1. Overview

This Privacy Policy explains how Denpro Pty Ltd (ABN 79 637 366 084), trading as Programa (“Programa”, “we”, “us”, “our”), collects, uses, discloses and stores personal information when you access or use our websites, applications and services (collectively, the “Services”).

This Privacy Policy applies to: (a) visitors to our websites; (b) users of the Services; and (c) anyone who contacts Programa Support. It does not apply to the practices of third parties that we do not own or control.

By using the Services, you acknowledge that your personal information will be handled in accordance with this Privacy Policy.

2. Who We Are and How to Contact Us

Denpro Pty Ltd (trading as Programa) is an Australian company and is the controller of personal information we process for our own purposes, unless otherwise specified.

If you have questions, requests or complaints about this Privacy Policy or how we handle personal information, you can contact us at support@programa.com.au.

3. Age Restriction

The Services are intended for use by individuals who are 18 years of age or older. Programa does not knowingly collect personal information from individuals under 18 and does not permit such individuals to create accounts. If we become aware that personal information has been collected from an individual under 18, we will take steps to delete that information. If you believe this has occurred, please contact support@programa.com.au.

4. When Programa Acts as Controller vs Process

Depending on how you interact with Programa, our role in relation to personal information may differ.

4.1. Programa as Controller

Programa acts as a controller when we process personal information to operate our business and provide the Services, including account creation and administration, billing, platform security, product development, customer support, marketing (subject to your preferences), and legal compliance.

4.2. Programa as Processor or Service Provider

If you interact with a designer, brand, supplier, or other business using Programa (each, a ‘merchant’ or ‘merchant user’), that business may be the controller of your personal information. In those cases, Programa processes personal information on their behalf as a processor or service provider, in accordance with their instructions and applicable data protection laws. Their privacy policy will also apply, and you may need to contact them directly to exercise certain rights.

5. Personal Information We Collect

We collect personal information in the following categories, depending on how you use the Services:

5.1. Account and Profile Information

Information such as your name, email address, business name, role, profile image, and account settings.

5.2. Communications

Information you provide when you contact Programa, including support requests, emails, messages sent through in-app communication features, survey responses and feedback.

5.3. Usage and Device Information

Information about how you access and use the Services, such as IP address, device identifiers, browser type, operating system, pages or features used, logs, and interaction data. This information may be collected through cookies or similar technologies.

5.4. Payment and Billing Information

For subscriptions or payments to Programa, we collect billing details such as billing contact information and payment method metadata. Payment processing is handled by third-party payment providers, including Stripe. Programa does not store full payment card numbers. Payment providers process payment information in accordance with their own terms and privacy policies.

5.5. Information from Integrations

If you connect third-party services or tools to your account, we may receive information from those services as permitted by your settings and the third party’s terms, solely to provide the integration and related functionality.

5.6. Content You Submit

The Services allow you to upload or create content (such as schedules, specifications, project data, files, images and messages). This content may include personal information depending on what you choose to submit.

6. How We Use Personal Information

We use personal information for the following purposes:

6.1. Providing and Operating the Services

To create and manage accounts, authenticate users, deliver platform functionality, administer subscriptions, enable features (including invoicing and payment features), and operate the Services.

6.2. Customer Support and Communications

To respond to enquiries and provide assistance, communicate about your account, and send service-related notices such as updates, security alerts, and billing information.

6.3. Product Improvement and Development

To maintain, test, troubleshoot, analyse usage, develop new features and improve the Services.

To improve, troubleshoot and optimise the Services, Programa may use analytics and diagnostic tools including session replay and behavioural analytics technologies. These tools help us understand how users interact with the Services, identify errors, and improve usability and performance.

Where session replay technologies are used, Programa applies appropriate safeguards and uses the data solely for product improvement, support and security purposes, in accordance with this Privacy Policy.

6.4. Security, Fraud Prevention and Compliance

To detect, prevent and investigate spam, fraud, abuse, security incidents, or prohibited activity, to enforce our Terms and policies, and to comply with legal obligations.

6.5. Marketing and Advertising

We use personal information to market and promote Programa and to measure the effectiveness of our communications. This may include targeted or interest-based advertising delivered through third-party advertising platforms, subject to your preferences and applicable law.

Programa will not use your content or Materials stored in the platform in marketing or advertising without your explicit permission (for example, in authorised case studies or co-marketing). Targeted advertising is based on interactions with our websites and Services (such as cookie and device data), not the content you create or store in the platform.

From time to time, Programa may conduct co-marketing activities with selected partners. In these cases, Programa may send communications to its own users on behalf of, or in collaboration with a partner. Unless otherwise stated and agreed by you, Programa does not provide your contact details to partners for their independent marketing use.

Where we do share personal information with partners for marketing purposes, we do so only with appropriate notice and, where required by law, your consent. You may opt out of marketing communications at any time as described in this Privacy Policy.

6.6. Aggregated and De-identified Data

We may aggregate, de-identify, or anonymise information so it can no longer reasonably identify you. We may use such information for analytics, product improvement or business insights.

7. Legal Bases for Processing

Depending on your location and how you use the Services, applicable privacy and data protection laws may require a legal basis for processing personal information. Where such requirements apply, Programa processes personal information for purposes such as providing the Services, operating and securing the platform, complying with legal obligations, and conducting marketing activities in accordance with this Privacy Policy and applicable law.

8. Artificial Intelligence and Automated Features

The Services may include features that use artificial intelligence, machine learning or similar technologies (“AI Features”) to generate suggestions, classifications, summaries or other outputs.

AI Features may process information you submit through the Services in order to generate outputs or provide functionality. Some AI Features may involve third-party service providers acting as sub-processors, and only the information necessary to provide the feature is shared.

Programa does not use AI Features to make automated decisions that produce legal or similarly significant effects about you without appropriate safeguards.

9. How We Share Personal Information

We may share personal information with the following categories of recipients:

9.1. Service Providers

Third-party vendors and sub-processors that support our business, including hosting, analytics, communications, security, customer support tools, and payment processors.

9.2. Integrations You Enable

Third-party providers you choose to connect with your account to facilitate the integration.

9.3. Advertising and Analytics Partners

Advertising and analytics partners that help us deliver targeted advertising and measure campaign performance, subject to applicable law and your choices.

9.4. Corporate Transactions

In connection with a merger, acquisition, financing, restructuring, sale of assets or similar transaction.

9.5. Legal and Safety Reasons

Where required by law, to respond to lawful requests, or to protect the rights, property, or safety of Programa, our users or others.

10. International Data Transfers

Programa may process and store personal information in Australia and other countries where we or our service providers operate, including the United States. Laws in those countries may differ from those in your location. We take reasonable steps to protect personal information when it is processed internationally, consistent with this Privacy Policy and applicable law.

11. Cookies and Tracking Technologies

We use cookies and similar technologies to operate our websites and Services, remember preferences, analyse usage, improve performance, and deliver targeted advertising.

11.1. Targeted Advertising

We may work with advertising and analytics partners that use cookies, pixels, or similar technologies to collect information about your interactions with our websites and Services in order to deliver interest-based advertising.

Depending on your location, you may have the right to opt out of targeted advertising or “sharing” of personal information for cross-context behavioural advertising. You can exercise these choices through your browser settings, cookie preferences (where available), or by contacting support@programa.com.au.

12. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, including providing the Services, complying with legal obligations, resolving disputes, enforcing agreements, and maintaining security and fraud prevention.

Retention periods vary depending on the type of information and purpose. Where you request deletion, we will take reasonable steps to delete or de-identify personal information unless retention is required or permitted by law or for legitimate purposes such as compliance, dispute resolution, or backups.

13. Security

We implement appropriate technical and organisational measures designed to protect personal information. However, no system is completely secure, and we cannot guarantee absolute security of personal information.

14. Your Rights and Choices

Depending on your location and subject to applicable law, you may have rights to request access to, correction of, deletion of, or restriction or objection to certain processing of your personal information. The availability and scope of these rights depend on applicable law and the nature of Programa’s role (for example, whether Programa acts as a controller or processor). Certain requests may be limited by technical, operational or legal constraints.

To exercise your rights, contact support@programa.com.au. We may need to verify your identity before responding.

If you interact with a merchant user through Programa, you may need to contact that merchant directly to exercise rights relating to that interaction.

15. Marketing Preferences

You can opt out of marketing emails at any time using the unsubscribe link in the email, adjusting your account settings (where available), or contacting support@programa.com.au. Service-related communications (such as billing, security, and account notices) are not marketing and may still be sent.

16. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top. If changes are material, we may provide additional notice through the Services or by email.

17. Complaints

If you have concerns about how we handle personal information, please contact support@programa.com.au and we will work with you to resolve the issue. Depending on your location, you may also have the right to lodge a complaint with your local privacy or data protection authority.

Appendix A – United States Information Notice

This notice provides supplemental information for individuals located in the United States. It is intended to describe certain data practices in a transparent manner and does not constitute a representation that Programa complies with any specific United States state privacy law.

This notice supplements, and should be read together with, the Programa Privacy Policy. Except as expressly stated here, all information about how Programa collects, uses and discloses personal information is described in the main Privacy Policy.

Sale and Sharing of Personal Information

Programa does not sell personal information in exchange for monetary consideration.

However, under certain US privacy laws, the use of cookies or similar technologies for targeted or interest-based advertising may be considered a “sharing” of personal information for cross-context behavioural advertising purposes. Programa may engage in such sharing as described in the Privacy Policy. Programa does not use your content or Materials stored in the Services for advertising without your explicit permission.

Your Privacy Rights (US Residents)

Depending on applicable law, you may have certain choices regarding marketing communications and targeted advertising technologies. These choices are described in this Privacy Policy.

Exercising Your Rights

You may exercise your privacy rights by contacting support@programa.com.au. We may need to verify your identity before responding. If you interact with a merchant user through Programa, that merchant may control your personal information for that interaction, and you may need to contact them directly.