COLLEXN — PRIVACY POLICY
Version 1.0 | Effective Date: 8 July 2026
This Privacy Policy explains how Collexn Pty Ltd (A.C.N. 672 158 208) as trustee for the Collexn Trust (A.B.N. 92 170 947 665) (“Collexn”, “we”, “us”, “our”) collects, uses, discloses, and protects your personal information when you use our mobile application and related services (the “Platform”). This policy complies with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and — for users outside Australia — with the EU/UK General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA), as set out in Section 7.
1. INFORMATION WE COLLECT
1.1 Information you provide directly:
• Account details: name, email address, password
• Profile information: display name, bio, profile photo
• Collection data: items, photos, videos, descriptions, valuations, categories, conditions, purchase prices
• Social content: posts, comments, reactions, messages in groups
• Wishlist data: items, priorities, target prices
• Marketplace data: listings, item descriptions, pricing, listing type (sale/trade), reports submitted against listings
• Communications: emails, support requests, feedback
• Camera, photo library & microphone: photos and videos you capture or select for your items (with your permission). Item videos are compressed on your device and have their audio removed before upload — we do not receive or store any audio from your item videos. The microphone permission requested during recording is used only by your device’s camera to capture the clip.
1.2 Information collected automatically:
• Device information: device type, operating system, app version
• Usage data: features used, screens visited, timestamps
• Push notification tokens (if you enable notifications)
• IP address and approximate location (country/region level)
• Crash reports and performance data
1.3 Information from third parties:
• Google account details (if you sign in with Google)
• eBay market data (for valuation features — no personal eBay data is collected)
2. HOW WE USE YOUR INFORMATION
2.1 We use your information to:
• Provide, maintain, and improve the Platform
• Create and manage your account
• Process and deliver subscriptions
• Enable social features (posts, comments, follows, groups)
• Operate the Marketplace feature (listing creation, browsing, reporting, trust indicators)
• Provide AI-powered features (grading, identification, valuations)
• Moderate content for safety and policy compliance (including Marketplace listings)
• Send push notifications you have opted into
• Send transactional emails (password resets, account notifications)
• Analyse usage to improve the Platform
• Detect and prevent fraud, abuse, and security incidents
• Comply with legal obligations
3. CONTENT MODERATION & AI PROCESSING
3.1 To maintain community safety, all user-generated content — including posts, comments, messages, profile information, item photos, and item videos (via representative still frames) — is processed through our automated content moderation system, which includes AI-based analysis.
3.2 Moderation processing may include:
• Pattern matching against known prohibited content
• AI analysis of text for policy violations
• AI vision analysis of images and video frames for policy violations
• Logging of flagged or rejected content for review
• User reports and community flagging
3.3 Content flagged by our moderation systems may be reviewed by authorised personnel for the purpose of enforcing our Terms of Service.
3.4 We retain moderation logs (including rejected content) for up to 12 months for safety and legal compliance purposes.
4. HOW WE SHARE YOUR INFORMATION
4.1 We do not sell your personal information.
4.2 We may share your information with:
• Service providers: Cloud hosting (AWS), email delivery (SendGrid), payment processing, analytics, error tracking (Sentry)
• AI service providers: For content moderation and AI features (content is processed but not stored by these providers beyond what is needed to deliver the service)
• Other users: Your public profile, posts, comments, collection information you choose to share, and Marketplace listings (including your display name, account age, and completed transaction count as seller trust indicators)
• Law enforcement: When required by law, court order, or to protect safety
• Business transfers: In connection with a merger, acquisition, or sale of assets
5. DATA STORAGE & SECURITY
5.1 Your data is stored on secure servers. We use industry-standard security measures including:
• Encryption in transit (TLS/SSL)
• Encrypted password storage (bcrypt hashing)
• Secure token-based authentication (JWT)
• Access controls and monitoring
• Regular security assessments
5.2 While we take reasonable steps to protect your information, no method of transmission over the Internet is 100% secure.
6. DATA RETENTION
6.1 We retain your personal information for as long as your account is active or as needed to provide services.
6.2 Upon account deletion:
• Your profile, collections, items, and social content will be permanently deleted
• Moderation logs may be retained for up to 12 months
• Backup copies may persist for up to 30 days
• Anonymised, aggregated data may be retained indefinitely
7. YOUR RIGHTS (UNDER THE PRIVACY ACT 1988)
7.1 You have the right to:
• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your account and associated data
• Complaint: Lodge a complaint with us or the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the APPs
7.2 To exercise these rights, contact us at [email protected].
7.3 We will respond to access and correction requests within 30 days.
7.4 ADDITIONAL RIGHTS FOR USERS IN THE EUROPEAN ECONOMIC AREA (EEA), UNITED KINGDOM & SWITZERLAND
If you are located in the EEA, the UK, or Switzerland, the General Data Protection Regulation (GDPR) and equivalent UK/Swiss laws apply to our processing of your personal data, and you have additional rights.
• Data Controller: Collexn Pty Ltd (A.C.N. 672 158 208) is the controller of your personal data. Contact: [email protected].
• Legal bases for processing: we process your data on the bases of (a) performance of a contract (to provide the app and your account); (b) your consent (e.g., optional features, marketing — which you may withdraw at any time); (c) our legitimate interests (e.g., securing the Platform, preventing fraud and abuse, improving our services); and (d) compliance with legal obligations.
• Your GDPR rights: in addition to access, correction, and deletion (above), you have the right to (i) data portability (receive your data in a structured, machine-readable format); (ii) restrict or object to processing, including processing based on legitimate interests; (iii) withdraw consent at any time without affecting prior processing; and (iv) not be subject to solely automated decisions producing legal or similarly significant effects. Our AI features (moderation, identification, valuation estimates) support, rather than replace, human decision-making about your account.
• International transfers: where we transfer your data outside the EEA/UK (e.g., to cloud providers in the United States), we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum) to ensure an adequate level of protection.
• Right to complain: you may lodge a complaint with your local supervisory authority (in the EEA), the UK Information Commissioner’s Office (ICO), or the Swiss Federal Data Protection and Information Commissioner (FDPIC).
7.5 ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS (CCPA / CPRA)
If you are a California resident, you have the right to (a) know the categories and specific pieces of personal information we collect and how we use them; (b) request deletion of your personal information; (c) request correction of inaccurate information; and (d) not be discriminated against for exercising these rights.
• We do NOT sell or share your personal information for cross-context behavioural advertising, and we do not use third-party advertising trackers.
• To exercise these rights, contact [email protected]. We will verify your request and respond within the timeframes required by law.
8. CHILDREN’S PRIVACY
8.1 The Platform is not intended for children under 13. We do not knowingly collect personal information from children under 13.
8.2 If we become aware that a child under 13 has provided personal information, we will take steps to delete it promptly.
8.3 For users aged 13–17, we recommend parental or guardian oversight.
9. CROSS-BORDER DATA TRANSFERS
9.1 Your data may be transferred to and processed in countries outside Australia (e.g., to our cloud service providers in the United States).
9.2 In accordance with APP 8, before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the recipient does not breach the APPs or is subject to substantially similar privacy protections.
10. COOKIES & TRACKING
10.1 The Platform may use local storage and similar technologies for authentication and preferences.
10.2 We do not use third-party advertising trackers.
11. CHANGES TO THIS POLICY
11.1 We may update this Privacy Policy from time to time. We will notify you of material changes via the Platform or email.
11.2 Continued use after changes take effect constitutes acceptance.
12. NOTIFIABLE DATA BREACHES
12.1 In compliance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988, if we become aware of an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the OAIC as required.
13. CONTACT
Privacy Officer
Collexn Pty Ltd (A.C.N. 672 158 208) as trustee for the Collexn Trust (A.B.N. 92 170 947 665)
Email: [email protected]
General Support: [email protected]
Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992