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; (c) anyone who contacts Programa Support; and (d) end customers and other individuals who interact with the Services through payment pages, client dashboards, shared invoices, or other customer-facing functionality provided by a Programa user.
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.
This Policy also covers individuals whose information appears in published brand or supplier profiles, product libraries or project records, including sales representatives, and individuals who receive shared specifications or submit client reviews. It can apply even where the individual does not hold a Programa account.
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 Processor
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.
For a customer-direct profile publication, imports, specifications, project sharing, reviews and activity records, Programa processes personal information on the customer's behalf. If Programa determines a separate purpose for processing personal information to provide Brand Insights to other businesses, its role and lawful basis must reflect that activity; it does not act as a processor merely because the information originated in a customer's project. The Insights disclosures described in Section 6.6 remain subject to the relevant permissions and confidentiality protections.
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.
End-customer payment information. Where an end customer makes a payment through Programa’s Payment Services (such as paying an invoice issued by a Programa user), the applicable Payment Provider collects and processes the end customer’s payment information (such as card details or bank account information) directly. Programa may collect limited end-customer information in connection with payment processing, including email address, name, billing address, and transaction details, solely to facilitate the payment and provide related functionality (such as payment confirmations and receipts).
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.
5.7 Recordings, Audio and Transcripts
Where you use the Meeting Notes Features, we process audio recordings created during meetings, calls and conversations, transcripts generated from that audio, speaker labels, and any notes or summaries derived from them. This content may include the voices and statements of meeting participants, who may include individuals other than the account user. Speaker labels are assigned by you, not by automated voice-recognition. Programa does not use voiceprints to identify participants and does not retain voiceprints or other biometric identifiers.
5.8 Brands and Project Specification Information
We collect public information and information supplied by an organisation or its users about business profiles, locations, representatives and product libraries. This may include representatives' names, roles, territories, photographs and contact information. Representatives selected for a published profile may have their details displayed there. Where no separate representative photo is supplied, the profile may use the individual's account profile image.
Project information includes specifications, rooms and locations, quantities and allocations, linked products, labels, saved views, commercial figures, contacts, files and documents. Related records include sharing settings and snapshots, client review decisions, acting users, timestamps, sources of changes, previous field values, revisions, product matching decisions and the exact PDFs retained when documents are issued.
Information comes from users and their organisations, clients and suppliers interacting with them, integrations, uploaded spreadsheets and webpages selected for import. Imports can retrieve and store product text and images and generate processing results and error information. Preparing a procurement document may create or update an address book contact even if the document is not completed.
5.9 Ask Programa Information
When you use Ask Programa, we collect your questions, generated answers and citations, feedback, conversation titles and timestamps, and any page or project context used for the question, such as a context label or project identifier. We also collect usage and diagnostic information, including user and organisation identifiers, model and processing information, response times and errors. Conversation histories and diagnostic records can include copies of the workspace information used to generate the answer.
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 for analytics, product improvement and business insights. Brand Insights uses specification activity, product information, quantities, values, status categories and product matches to provide product-demand information to brands and suppliers. The processing of identifiable source information remains subject to applicable privacy obligations even if the resulting output is de-identified.
Information disclosed as de-identified must not reasonably identify an individual in the circumstances, taking account of information reasonably available to the recipient. Removing names or presenting counts does not necessarily achieve that result ; free-text descriptions, images and small groups may still identify people or projects. We withhold or limit disclosures where necessary to meet these requirements and the contractual confidentiality protections for studios, clients and projects.
Named or identifiable studio or project information is disclosed through Brand Insights only within the relevant studio's authorisation and with the lawful basis, notices and consents required by applicable law. A supplier's listing of a brand or product does not, by itself, authorise access to that information. The Terms describe the permitted disclosures and recipient restrictions.
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. For recordings and transcripts created through the Meeting Notes Features, the customer using those features is responsible for establishing a lawful basis (including any participant consent required by law) for the conversations they record.
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 process information submitted through the Services to generate outputs or provide functionality. Ask Programa processes your questions, relevant conversation history and the workspace information needed to answer your question. Depending on the question, this may include project and product records, tasks, contacts, logged time, studio settings, and meeting transcripts, summaries and decisions. Workspace retrieval follows your existing access permissions.
We use service providers to generate AI responses and support search, including converting queries into representations used to find relevant information. These providers receive the questions, history or content needed for the relevant function.
We store conversation histories and process usage and diagnostic information to operate and secure Ask Programa, troubleshoot problems and evaluate answer quality. These records can include questions, answers and retrieved workspace extracts, including meeting text. Access to these records is limited to authorised personnel and service providers for those purposes.
We do not use your Ask Programa questions, answers or workspace content to train or fine-tune AI models, and we require our AI service providers not to do so.
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, storage, website and spreadsheet import processing, search, analytics and data warehousing, communications, security, customer support tools, AI processing and diagnostics, transcription, invoicing and payment services processors. The information provided depends on the relevant feature and the provider's role.
9.2 Tax Authorities and Regulatory Bodies
Programa and/or its Payment Providers may be required to report transaction data to tax authorities (including the US Internal Revenue Service) in connection with payments processed through the Services. This may include transaction amounts, dates, payment methods, and identifying information. Where required by applicable law, Programa and/or the applicable Payment Provider will issue tax reporting forms (such as IRS Form 1099-K) to users.
9.3 Integrations You Enable
Third-party providers you choose to connect with your account to facilitate the integration.
9.4 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.
9.5 Corporate Transactions
In connection with a merger, acquisition, financing, restructuring, sale of assets or similar transaction.
9.6 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.
9.7 Project and Organisation Recipients
Information may be available to authorised organisation users and administrators, and to clients, suppliers and other recipients selected through sharing, quoting, review and document features. Visibility depends on the applicable permissions and sharing settings. Recipients may download and retain documents.
9.8 Brand Insights Recipients
Brands and suppliers receive the information permitted under Section 6.6 and the Terms. Independent listings for the same brand or product can affect attribution but do not expand disclosure permissions. Identifiable or confidential project information is limited to the specified authorised recipients and purposes.
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.
Audio recordings, transcripts and related content - including content relating to participants located in the European Economic Area or the United Kingdom - are stored on infrastructure operated by Amazon Web Services in the United States, and are processed by our transcription provider in the United States to generate transcripts and speaker labels. Where we transfer personal data from the EEA or UK to the United States, we rely on appropriate safeguards, including Standard Contractual Clauses, and, where applicable, our providers’ certification under the EU-US Data Privacy Framework. A copy of the relevant safeguards is available on request at support@programa.com.au.
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.
Activity histories, product matching decisions, revisions and issued PDFs may remain after a working product or view is removed because they preserve project and decision records. Uploaded import files and processing copies may be retained to complete and troubleshoot an import. Personal information in those records, search indexes, analytics systems and backups remains subject to the retention and deletion principles above and the Data Processing Addendum where applicable.
Ask Programa conversation histories and diagnostic records may contain copies of questions, answers and retrieved workspace information, including meeting text. These copies are subject to the retention and deletion principles above, including when held by our service providers. Deleting an underlying workspace record does not necessarily remove copies already included in Ask Programa conversation or diagnostic records.
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.
Where a recording or transcript was created by a customer using the Meeting Notes Features, that customer determines the purposes and means of processing that content and acts as its controller. If you are a meeting participant and wish to exercise rights in relation to a recording or transcript, you may need to contact the customer who created it; we will assist that customer as a processor to the extent required by applicable law.
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.
End-Customer Information (California Residents). Where Programa collects personal information from end customers located in California in connection with Payment Services (such as when an end customer pays an invoice), Programa may process such information as a service provider on behalf of the Programa user (designer/merchant). California residents who wish to exercise rights under the CCPA/CPRA in relation to payment transactions should contact the designer or business that issued the invoice. For information Programa collects as a controller (such as through its own websites), California residents may contact support@programa.com.au.
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.