requests.

10. Your Rights Under the California Consumer Privacy Act (CCPA)

If you are a California resident, you have specific rights regarding your personal information:

(a)  Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. This includes the categories of personal information we collect, the purposes for which we use it, and the categories of third parties with whom we share it.

(b)  Right to Request Deletion. You have the right to request that we delete any personal information we have collected from you, subject to certain exceptions.

(c)  Right to Opt-Out of Sale. We do not sell personal information. However, if we change our practices, we will update this policy and provide you with the right to opt-out.

(d)  Right to Non-Discrimination. Exercising your rights under the CCPA will not result in any discriminatory treatment, such as denial of service or charging different rates.

To exercise any of these rights, please contact us as set out in clause 1(d).

11. Hosting and International Data Transfers

(a)  Where We Store Your Data. Hootnotes may store and process personal information in Australia, the United States, and other jurisdictions where our servers, employees, or third-party service providers are located.

(b)  Cross-Border Data Transfers & Compliance. For users in the European Economic Area (EEA), United Kingdom (UK), and other regions with strict data protection laws, we ensure that cross-border transfers comply with applicable legal requirements.

(c)  Third-Party Data Processing & Safeguards. We may share personal data with third-party service providers, cloud storage providers, and analytics tools that help us operate Hootnotes.

(d)  User Acknowledgement of International Transfers. By using Hootnotes, you acknowledge that your data may be stored or processed in countries outside your place of residence, which may have different data protection laws. Where required by law, we will seek your explicit consent before transferring personal data internationally.

12. Security of your personal information

(a)  Commitment to Security. Snowy Owl Networks Pty Ltd is committed to protecting your personal information from unauthorized access, loss, misuse, disclosure, alteration, or destruction. We implement industry-standard security measures to safeguard your data both in transit and at rest.

(b)  Security Measures We Use. We take reasonable technical and organizational measures to protect your personal information, including:

•  Encryption: Data is encrypted both in transit (TLS) and at rest using secure encryption methods.
•  Access Controls: Role-based access restrictions and authentication mechanisms limit access to personal data.
•  Data Minimization: We only collect and retain the minimum personal information necessary for providing Hootnotes services.
•  Security Audits: We conduct routine security assessments to identify vulnerabilities.

(c)  User Responsibility for Account Security:

•  You are responsible for keeping your login credentials secure and not sharing them with others.
•  If you use Hootnotes' collaboration features to share content with others, you are responsible for managing access permissions and protecting shared data from unauthorized modifications.
•  Hootnotes is not responsible for data loss, unauthorized access, or modifications resulting from weak passwords, credential sharing, or misconfigured sharing permissions.

(d)  Data Breach Notification:

•  If we become aware of a data breach that compromises the confidentiality, integrity, or availability of your personal information, we will promptly notify affected individuals and relevant authorities within the timeframes required by law, including within 72 hours as required under GDPR, where applicable.
•  Notification may be provided via email, in-app alert, or website announcement, depending on the nature of the breach.
•  If applicable, we will also provide recommendations on how you can protect yourself from further harm following a breach.

(e)  Limitations of Security Measures. While we take reasonable steps to secure your information, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. If you believe your account has been compromised, please contact us immediately.

13. Access to your personal information

(a)  You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR. If you would like a copy of the information which we hold about you, believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, or wish to submit requests relating you tour CCPA rights, please contact us as set out in clause 1(d). We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law. We may also require additional information to verify your identity before fulfilling your request.

(b)  We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. If you request deletion of your personal data, we will comply unless retention is required by law, regulatory obligations, or legitimate business purposes (e.g., fraud prevention, tax compliance). Once the retention period expires, your personal data will be securely deleted or anonymized.

14. Account Retention & Inactivity Policy

(a)  Account Retention Periods. Hootnotes retains user accounts and associated data for as long as necessary to provide the Services or as required by law. However, we may delete accounts that remain inactive for a continuous period of 12 months.

(b)  Definition of Inactivity. An account is considered inactive if there has been no login activity, no content creation, and no paid subscription activity during the 12-month period.

(c)  Notification & Deletion Process. Before deletion, we will send a notification to your registered email at least 30 days in advance, allowing you to log in and prevent account removal. If you do not log in during the notice period, your account and associated data will be permanently deleted.

(d)  Exceptions & Data Retention. If required by law, certain data may be retained for compliance, security, or dispute resolution purposes. Non-identifiable data may be retained for analytics and service improvement.

15. Complaints about privacy

(a)  If you have any complaints about our privacy practices, please feel free to send in details of your complaints to contact@hootnotes.io. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

(b)  If you are an EU resident and believe your data protection rights under the GDPR have been infringed, you have the right to lodge a complaint with your local supervisory authority. For more information, please refer to the contact details of data protection authorities within the EU, which can be found here https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

16. Changes to Privacy Policy

(a)  Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

17. Website

(a)  When you visit our website. When you come to our website (hootnotes.io), we may collect certain information such as browser type, operating system and website visited immediately before coming to our site. This information is used in an aggregated manner to analyse how people use our site, so that we can improve our service.

(b)  Cookies. We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

(c)  Third party sites. Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Snowy Owl Networks Pty Ltd is not responsible for the privacy practises of other such websites. We encourage our users to be aware when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

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