Privacy & Policy

1. Introduction

This Privacy Policy explains how SEEN Pty Ltd (ACN 621 324 721) trading as JRpos (“SEEN”, “we”, “us” or “our”), the company that builds and operates the JRpos cloud point-of-sale platform, collects, uses, holds, discloses and protects personal information in connection with:

• our websites at https://jrposnow.com and https://jrpos.app (together, the “Sites”);
• the JRpos web application and the JRpos mobile applications for iOS and Android (together, the “Platform”);
• our sales, onboarding, data migration, demonstration, support and marketing activities (including our blog, newsletter, ROI calculator, plan wizard, interactive tour and business intelligence tools); and
• any other interaction you have with us (together with the Sites and the Platform, the “Services”).

We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where we process personal data of individuals located in the European Economic Area (EEA), the United Kingdom or other jurisdictions with comparable data protection laws, we also aim to comply with the EU General Data Protection Regulation (GDPR) and the UK GDPR to the extent they apply to us.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Services.

2. Our Role: Controller and Processor

JRpos is a business-to-business platform used by retailers, restaurants, cafes, pharmacies, supermarkets and other merchants (“Merchants”). It is important to understand the two different roles we play:

3. Information We Collect

4. How We Use Personal Information

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

• to create and administer accounts, authenticate users and provide the Platform and its features (sales and POS, inventory, reporting, loyalty, receipts and related modules);
• to process subscriptions, billing, GST where applicable, refunds and account management;
• to deliver requested services such as demos, migrations, onboarding, training and the monthly live Zoom demonstrations;
• to operate AI-assisted features (see Section 5), including AI product search, predictive analytics, forecasting, and the analysis of uploaded payment statements;
• to deliver receipts and notifications through channels selected by the Merchant, including WhatsApp;
• to provide customer and technical support and to respond to enquiries and complaints;
• to monitor, secure, maintain and improve the Services, including debugging, load management, service analytics and the development of new features;
• to send service communications (such as maintenance notices, security alerts and changes to terms) and, with your consent or as otherwise permitted by law, marketing communications such as our newsletter and product updates;
• to detect, investigate and prevent fraud, misuse, security incidents and other unlawful activity;
• to comply with our legal and regulatory obligations, and to establish, exercise or defend legal claims; and
• for other purposes described to you at the time of collection or to which you consent.

5. AI and Automated Features

The Platform includes AI-assisted features such as AI product search, predictive reorder and stock forecasting, customer segmentation, revenue and growth forecasting, the Business Health Check and the AI Payment Statement Analyzer. In relation to these features:

• outputs are generated to assist decision-making; they are informational and do not constitute financial, legal or professional advice;
• we do not use these features to make decisions that produce legal or similarly significant effects about individuals without human involvement;
• documents you upload for analysis (such as merchant payment statements) are processed to deliver the requested analysis, and are retained and secured in accordance with this Policy; and
• we may use aggregated and de-identified usage information to evaluate and improve model and feature performance. We do not sell personal information for these purposes.

6. How We Disclose Personal Information

We may disclose personal information to:

• Service providers and subprocessors: cloud hosting and infrastructure providers, payment processors, messaging providers (including WhatsApp/Meta for receipt delivery and support where you use that channel), email and communication tools, video conferencing providers (for demos), analytics providers and customer support tooling, in each case only to the extent needed to provide their services to us and subject to appropriate contractual protections.
• Our related bodies corporate and personnel: on a need-to-know basis for the purposes described in this Policy.
• Professional advisers: lawyers, accountants, auditors and insurers where reasonably necessary.
• Business transfers: a purchaser or prospective purchaser in connection with a sale, merger, financing or reorganisation of our business, subject to confidentiality obligations.
• Regulators and law enforcement: where required or authorised by law, court order or enforceable governmental request, or where necessary to protect our rights, users or the public.

We do not sell personal information.

7. Overseas Transfers

JRpos serves Merchants in multiple countries and supports 47+ languages and multi-currency operation. Personal information may be stored and processed in Australia and in other countries where we or our service providers maintain facilities. Where we transfer personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs and, where the GDPR/UK GDPR applies, we rely on appropriate safeguards such as adequacy decisions or standard contractual clauses. You can contact us for more information about the safeguards applying to specific transfers.

8. Security

We take reasonable technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These measures include encryption of data in transit, access controls and role-based permissions (including Manager PIN approvals within the Platform), network and application security monitoring, backup and recovery processes, and staff confidentiality obligations. No system is completely secure; you are responsible for keeping your login credentials confidential and for the security of devices on which you use the Platform. Please notify us immediately at support@JRposnow.com if you suspect unauthorised access to your account.

9. Data Retention

We retain personal information for as long as needed to provide the Services, comply with our legal obligations (for example, taxation and financial record-keeping requirements), resolve disputes and enforce our agreements. In general:

• account and billing records are retained for the life of the account plus the period required by applicable law (typically at least seven years for financial records in Australia);
• Merchant Data is retained while the Merchant’s subscription is active and for a limited wind-down period after termination to allow export, after which it is deleted or de-identified in accordance with our agreements and applicable law;
• uploaded analysis documents (such as payment statements) are retained only as long as needed to provide the analysis and for reasonable audit purposes; and
• marketing data is retained until you unsubscribe or ask us to delete it.

10. Cookies and Similar Technologies

11. Marketing Communications

If you subscribe to our newsletter or otherwise agree to receive marketing, we may send you insights, product updates and offers by email or other channels you have chosen. Every marketing email includes an unsubscribe link, and you may opt out at any time by using that link or contacting us at support@JRposnow.com. Opting out of marketing does not affect service communications that are necessary for the operation of your account.

12. Your Privacy Rights

13. Children

The Services are designed for businesses and are not directed to children under 16. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact us and we will take steps to delete it.

14. Data Breach Response

We maintain a data breach response process. If a data breach occurs that is likely to result in serious harm to affected individuals, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth), and will comply with any equivalent notification obligations in other applicable jurisdictions (including the 72-hour supervisory authority notification under the GDPR where it applies).

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies or legal requirements. The current version will always be posted at https://jrposnow.com/privacy with its effective date. For material changes, we will provide reasonable notice, such as by email or an in-Platform notice. Your continued use of the Services after the effective date constitutes acceptance of the updated Policy.

16. Contact Us and Complaints

Privacy Officer — SEEN Pty Ltd (JRpos)

• Email: support@JRposnow.com
• Postal address: Suite 15, 2A Robe Street, St Kilda VIC 3182, Australia
• Web: https://jrposnow.com/contact

If you have a privacy concern or complaint, please contact our Privacy Officer first. We will acknowledge your complaint promptly and aim to resolve it within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or, if you are in the EEA or UK, to your local data protection authority.