Saropa strives to provide the highest standard of security and privacy to all users. To see the Saropa GDPR policy as it applies to EU customers, please click here: /GDPR

Saropa understands that privacy is an important issue for its customers and generally for individuals.

Saropa believes that due respect for individual privacy not only protects an important right of the individual but is a powerful tool in the creation of healthy relationships with its customers and suppliers and with others with whom it deals in the business community.

As the provider of a repository service for our customers’ personal information we accept that privacy and security is of special importance for our customers.

There are two categories of personal information that Saropa collects:

1. general information to enable us to manage our relationships with customers, suppliers and other businesses; and
2. the information that our customers up-load to our on-line repository service.

Saropa is committed to protecting your privacy and handles your personal information in accordance with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cwth) (Privacy Act), as well as other applicable privacy laws and our obligations of confidentiality.

It is our belief that by doing so we will enhance the level of trust in our relationships with customers, suppliers and other individuals.

ACCOUNTABILITY

It is the responsibility of all Saropa employees to comply with privacy laws and this policy. Saropa requires that its employees familiarize themselves with and accept and adopt this policy. Saropa employees must do everything within their power to cause Saropa to meet its privacy obligations and to achieve the benefits referred to above. Saropa will regard non-compliance with this policy most seriously. In the case of employees, violation of this policy will lead to disciplinary procedures being imposed, including the possibility of dismissal.

Saropa will, wherever practicable, require its independent contractors to be contractually bound to comply with this policy. Contractors who display a willingness to do so and a culture of respect for privacy and compliance with privacy laws will be preferred.

SOME IMPORTANT TERMINOLOGY EXPLAINED

Personal Information - this means information or an opinion, including information or opinion forming part of a data base concerning an individual. It does not matter whether the information or opinion is true or justifiable or not. It does not matter how the information is recorded, but it must be recorded. Finally, the information must be such as to identify the individual or to enable the identity of the individual to be reasonably ascertained.

Personal information relates to individuals not companies. However, personal information can include information within a business context.

Personal information also includes sensitive information (see below).

Privacy Act means the Privacy Act 1988, as amended by the Privacy Amendment (Private Sector) Act 2000 and includes the National Privacy Principles, or “NPPs”.

Sensitive Information is personal information concerning an individual’s:

• racial or ethnic origin; or
• political opinion; or
• membership of a political association; or
• religious beliefs or affiliations; or
• philosophical beliefs; or
• membership of a professional or trade association; or
• membership of a trade union; or
• sexual preferences or practices; or
• criminal record; or
• information; or an opinion about the health or disability of an individual or an individual’s wishes about the future provision of health services.

CONSENT

Consent is not always required under the Privacy Act, but where it is required we will provide sufficient information to enable the individual to make an informed decision about whether or not to give consent. We will explain all relevant matters fully and adequately and we will not put undue or inappropriate pressure on an individual to give consent. We believe that for consent to be valid it must be voluntary.

CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 16 (or a higher age threshold if applicable in certain jurisdictions). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child without parental consent, we will take steps to delete such information promptly. If you are a parent or guardian and believe your child has provided us with personal information, please contact us using the details provided in this policy.

WHAT KIND OF PERSONAL INFORMATION WE COLLECT

Generally, we will not collect sensitive information from individuals unless we obtain consent to do so.

Customer information up-loaded to the on-line repository - In the case of personal information up-loaded by our customers to our on-line repository, we have no control over the content of that material - and so we assume that if the material is up-loaded with the consent of the customer.

Personal Information collected for general business purposes - Other than information up-loaded by a customer to our on-line service, we will not normally collect personal information other than an individual’s name, and contact details such as address, phone numbers and email addresses.

THE PURPOSES OF COLLECTING THE PERSONAL INFORMATION AND WHAT WE DO (AND WILL NOT DO) WITH IT

Customer information up-loaded to the on-line repository - this information is “collected” by Saropa because that is the service Saropa is in business to supply, including for associated operational purposes such as system monitoring and service improvement.

We will never disclose personal information uploaded by a customer to our on-line repository service in a manner that enables the customer to be identified.

From time to time we may use the information that we collect for commercial purposes, such as sale to marketing analysts or commercial firms having an interest in demographic data or statistics. We will always de-identify information before we use it in this manner.

Personal Information collected for general business purposes - We will generally collect personal information to enable us to contact our customers, suppliers, business partners and others with whom we have business relationships. This will enable us to fulfil our commitments and responsibilities to members and to enable them to reap the full benefits of membership. This will also enable us to monitor and administer our contracts and perform our contractual obligations.

We also collect personal information to enable us to carry out marketing initiatives - to let our customers and contacts know about the services we offer from time to time, such as new features or product updates.

DATA RETENTION

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements, or as otherwise required or permitted by law. For customer information uploaded to our on-line repository, the data is retained as long as the customer maintains an active account or as per the terms of their service agreement.

For general business information, retention periods are determined based on operational needs and legal obligations. Once personal information is no longer needed, we will take reasonable steps to securely destroy or de-identify it.

For general business information, retention periods are determined based on operational needs and legal obligations, such as the duration of a business relationship or statutory record-keeping requirements.

Once personal information is no longer needed, we will take reasonable steps to securely destroy or de-identify it.

ACCURACY OF PERSONAL INFORMATION

Customer information up-loaded to the on-line repository - we have no control over the accuracy of this information. It is the responsibility of our customers0 to ensure that the information up-loaded to our on-line service is accurate.

Personal Information collected for general business purposes - It is our policy to ensure that when personal information is collected from an individual it is accurately recorded. This is the responsibility of all staff involved in the collection and recording of such information. It is also our policy to collect personal information direct from the individual wherever possible since this is likely to generate greater accuracy.

Individuals have a right of access to the personal information held by Saropa and will have the opportunity to correct any inaccuracies (as to which, see below).

Saropa will respond promptly to any request for correction of data.

SECURITY OF PERSONAL INFORMATION

It is not appropriate in this policy to provide specific details of security measures adopted by Saropa to protect information held by it. To do so could compromise those security measures.

Customer information up-loaded to the on-line repository - Saropa pays special attention to the security of the information up-loaded to the on-line repository by its customers.

To some extent the battle with computer crime involves an “arms race” and a constant battle of technological measure and counter-measure. Saropa cannot guarantee absolute security; however, to maintain the integrity of information, Saropa has acquired and will continue to up-date appropriate technology, such as “fire-walls” and encryption programmes to exclude unauthorized access, hacking and computer virus infection from Saropa’s computer system.

Personal Information collected for general business purposes - Saropa will use an appropriate combination of administrative protocols, physical barriers and technology to help prevent unauthorised persons or intruders from gaining access to information.

Personal Information collected for general business purposes - Saropa will use an appropriate combination of administrative protocols, physical barriers and technology, such as access controls and data encryption, to help prevent unauthorised persons or intruders from gaining access to information.

INTERNATIONAL DATA TRANSFERS

Saropa is based in Australia. Your personal information may be stored and processed in Australia or any other country where Saropa or its third-party service providers (such as hosting providers) maintain facilities. Where we transfer your personal information outside of your country of residence, we will take steps to ensure that your information receives an adequate level of protection in the jurisdictions in which it is processed, for example, by entering into appropriate data transfer agreements incorporating recognized legal transfer mechanisms such as Standard Contractual Clauses.

INDIVIDUALS’ ACCESS AND CORRECTION RIGHTS

Customer information up-loaded to the on-line repository - The business Saropa is in involves the supply of an on-line repository for information. Saropa charges fees for the supply of that service. Saropa may deny access to the on-line repository if the agreed service fees are not paid.

Personal Information collected for general business purposes - Saropa will provide individuals access to the personal information which Saropa holds about them. This right of access will be advised when personal information is collected. To exercise this right, please contact us using the email address listed in the "Complaints and Further Information" section.

Saropa will respond to verifiable requests for access as soon as possible and will acknowledge the request within 14 days and deal with it within 30 days.

As regards other personal information collected and retained by Saropa for general business purposes (i.e. not up-loaded to the on-line repository), Saropa will not charge individuals for access to their personal information.

In some circumstances it may be appropriate and lawful for Saropa to deny access, as set out in NPP 6.

DELETING YOUR DATA

We respect your right to have your personal data deleted.

To request the deletion of your data:

• Email us at: delete.me@saropa.com
• Clearly state in your email that you are requesting the deletion of your personal data.
• For verification, please attach a copy of your proof of identity. For your security, ensure your passport photo, the numbers at the bottom of your passport, your identification number, and your social security number (or equivalent national identifier) are redacted (made unreadable).

We will respond to your deletion request within four weeks of receiving your verifiable request.

In limited circumstances (e.g., legal obligations, resolving disputes, or if data is essential for a service you still use and cannot be de-linked), we may need to retain some information. We will inform you if this applies to your request.

ELECTRONIC COMMUNICATION AND OUR WEB SITE

Special issues arise when personal information is collected or communicated by electronic means.

The Saropa web site will contain:

• a copy of this policy
• a policy statement specifically about on-line privacy; and
• at each point within the web site where personal information is collected, a collection notice as required by NPP 1.3

OUR OUTSOURCING OF SOME FUNCTIONS

From time to time, Saropa may engage external contractors to perform certain functions or services for Saropa, such as:

• hosting or maintaining the Saropa website and database, including the on-line repository;
• hosting or maintaining our IT generally;
• providing direct marketing and mailing services.

It is our policy that our contracts with such external providers, to the extent that it is contractually and commercially possible in each case, should require the provider to comply with the Privacy Act and the National Privacy Principles.

It is our policy that our contracts with such external providers, to the extent that it is contractually and commercially possible in each case, should require the provider to comply with the Privacy Act and the National Privacy Principles, and to only use the information shared for the specific function they have been engaged to perform.

COMPLAINTS AND FURTHER INFORMATION

If you have a complaint about a privacy matter or require further information, please contact us by one of the following means:

• email: privacy@saropa.com

Saropa Pty Limited is committed to continuously improving its approach to privacy and may update this policy statement from time to time to reflect changes in our practices or legal obligations. We encourage you to review this policy periodically. Significant changes will be communicated through our website or directly to you where appropriate.

Significant changes will be communicated through a prominent notice on our website, or directly to you where appropriate, before such changes take effect.

---

Policy Changelog

This policy was last updated on October 21, 2025.

• Compliance Statement: Clarified Saropa's commitment to privacy principles (e.g., Australian Privacy Principles under the Privacy Act 1988). (Note: Actual text reflects the company's current compliance status).
• Data Deletion Rights: Added a new section "DELETING YOUR DATA" detailing users' right to request data deletion and the process to do so, including contact via delete.me@saropa.com.
• Data Retention: Added a new section "DATA RETENTION" to provide general information on how long personal data is kept.
• International Data Transfers: Added a new section "INTERNATIONAL DATA TRANSFERS" to explain that data may be processed in Australia or other countries where Saropa or its service providers operate, and the measures taken to protect such data.
• Children's Privacy: Added a new section "CHILDREN'S PRIVACY" stating that services are not directed to children under 16 and outlining actions if children's data is inadvertently collected.

Saropa Pty Ltd (“Saropa”, “us”, “we”, or “our”), legally based in Australia, is responsible for this privacy policy.

We understand your privacy is of critical importance. In this privacy policy you will find information about your rights with regard to your data and how you can make use of those rights. We also inform you on how cookies are collected, processed and stored and for what purposes this is done.

The privacy policy may at times be edited, for example, due to legislative changes. While we advise consulting this policy periodically, for any material changes, we will provide a more prominent notice, such as through an email to our registered users or a clear notification on our website, prior to the changes becoming effective.

Personal Data That We Process

We will collect, store and process the information that you voluntarily provide to us when making use of our repository service for personal information (“Service”) or contacting us in any other way.

This includes personally identifiable information, like your name and contact information (“Personal Data”). The following Personal Data may be processed by Saropa:

• your first and last name, address, email address and phone number;
• the contact information that you provide about your emergency contact(s), like their name and phone number;
• your date of birth;
• your national identifying number (Social Security, National Insurance, PPS, etc.);
• information about your physical appearance, like your eye colour, skin colour, weight and/or height;
• information about your employment or education, like information about your salary or student identification number;
• geo-tracking data;
• any other Personal Data that you actively provide when contacting us or making use of the Service.

Sensitive Personal Data

The Personal Data that is collected by making use of the Service includes data that is, by its nature, of particularly sensitive nature (“Sensitive Data”). We only collect such Sensitive Data when it is voluntarily provided by you and after you have given your explicit consent to us doing so, to better serve and meet your needs.

The Sensitive Data we may process includes:

• information concerning your health and medical history;
• genetic data;
• data about your religious or other beliefs;
• any other Sensitive Data that you actively provide when contacting us or making use of the Service.

Usage and Connection Data

We also may use software tools like Google Analytics, to measure and collect session information, like the length of your visit to our website and/or Service, page response times, page interaction information and methods used to browse away from the page.

In addition, we may collect the Internet protocol (IP) address used to connect your computer or mobile device to the Internet; as well as other connection information, like information about your (mobile) operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

For what purpose and on what basis we process Personal Data

We use your Personal Data to provide you with the Service. We also use your Personal Data to give the contact persons you provided access to the Service during a crisis.

We may use your contact information to respond to your questions, inquiries or requests.

We may use software tools like Google Analytics to improve our Service and/or website and create a better user experience. Where we do so, and where consent is not the specific basis for this particular processing, we rely on our legitimate interests to understand how our services are used, to enhance their functionality, and to diagnose and troubleshoot malfunctions.

We may also use Personal Data for marketing purposes, but only if you have previously indicated that you wish to receive such messages. If you no longer wish to receive such messages from us, you can contact us using the contact details provided at the end of this privacy statement.

We do not process your Personal Data for other purposes and only with your explicit consent or for the implementation of the agreement that we have entered into with you.

We conduct a balancing test to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. You have the right to object to processing based on our legitimate interests (see 'View, modify or delete data' section for how to exercise your rights).

Sharing of Personal Data with Third Parties

We share your Personal Data with third parties only when it is necessary for providing and delivering our Service to you, or when legally required.

Examples of third parties we may share data with include:

• Our hosting provider, who manages the infrastructure for our website and Service.
• Other essential service providers who assist us in operating our Service (e.g., analytics providers as described previously, payment processors if applicable).

When we share your Personal Data with these third parties, we do so under strict contractual agreements. These agreements ensure that:

• They use your data only for the specific purpose of providing the contracted service to us.
• They implement appropriate security measures to protect your data (including encryption where appropriate for data in transit and at rest).
• They do not use your data for their own purposes or share it further without authorization.
• They delete or return your data once it is no longer needed for the service.

We will not provide your Personal Data to other parties for their own independent use unless we have your explicit consent or are required to do so by law.

Server Location and International Data Transfers

To provide our Service effectively and ensure resilience, Saropa utilizes a global infrastructure with servers and data processing facilities that may be located in various countries around the world, including Australia, countries within the European Economic Area (EEA), the United States, and other regions. The specific location where your Personal Data is processed may depend on factors such as the point from which you access our Services or the location of other users you interact with.

Regardless of where your Personal Data is processed, we are committed to ensuring its protection. When your Personal Data is transferred from the European Economic Area (EEA) to, or accessed from, a country outside the EEA that has not been deemed by the European Commission to provide an adequate level of data protection, we ensure that such transfers are lawful and that your data remains protected. We primarily achieve this by:

• Implementing Standard Contractual Clauses (SCCs) approved by the European Commission between Saropa (or the relevant Saropa entity processing your data) and the data importer (which may be another Saropa entity or a third-party service provider). These SCCs are supplemented by Transfer Impact Assessments (TIAs) and additional technical, organizational, and contractual safeguards as necessary to ensure an essentially equivalent level of protection to that in the EEA.
• Relying on an adequacy decision from the European Commission for the recipient country, where applicable (for example, if data is transferred to a country recognized as adequate).
• For transfers to third-party service providers located outside the EEA, ensuring they are bound by similar contractual obligations and transfer mechanisms.
• In limited circumstances, utilizing other valid transfer mechanisms or derogations recognized under the GDPR.

Our third-party hosting providers and other service providers who may process your Personal Data on our behalf are also required to adhere to these international data transfer requirements when handling data originating from the EEA.

You can request further information about the specific safeguards applied to the transfer of your Personal Data by contacting us using the details provided in this policy.

How long we keep Personal Data

We do not retain Personal Data for longer than is necessary to fulfill the purposes for which it was collected. To determine the appropriate retention period, we consider the following criteria:

• The duration for which you have an active account and require our Service.
• Our legal and regulatory obligations (e.g., for accounting or reporting purposes).
• The nature and sensitivity of the Personal Data.
• The potential risk of harm from unauthorised use or disclosure.

Personal Data within an active account is retained for the duration of the Service. Upon account closure, data may be retained for a limited period to comply with legal obligations or to resolve disputes, after which it will be securely deleted or anonymized.

Cookies

We use cookies and similar technologies ("cookies") to authenticate users, track the activity on our Service and/or website, to help us analyze how they are used and to improve them.

A cookie is a small text file that is stored on your computer, tablet or smartphone when you first visit our website and/or Service. The cookies we use are necessary for the technical operation of the website and Service and for your ease of use. They ensure that the Service and website work properly, identify you and, for example, remember your preferences. We also use cookies to aid in security measures used to protect user accounts. We may also use cookies to optimize our Service and website.

Below is described which cookies are used.

Functional cookies

Functional cookies are necessary for the functioning of the Service and website. Certain components of the Service and website cannot be used without these cookies. These cookies are used anonymously and therefore have little impact on your privacy.

Session cookies

With the help of a session cookie we can see which parts of the Service and website you have viewed during your visit. We can therefore adjust our Service and website as much as possible to the surfing behaviour of our visitors. These cookies are automatically deleted as soon as you close your web browser.

Prevent use of cookies

You can opt out of cookies by setting your internet browser so that it no longer stores cookies. In addition, you can also delete all information that were previously saved via the settings of your browser. It is possible that in that case you will not be able to use all functions of our website and/or Service anymore.

If you do not want your visitor behaviour to be recorded, you can download a plugin from Google that prevents this. For Microsoft Internet Explorer 11, Google Chrome, Mozilla Firefox, Apple Safari and Opera this plugin is available via: tools.google.com/dlpage/gaoptout. This setting then applies to all websites that you visit, not just our website.

Web Analytics Provider

A Web Analytics Provider (WAP), such as Google Analytics, collects data on visitor behaviour on our website and/or Service. This helps us understand how visitors navigate and interact with our services, allowing us to optimize their operation and design.

The WAP may share this information with other third parties if legally required, or if these third parties process information on the WAP's behalf. We do not control these disclosures by the WAP. We do not permit the WAP to use the analytics information obtained from our services for their other services.

The information collected by a WAP is typically anonymized or pseudonymized to the greatest extent possible. For instance, your full IP address is generally not directly accessible to us through these tools.

If a WAP, like Google Analytics, transfers data outside the European Economic Area (EEA) (e.g., to servers in the United States), we take steps to ensure that appropriate safeguards are in place for such transfers. These safeguards may include:

• Relying on the WAP's use of Standard Contractual Clauses (SCCs) approved by the European Commission, supplemented by a Transfer Impact Assessment (TIA) to ensure an essentially equivalent level of data protection.
• Verifying if the WAP is certified under an adequacy decision recognized by the European Commission, such as the EU-U.S. Data Privacy Framework (where applicable and valid for the specific WAP and data transfer).

Children under 16

We do not intend to collect data about visitors of the website who are younger than 16 years of age, unless they have permission from parents or guardians. Since we cannot check whether a visitor is older than 16, we advise parents and guardians to be involved in the online activities of their children, to prevent that data about children is being collected without parental consent.

In the event that you are under the impression that we have collected personal information about a minor without parental permission, please contact us via our contact details at the bottom of this page. We will then remove this information.

How we protect Personal Data

As the provider of the Service we are aware that privacy and security is of special importance for our customers. We pay special attention to the security of all the information that is uploaded to the Service.

Saropa takes the protection of your data seriously and takes suitable and appropriate security measures to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized changes.

Saropa uses an appropriate combination of administrative protocols, physical barriers and technology to help prevent unauthorised persons or intruders from gaining access to information.

We have acquired and will continue to update appropriate technology, such as “fire-walls” and encryption programmes to exclude unauthorized access, hacking and computer virus infection from Saropa’s computer system.

If you feel that your data is not properly protected or there are indications of abuse, please contact us via our contact details as stated at the bottom of this page.

View, modify or delete data

You have the right to access, correct, and delete your Personal Data. In addition, you have the right to withdraw your consent for data processing at any time (where processing is based on consent), to object to the processing of your Personal Data by Saropa (under certain conditions), and the right to request the restriction of processing of your Personal Data (under certain conditions).

You also have the right to data portability. This means you can request us to send the Personal Data we hold about you in a structured, commonly used, and machine-readable format to you or to another organization you nominate.

Exercising Your Rights

To exercise any of these rights, please contact us using the details provided at the bottom of this policy. To help us verify your identity and process your request efficiently, please provide sufficient information to identify yourself and specify the right you wish to exercise. We may request a copy of your proof of identity, with sensitive details (such as passport photo, ID numbers) redacted for your security.

We will respond to your request as quickly as possible, and in any case, no later than one month from receipt of your request (this period may be extended by two further months where necessary, taking into account the complexity and number of requests, in which case we will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay).

Right to Lodge a Complaint

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that Saropa's processing of your Personal Data infringes the GDPR. If you are in the European Union or European Economic Area, you can typically lodge a complaint with the supervisory authority in your country of habitual residence, place of work, or place of the alleged infringement. You can find a list of national data protection authorities on the European Data Protection Board's website.

Questions and Contact

For questions or remarks about the processing of your Personal Data or this privacy policy you can contact us via the following email address: dpo.gdpr.privacy@saropa.com.

---

GDPR Policy Changelog

This GDPR policy was last reviewed and updated on May 10, 2025.

• International Data Transfers (Analytics): Revised section on Web Analytics Providers (WAP) to remove outdated references to Privacy Shield. Updated to reflect current valid transfer mechanisms (e.g., SCCs, EU-U.S. Data Privacy Framework) for data transfers outside the EEA by WAPs like Google Analytics.
• Server Location & Third-Party Data Sharing: Clarified information on primary server locations. Enhanced details on contractual safeguards with third-party service providers, including data security and limitations on use. Explicitly addressed international transfer mechanisms for data processed by these third parties or on servers outside the EEA.
• Data Subject Rights: Added the "right to restriction of processing" to the list of user rights. Clarified the right to lodge a complaint with a supervisory authority and provided guidance on identifying it.
• Data Protection Officer (DPO): Added a statement clarifying Saropa's DPO status and relevant contact procedures.
• Lawful Basis (Legitimate Interests): Provided greater specificity on the use of "legitimate interests" as a lawful basis for certain processing activities (e.g., service improvement analytics) and highlighted the user's right to object.

IMPORTANT NOTE: Please read these Terms & Conditions carefully. On acceptance they create a binding contract between you and Saropa. You may not use the services provided at this website unless you accept them.

1  Some Important Terms

1.1  The following expressions, where used in these Terms & Conditions, have the following meanings:

Saropa means Saropa Pty Ltd (ABN 41 142 178 434), its successors and assigns.

Code means the computer code underlying this Website.

Content means the content of this Website, but does not include Your Material.

Domain Name means saropa.com.

Fees means monies payable by you to Saropa for the use of this Website and the Services.

Intellectual Property means all forms of intellectual property throughout the world including copyright, patents, petty patents, innovation patents, patentable inventions, know-how, trademarks (whether registered or unregistered), registered and registrable designs, circuit layout rights, applications for registration of any of the foregoing and rights to apply for registration of any of the foregoing.

Member means a user of this Website who has joined as a member and who uses the Website subject to the payment of Fees.

Sensitive Information means information about an individual''s health, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices or criminal record.

Services means services provided at this Website.

Website means this website.

Your Material means information, photographs, documents or other materials uploaded to this Website.

2  Application

2.1  These Terms & Conditions apply to your use of the Services. They apply whether you are a guest or visitor using the Website and the Services on a trial basis or a Member.

2.2  By viewing the Content on this Website or using the Services or by logging on as a Member, you signify your agreement to these Terms & Conditions.

2.3  If you do not agree to these Terms & Conditions, please exit this Website immediately.

3  Your Password

3.1  Access to the Services is by password which you have chosen. You must keep your password confidential and you must not disclose it to any third party. You are solely responsible for protecting your password from unauthorized access and use. Saropa is not liable to you or any third party for any loss of any kind which you may incur if a third party uses your password.

4  Use

4.1  You may use the Website and the Services for your own personal or in-house business use.

5  Unacceptable Use

5.1  You must not use this Website or the Services to:

1. copy the Website, the Content or the Code for commercial sale or licence;
2. upload, post or transmit any material that is pornographic, racist, offensive, defamatory, abusive, misleading or deceptive or unlawful;
3. defame, abuse, threaten, intimidate or harass any person;
4. transmit any computer virus or other potentially harmful computer program;
5. infringe the intellectual property rights of any user or other third party;
6. commit fraud or any other unlawful activity;
7. breach the privacy rights of any person;
8. harvest or collect information (including the identity and contact details of any person for commercial use or distribution);
9. advertise any business, goods or services, solicit for money, donations, gifts or membership of any organization or scheme;
10. interrupt or corrupt the use of the Website or the Services by any person; or
11. upload, post or transmit spam, chain letters.

5.2  If Saropa considers in its discretion that you have breached any of the rules in the preceding clause, Saropa can suspend your use of or access to the Website and your use of the Services. Exercising this right does not prevent Saropa from exercising any other rights or remedies it has under these Terms & Conditions and at law.

6  Your Material

6.1  Subject to, and to your compliance with, these Terms & Conditions and to the payment of applicable Fees, you may upload and remove Your Materials as you require.

6.2  Saropa agrees that it obtains no right, title or interest in or to Your Material or the Intellectual Property inherent in it as a result of your use of this Website or the Services.

6.3  When you upload Your Material to the Website you grant Saropa a world-wide and royalty free licence to store and publish it on the Website, subject to these Terms & Conditions.

6.4  You are solely responsible for determining what materials you will upload to this Website as “Your Materials”. Saropa is not obliged to monitor or screen Your Materials but may do so.

6.5  To maintain a safe and respectful environment, Saropa may moderate Your Materials if they violate these Terms or applicable laws. We aim to apply consistent standards and may remove content that breaches our guidelines. Where practical, we will notify you of moderation actions.

6.6  If Saropa admits Your Materials to the Website, or does not remove them from the Website, this does not imply that Saropa has accepted them as complying with these Terms & Conditions. Saropa may exercise its rights under the preceding clause at any time.

7  Ownership of the Website and its Intellectual Property

7.1  You agree that Saropa or its related entities is the owner of:

1. this Website;
2. the Domain name;
3. the Code;
4. the Content;
5. the trade mark “Saropa” and
6. all Intellectual Property rights in relation to the foregoing

7.2  You must not reverse engineer or decompile this Website and you must not seek to gain access to the Code.

7.3  You are permitted to temporarily store the Content on your personal computer for the sole purpose of viewing it or using the Services. You must not copy, reproduce, transmit or distribute the Content or the Code in any form or on any medium for any other purpose.

8  Variation

8.1  Saropa may update these Terms & Conditions or Website Content to reflect changes in services, technology, or legal requirements:

1. updates will apply prospectively from the time they are published on the Website; and
2. where changes are material, Saropa will aim to provide at least 30 days’ notice via the Website or email.

8.2  Your continued use of the Website after changes take effect constitutes acceptance of the updated Terms. If you do not agree, you may discontinue use of the Services.

9  Technical Issues and Down-time

9.1  You acknowledge and agree that:

1. Saropa does not promise that the Website will operate at any particular speed or in any particular technical environment. It is your responsibility to determine the technical compatibility and performance parameters of your connection to the Website;
2. Saropa does not promise that the Website will operate error or bug free;
3. the Website may experience delays, interruptions and down-time as a result of technical difficulties whether with the Website or the internet;
4. Saropa may at its discretion interrupt or close access to the Website to perform maintenance or to modify the Website;
5. while Saropa has taken precautions against the transmission of computer virus and other damaging programs, Saropa cannot ensure that all such viruses and programs are screened and excluded. You are solely responsible for and must take such measures as you consider appropriate to protect your computer system from infection;

10  Security of Your Materials

10.1  While Saropa has taken precautions to prevent unauthorized access to Your Materials, Saropa cannot ensure that all unauthorised persons are excluded and you release Saropa from liability for loss of any kind caused by unauthorised access except to the extent that Saropa or its employees deliberately allowed an unauthorized person such access.

10.2  You acknowledge and agree that Saropa has no control over the infrastructure (such as phone lines, satellite facilities etc.) used to upload, download and otherwise manipulate Your Materials by accessing the Website. Saropa is not liable for any loss you suffer if such infrastructure is compromised.

11  Saropa’s Recommendation Acknowledged

11.1  You acknowledge that the Website and the Services are a back-up measure for organizations and storage of Your Materials. You acknowledge that Saropa recommends that you keep your own copies of Your Materials in a secure manner and place.

12  Exclusion and Limitation of Saropa’s Liability

12.1  Important Notice: Nothing in these Terms & Conditions can or is an attempt to limit or exclude any right or remedy which is conferred by statute (including the Trade Practices Act, 1974 (Cwth)) and which cannot be limited or excluded.

12.2  To the extent permitted by law and subject to the preceding subclause:

1. except where required by law, Saropa does not provide warranties beyond those expressly stated in these Terms & Conditions;
2. Saropa’s liability for breach of contract, negligence or other tort and breach of any statutory duty or implied term is limited to refunding Fees actually paid by you, whether your loss is in the nature of personal injury, death, damage to or loss of property, financial or economic;
3. for the avoidance of doubt Saropa is not liable for economic loss, loss of profit, business interruption, loss of opportunity or for the inability to successfully identify or recover property or to make a successful insurance claim; and
4. Saropa is not liable for any damage to your computer hardware or software or the loss or corruption of any data stored on your computer.

13  Release and Indemnity

13.1  To the fullest extent permitted by law, you agree to release and indemnify Saropa from any claims, demands, or proceedings brought by third parties arising out of your use of the Website or Services, including any breach of these Terms or misuse of the platform by you or anyone using your account. This indemnity applies regardless of the nature of the claim and includes reasonable legal costs incurred by Saropa in defending such claims.

14  Privacy Acknowledgement and Consent

14.1  We take your privacy seriously. By using this Website, you agree to our Privacy Policy, which explains how we collect, use, and protect your personal information. Please review it to understand your rights and choices.

14.2  You acknowledge and agree that:

1. Saropa cannot ensure the security or privacy of Your Materials and that the Website and the internet are not immune to breach of security and privacy by third parties;
2. Saropa has no control over or responsibility for the use which may be made by other persons of Your Materials and any personal information which you may provide to them; and
3. by posting Your Materials, you consent to Saropa’s collection of the personal information contained in it. In particular, you consent to the collection, by Saropa of any Sensitive Information contained in Your Materials.

14.3  You agree that Saropa may contact you at any time regarding your use of this Website and to advise you of any other related services in which Saropa believes you may have interest.

15  Payment of Fees

15.1  You agree to pay all Fees payable to Saropa in full and without deduction on or before the due date for payment and in the manner agreed on entry to membership and otherwise as specified in this Website from time to time.

15.2  If you fail to pay Fees when due:

1. Saropa can suspend your use of or access to the Website and your use of the Services. Exercising this right does not prevent Saropa from exercising any other rights or remedies it has under these Terms & Conditions and at law; and
2. Saropa may charge you interest at the rate equivalent to that payable on commercial overdrafts of $50,000 by Saropa’s bank.

15.3  Exercising rights under the preceding clause does not prevent Saropa from exercising any other rights or remedies it has under these Terms & Conditions and at law

16  Termination Right

16.1  If you:

1. fail to pay any Fees or other monies payable to Saropa in full and without deduction on or before the due date for payment as specified in this Website; or
2. otherwise breach these Terms & Conditions,

Saropa may terminate this contract and:

1. suspend or exclude your access to this Website; and
2. remove Your Materials from this Website,

in each case, either permanently or temporarily, if Saropa reasonably believes a breach has occurred. Where feasible, Saropa will provide notice and an opportunity to address the issue before taking action.

17  Links With Other Sites

17.1  If this Website contains any link to a website that is not owned or controlled by Saropa, you acknowledge and agree that:

1. Saropa has no control over nor responsibility or liability for the content of any such linked website;
2. Saropa does not republish the content of any such linked website; and
3. such linked websites and their owners and controllers are solely liable for the privacy treatment of your personal information, insofar as you interact with any linked website.

18  Applicable Law

18.1  These Terms are governed by the laws of Victoria, Australia, where Saropa is headquartered. This ensures consistency in legal interpretation across our operations:

1. these Terms & Conditions;
2. your use of the Website;
3. your use of the Services; and
4. the Content.

18.2  Any legal proceedings commenced by you must be commenced in the courts of the State of Victoria, Australia.