PRIVACY POLICY

1. ABOUT THIS POLICY

1.1 Responsible Entity

This Privacy Policy is issued by JARACZEWSKI HOLDINGS PTY LTD (ABN: 33692484790), trading as "Polished Turds," with its registered office at Level 19, 10 Eagle Street, Brisbane, QLD, Australia. References to "we," "us," or "our" throughout this document refer to this entity.

1.2 Scope

This policy applies to all personal information collected through the Polished Turds platform, including the web application, progressive web app (PWA), Android application, and any associated services or APIs.

1.3 Our Mission

"To promote transparency and accountability in the Australian rental market by empowering tenants to share their genuine experiences, while maintaining the highest standards of privacy protection for all users."

2. DEFINITIONS

In this Privacy Policy, the following terms have the meanings set out below:

• Personal Information -- information that identifies or could reasonably identify an individual, as defined by the Privacy Act 1988 (Cth).
• Platform -- the Polished Turds web application, PWA, Android application, and associated services.
• User -- any individual who accesses or uses the Platform, whether registered or unregistered.
• Content -- any text, images, videos, ratings, reviews, or other material submitted by Users.
• APPs -- the Australian Privacy Principles contained in Schedule 1 of the Privacy Act 1988 (Cth).

3. INFORMATION WE COLLECT

3.1 Overview

We collect information necessary to operate the Platform and provide our services. The categories below describe the types of information collected, the specific data points, and the purposes for collection.

3.2 Account and Registration Data

3.3 User-Generated Content Data

3.4 Automatically Collected Data

4. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• Providing, maintaining, and improving the Platform and its features
• Processing, displaying, and moderating user-submitted reviews and content
• Authenticating users and maintaining account security
• Sending essential service notifications (account activity, moderation outcomes)
• Operating trending, latest, and search features using aggregated interaction data
• Detecting, preventing, and responding to fraud, abuse, spam, and policy violations
• Generating anonymised, aggregated analytics to improve the user experience
• Responding to support inquiries, legal requests, and dispute resolution
• Complying with applicable Australian laws and regulatory requirements

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

5. INFORMATION SHARING AND DISCLOSURE

5.1 Categories of Recipients

5.2 No Sale of Data

We do not sell, rent, lease, or trade your personal information to any third party for marketing, advertising, or any other commercial purpose. This commitment is unconditional and applies to all categories of personal information we collect.

5.3 Legal Disclosure

We may disclose personal information where required by law, court order, subpoena, or valid government request, or where necessary to protect the rights, property, or safety of our users, ourselves, or the public.

6. YOUR RIGHTS AND CHOICES

6.1 Available Rights

We will respond to all valid requests within 30 days. In complex cases, we may extend this period by an additional 30 days with written notice. We will not charge a fee for reasonable access requests.

7. DATA SECURITY

We implement and maintain technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction:

• All data transmitted via HTTPS/TLS encryption
• Passwords stored using industry-standard one-way hashing algorithms
• Row-level security (RLS) policies enforced at the database level
• Authentication tokens with secure session management
• Regular security reviews and dependency updates
• Access controls limiting data access to authorised personnel only
• Content moderation systems to detect and remove harmful material

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security but will promptly notify affected users in the event of a data breach as required by the Notifiable Data Breaches scheme under the Privacy Act 1988.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 Overview

The Platform uses limited cookies and local storage technologies essential to its operation. We do not use third-party advertising cookies or cross-site tracking.

8.2 Technologies Used

9. DATA RETENTION

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Specific retention periods are noted in Section 3.4 above for automatically collected data.

• Active accounts: Data retained for the lifetime of the account.
• Deleted accounts: Personal data removed within 30 days of deletion request. Backup copies may persist for up to 90 days.
• Public reviews: May be anonymised rather than deleted to maintain platform integrity and community trust. Anonymised content is no longer linked to any identifiable user.
• Legal holds: Data subject to legal proceedings or regulatory investigation will be retained until the matter is resolved.

10. CHILDREN'S PRIVACY

The Platform is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take immediate steps to delete that information. If you believe a child has provided us with personal information, please contact us at privacy-polished@proton.me.

11. INTERNATIONAL TRANSFERS

Our Platform is primarily designed for users in Australia. Our database infrastructure is hosted by Supabase, which may store data in data centres located outside Australia. Where personal information is transferred internationally, we ensure that appropriate safeguards are in place in accordance with APP 8, including contractual obligations requiring the overseas recipient to comply with the APPs.

12. AUSTRALIAN PRIVACY PRINCIPLES

We are committed to compliance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). This policy has been designed to address the requirements of each applicable APP, including:

• APP 1: Open and transparent management of personal information (this Policy).
• APP 3: Collection of solicited personal information only where reasonably necessary.
• APP 5: Notification of collection (Sections 3.1 -- 3.4).
• APP 6: Use and disclosure limited to primary purpose or related secondary purposes (Section 4).
• APP 8: Cross-border disclosure safeguards (Section 11).
• APP 11: Security of personal information (Section 7).
• APP 12: Access to personal information (Section 6).
• APP 13: Correction of personal information (Section 6).

If you have concerns about our compliance with the APPs, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or by phone at 1300 363 992.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• Post the updated policy on the Platform with a revised effective date
• Notify registered users via in-app notification for significant changes
• Provide at least 14 days notice before material changes take effect

Your continued use of the Platform after the effective date of any changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

14. CONTACT AND COMPLAINTS

If you have questions, concerns, or complaints about this Privacy Policy or our handling of your personal information, please contact us:

We aim to resolve all complaints internally within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.