BIA Privacy Policy

Broker Institute of Australia ("BIA", "we", "us", "our") is committed to protecting the privacy of personal information we handle. We comply with the Privacy Act 1988 (Cth) (the "Privacy Act") and the Australian Privacy Principles (APPs).

This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how we keep it secure, how you can access and correct it, and how to make a complaint.

Issuing entity: Flint Trademark Pty Ltd ACN 683 224 697 as trustee for the Broker Institute of Australia Trading Trust ABN 72 514 173 255.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Sensitive information is a specific subset, such as health information, and receives additional protection under the Privacy Act. We do not seek to collect sensitive information unless it is reasonably necessary.

Depending on how you interact with us, we may collect:

• identity and contact information — name, email address, phone number, postal address;
• account information — username, password (stored hashed), date of birth (where required for age verification), profile information you choose to provide;
• payment information — we do not store full credit card numbers ourselves; payment details are processed by Kajabi Payments and Stripe and we receive a tokenised reference, the last four digits of the card, the card type and the billing address;
• transaction information — purchase history, refund history, dispute and chargeback records;
• content and engagement information — modules accessed, time spent, completion status, downloads, posts in community channels, support enquiries;
• technical information — IP address, device identifiers, browser type, operating system, login times, geographic region derived from IP, device fingerprint;
• marketing information — source of acquisition, marketing preferences, email open and click data;
• communications — records of correspondence with our team, including support tickets, calls which may be recorded with notice, and feedback; and
• user-generated content — testimonials, reviews, photos, video, posts and any other material you submit.

We collect personal information directly from you where reasonable and practicable, including when you:

• create an account or complete checkout on the BIA platform hosted by Kajabi;
• subscribe to our email list, download a free resource, register for a webinar or event, or complete a form on the BIA website;
• interact with us by email, phone, social media or through any community channel;
• participate in surveys, research, testimonials or case studies; and
• apply for employment with us.

We may also collect information from third parties, including payment processors, analytics providers, advertising platforms such as Meta, Google and TikTok, referral partners, identity-verification providers, debt collection agencies, credit reporting bodies where lawfully permitted, and publicly available sources.

Cookies and similar technologies. The BIA website and platform use cookies, pixels and similar technologies to operate the site, remember your preferences, secure your session, measure performance and serve targeted advertising. You can manage cookies through your browser settings. Disabling some cookies may affect site functionality.

We collect, use and disclose personal information for the following primary purposes:

1. to provide the Course and related services, including provisioning your Account, delivering content and responding to support enquiries;
2. to process payments, manage payment plans, issue tax invoices and pursue overdue amounts;
3. to operate and moderate BIA community channels;
4. to communicate with you about your Account, including transactional emails, payment notices, policy changes and security alerts;
5. to send marketing communications about BIA products, events and content, with the ability to opt out at any time;
6. to detect, prevent and respond to fraud, abuse, breach of our terms and security incidents, as set out in the BIA Bad-Faith and Non-Payment Control Framework;
7. to research, analyse and improve our products and services;
8. to comply with our legal obligations, including under the Privacy Act, the Spam Act 2003 (Cth) and the ACL; and
9. for any other purpose disclosed at the time of collection or to which you have consented.

We may disclose your personal information to:

• our staff, contractors and service providers who need it to perform their roles;
• Kajabi Inc. for course-hosting and learning management platform services;
• Kajabi Payments / Stripe for payment processing;
• email service providers, including ActiveCampaign, Klaviyo or Mailchimp where used from time to time;
• analytics, attribution and advertising platforms such as Google Analytics, Meta and TikTok;
• identity-verification providers, fraud-prevention services and debt-collection agencies, where reasonably necessary to enforce the Agreement;
• our professional advisers, including legal, accounting, audit and insurance advisers;
• any successor in our business or in connection with a merger, acquisition or restructure; and
• government agencies, regulators, law enforcement or courts where required or authorised by law.

Some of our service providers, including Kajabi, Stripe and certain email and analytics providers, are located or process personal information outside Australia, including in the United States and the European Union. Where we disclose personal information overseas, we take reasonable steps to ensure the recipient handles the information in a way consistent with the Australian Privacy Principles. By using our services you consent to this disclosure.

We send marketing communications by email and, where you have provided a number, SMS. Each marketing communication contains an unsubscribe option. You can also unsubscribe at any time by emailing info@brokerinstituteofaustralia.com.au.

Transactional and account-related communications are not marketing and you cannot opt out of those while you have an active Account.

We do not sell or rent personal information to third parties for their direct marketing purposes.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure, including through:

• use of reputable third-party platforms with industry-standard security, including Kajabi and Stripe;
• access controls and least-privilege principles for our staff;
• encryption of data in transit;
• logging and monitoring of administrative access; and
• incident response procedures aligned with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act.

Despite reasonable steps, no system is impenetrable. If you believe your Account has been compromised or you have identified a security issue, contact us immediately at info@brokerinstituteofaustralia.com.au.

We retain personal information for as long as is reasonably necessary for the purposes for which it was collected, including:

• Account and transaction records: at least seven (7) years after Account closure, consistent with tax record-keeping requirements;
• marketing records: until you unsubscribe, plus a reasonable period to evidence consent;
• enforcement records: seven (7) years after the matter closes; and
• user-generated content in community channels: until you delete it or you cease to be a Student, subject to backups.

After the relevant retention period we will destroy or de-identify the information unless we are required to retain it by law.

You have the right to request access to the personal information we hold about you and to ask us to correct it if it is inaccurate, out-of-date, incomplete or misleading.

To make a request, email info@brokerinstituteofaustralia.com.au with sufficient detail for us to identify your records. We will respond within thirty (30) days. We may charge a reasonable cost-recovery fee for access, but not for correction. We may decline access where lawfully permitted, in which case we will explain the reason.

If you believe we have breached the Privacy Act or the APPs, please contact us first at info@brokerinstituteofaustralia.com.au. We will acknowledge your complaint within five (5) business days and provide a written response within thirty (30) days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Online: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

We may update this policy from time to time. The current version is published at www.brokerinstituteofaustralia.com.au and includes the version number and effective date in the footer. Material changes will be notified by email to active Students.

Privacy Officer, Broker Institute of Australia

Suite 5, Level 14, 3 Spring Street, Sydney NSW 2000

Email: info@brokerinstituteofaustralia.com.au

This document forms part of the binding legal agreement between you and Broker Institute of Australia. For questions, contact info@brokerinstituteofaustralia.com.au.