Privacy Policy

Introduction

Barranjoey Capital Pty Limited (ABN 85 630 955 387) ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share personal information when you use www.dotty.cc (the "Site") and our simple web tools and utilities for humans, AI agents, and developers (collectively, the "Services"). It also describes your rights and how you can exercise them. We adhere to applicable global data protection laws, including the Australian Privacy Act 1988 (Cth), the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) (as amended by the CPRA), and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). This Policy applies to all users of our Services, including automated AI agents using our tools. By using the Site, you agree to the practices described in this Privacy Policy.

Information We Collect

We strive to collect only the minimal personal, device, and business information necessary to provide and improve our Services. The types of information we may collect include:

Information You Provide: If you choose to contact us (for example, via email at [email protected]) or provide input into our tools, we may collect the content of those communications and any personal data you include. This could include an email address, feedback, or any personal information contained in files or text you submit. Some of our tools allow you to input or upload content (for example, text, images, or documents such as passport scans or vCards). We process such content to perform the requested tool function, but we do not permanently store sensitive personal data from these inputs once the processing is complete (i.e. such data is handled transiently and then deleted from our systems).

Preferences and Hosted Content: Some tools may store your preferences or settings (for example, a preferred unit of measurement or theme) to enhance your experience. In certain cases, our tools may generate or host content on your behalf (for example, creating a shareable link to content you provided or that was generated for you). Such preferences or hosted content links may be stored so that they remain available to you and anyone with the link. We do not associate these preferences or content links with your identity, and you can request removal of hosted content by contacting us.

Device and Usage Information: We automatically collect certain technical information when you use our Site. This includes data like your IP address, browser type, operating system, referring URLs, and timestamps of visits. We also collect information about your interaction with our Services, such as tool usage metrics and error logs. We do not create user accounts or require registration, so we generally cannot directly identify you. However, device and usage data may be considered personal data under some laws (for example, IP addresses under GDPR). We use this information to ensure the Service functions properly, to maintain security, and to analyse and improve our tools.

Cookies and Similar Technologies: We use cookies and similar tracking technologies to operate and understand the usage of our Site. For example, we use anonymous cookies to remember your tool preferences or settings and to carry out basic usage tracking. These cookies do not reveal your identity but assign a random ID to distinguish repeat visits. We also employ third-party cookies for analytics and occasional advertising (described below). You can control cookies through your browser settings and you can refuse or delete cookies; however, some features of our Services may not function properly without them. Where required by law (e.g. in the EU), we will obtain your consent before using non-essential cookies such as analytics or advertising cookies.

How We Use Your Information

We use the information we collect for the following purposes:

To Provide and Improve Services: We process data you input into our tools to deliver the functionality you requested. For example, if you use a tool on our Site, we will use the provided information (which may include personal data) to generate the desired output. We also use data (like usage logs and feedback) to debug, enhance, and improve the performance and features of our web tools and utilities.

To Store Preferences and Content: We use cookies or similar technologies to save your tool preferences (such as interface settings) so that you have a consistent user experience. When our tools create shareable links to hosted content (based on your input or output you requested), we store that content as necessary to provide the service. Any personal information in such content is processed and stored only as needed to fulfill your request and is not used for other purposes.

Analytics and Usage Tracking: We analyse how users (including AI agents) interact with our Site to understand what parts of our Services are useful and to identify areas for improvement. For instance, we track aggregate metrics like page views, tool usage frequency, and error occurrences. This information is collected in an anonymous or pseudonymous manner (e.g. via cookies or logging IP addresses without directly tying them to your identity) and is used to generate statistics and insights about our user base and service performance.

Advertising (Occasional): We may occasionally display advertising content from partners on our Site. When we do so, we may use basic data about your visit (such as cookie identifiers or page context) to ensure that the ads are effectively served and to prevent showing the same ad too many times. Any ads will be clearly identified, and any personal information used for ad delivery or personalisation will be handled as described in this Policy (see "Third-Party Analytics and Advertising" below).

Communications: If you contact us with a question, support request, or exercise of your privacy rights, we will use your contact information and message to respond to you. We may also send administrative emails if necessary to inform you of important service updates or changes to this Privacy Policy or our Terms.

Legal Compliance and Protection: We may use or disclose information as necessary to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. This includes using data to enforce our Terms of Service, investigate potential violations, detect/prevent fraud or security issues, and protect the rights and safety of our users, our company, or others.

We will not use personal information for purposes that are incompatible with those above without obtaining your consent or unless required or permitted by law.

Third-Party Analytics and Advertising

We use a few third-party services to help us understand our site usage and occasionally to serve content or ads. These third parties may collect information sent by your browser or device (such as IP address, cookies, and other device identifiers) when you interact with our Site. The third-party services we use include:

Google Analytics and Google Tag Manager: We use Google Analytics, facilitated by Google Tag Manager, to collect anonymised statistical data about how our Site is used. Google Analytics uses cookies and similar technologies to collect data on website visitors' interactions. This data may include your IP address, browser type, pages visited, and time spent on pages. We have configured Google Analytics in a manner that does not allow us to identify individuals (for example, by using aggregated reports and not linking analytics data to any personally identifying information). Google may process data collected via Analytics on servers in various countries (including the United States) for the purpose of evaluating your use of the Site and compiling reports for us. Google operates under its own privacy policy and offers the ability to opt out of Google Analytics (for example, via a browser add-on). We use the information from Google Analytics solely to improve our Services, diagnose technical issues, and better understand user preferences.

Google Ads (Advertising Partners): Our Site may occasionally display advertising content from partners on our Site. When we do so, we may use basic data about your visit (such as cookie identifiers or page context) to ensure that the ads are effectively served and to prevent showing the same ad too many times. Any ads will be clearly identified, and any personal information used for ad delivery or personalisation will be handled as described in this Policy (see "Third-Party Analytics and Advertising" below). You have choices with regard to personalised ads: for example, Google allows users to opt-out of personalised advertising in their Google account settings, and the YourAdChoices website provides options to opt out of many ad networks. If required by law, we will obtain your consent before enabling advertising cookies or personalised ads.

Please note that third-party providers like Google may further process data for their own purposes as controllers (for example, for improving their services or benchmarking). We recommend you review Google's Privacy Policy to understand how they handle data. We remain committed to ensuring that any third-party services we use are compliant with relevant privacy laws and that appropriate data protection safeguards are in place when those services process personal data on our behalf.

Legal Basis for Processing Personal Data

For individuals in the European Economic Area (EEA), United Kingdom, and other regions with similar laws, we must have a valid legal basis to process your personal data. Depending on the context, our legal basis include:

Consent: We rely on your consent where applicable – for instance, when you allow non-essential cookies (such as analytics or advertising cookies) or when you voluntarily submit information into our tools for processing. You have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.

Performance of a Contract: When you use our Services (for example, using a web tool to process certain data), we treat this as a request to perform a service. We process your personal data as necessary to fulfill the service you have requested, which can be considered necessary for the performance of a contract or pre-contractual steps at your request. In other words, we use your data to provide you with the functionalities you seek from our Site.

Legitimate Interests: We may process personal data as needed for our legitimate interests, provided those interests are not overridden by your data-protection rights. Our legitimate interests include maintaining the security of our Site, understanding and improving how our services are used, and showing minimal advertising to support our services. For example, using basic usage analytics and logging (with privacy protections in place) may be based on our interest in efficiently operating and improving our platform. We will only rely on this basis after assessing that our legitimate interest is not outweighed by your privacy rights or interests.

Legal Obligation: In some cases, we must process and retain personal data to comply with a legal obligation. For example, if we are required by law enforcement or court order to retain certain data, or to comply with regulations (such as audit, tax, or reporting requirements under applicable law), we will do so on the basis of legal obligation.

We will clearly indicate where providing personal data is optional or based on consent. If you have questions about the legal basis of specific processing, feel free to contact us.

How We Share Your Information

We value your privacy and do not sell your personal information to third parties. We only share personal data in limited situations, described below, and with safeguards in place:

Service Providers (Processors): We use trusted third-party companies to support our operations – for example, cloud hosting providers, data storage services, analytics providers (such as Google Analytics), and email service providers. These third parties may process personal data on our behalf for the purposes described in this Policy. We ensure such providers are bound by contractual obligations to process personal data only under our instructions and to implement appropriate security measures.

Advertising and Analytics Partners: As noted, third-party advertising networks and analytics services may receive certain information automatically through their tracking technologies on our Site (e.g. they may receive your IP address or set their own cookies). These partners operate as independent controllers of that data in many cases (for example, Google may use data collected via Ads or Analytics for its own purposes). We do not share information that directly identifies you (such as your name or contact info) with these partners. We do, however, allow them to collect site usage information as described in the Third-Party Analytics and Advertising section for the purposes of providing their services to us. We also ensure any such partners are subject to appropriate privacy commitments.

Legal Compliance and Protection: We may disclose personal information to courts, law enforcement, government authorities, or other third parties when we believe disclosure is necessary (a) to comply with a law, regulation, or legal request; (b) to enforce our Terms of Service or other agreements; (c) to detect, prevent, or address fraud, security, or technical issues; or (d) to protect the rights, property, or safety of our users, the public, or our company. We will only disclose the minimum amount of information necessary and, when legally permissible, will inform you of such disclosures.

With Your Consent: In situations where you explicitly consent to or request a disclosure, we will share your information accordingly. For example, if you instruct us to share data with a third-party service, or you use functionality on our Site that by its nature shares information with others (such as posting content publicly or sharing a link containing information), we will do so with your direction and consent.

We do not otherwise share, rent, or sell personal data to third parties for their own marketing purposes.

Your Privacy Rights and Choices

You have certain rights regarding your personal information, which may vary depending on your location. We are committed to honoring the rights of users in all regions, and we provide mechanisms for you to exercise these rights (typically by contacting us at [email protected]). These rights include, at a minimum, the ability to access the personal information we hold about you and to request correction or deletion of that information.

Rights of Individuals in the EEA, UK, and Similar Jurisdictions (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with similar data protection laws, you have the following rights under the GDPR or UK GDPR:

Right to Be Informed: You have the right to be informed about the collection and use of your personal data. This Privacy Policy is one way we fulfill this right.

Right of Access: You can request confirmation of whether we are processing your personal data and obtain a copy of the data we hold about you. This allows you to know and verify the lawfulness of our processing.

Right to Rectification: If any of your personal data we have is inaccurate or incomplete, you have the right to request that we correct or update it.

Right to Erasure: You can ask us to delete your personal data in certain circumstances (the "right to be forgotten"). We will honor this request where applicable – for example, if the data is no longer necessary for the purposes it was collected, or if you withdraw consent and no other legal basis for processing applies, or if we processed the data unlawfully. Note that there are some exceptions to this right (such as when retention is required by law or necessary to establish or defend legal claims).

Rights of California Residents (CCPA/CPRA)

If you are a resident of California, you are protected by privacy rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) amendments. These rights include:

Right to Know: You have the right to request that we disclose the personal information we have collected about you, including the categories of personal information, the sources of that information, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it.

Right to Delete: You can request that we delete personal information that we have collected from you (and direct our service providers to do the same), subject to certain exceptions.

Right to Opt-Out of Sale or Sharing: We do not sell personal information for monetary consideration. In addition, the CPRA introduced the concept of "sharing" data for cross-context behavioral advertising. We do not knowingly engage in practices that would be considered a "sale" of personal information under CCPA, nor do we share personal information for targeted advertising outside the context of what is described in this Policy.

Rights of Canadian Users (PIPEDA)

If you are in Canada, our handling of your personal information is subject to Canada's federal privacy law (PIPEDA) or substantially similar provincial laws where applicable. We strive to adhere to PIPEDA's principles of accountability, transparency, and user control. Canadian individuals have the following rights:

Consent and Withdrawal of Consent: We will obtain your informed consent for the collection, use, or disclosure of your personal information, except where otherwise permitted by law. You have the right to withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Right of Access: You have the right to inquire whether we hold personal information about you and to access that information. Upon request, we will provide you with an account of your personal data in our possession and information about how it has been used and disclosed.

Exercising Your Rights (All Users)

Regardless of your jurisdiction, we welcome you to contact us with any requests or questions about your personal information. You can email us at [email protected] to:

• Request access to a copy of your personal data that we hold (if any)
• Ask for correction of any data that is inaccurate
• Request deletion of personal data, or object to a particular processing activity
• Withdraw any consent you have given (e.g., opt-out of analytics/advertising cookies by withdrawing consent, or unsubscribe from communications)
• Ask any questions about how we handle your personal data or privacy on our Site

AI Agents as Users

We recognise that our web tools and utilities may be used not only by human individuals but also by automated agents or AI systems acting on behalf of users or other entities. Privacy is a fundamental consideration for all interactions, whether initiated by a person or an AI. In this regard, we handle data from AI agents in line with this Privacy Policy:

If an AI agent provides data to our Service (for instance, an AI calls our tool and inputs some content or information), that data will be processed and protected in the same way as data provided directly by a human user. We do not distinguish between a human and a bot in terms of how data is secured or used.

We understand that AI agents might process personal data on behalf of someone. If you deploy an AI agent that interacts with our Services and it submits personal information (yours or others'), that information will be treated according to this Policy. For example: if an AI agent uploads a document containing personal details for analysis by one of our tools, we will treat that content as personal data provided to us and ensure it's handled securely and deleted when no longer needed, just as if you (a person) uploaded it directly.

Data Security

We take the security of your personal information seriously. We have implemented a variety of technical and organisational measures to protect your data from unauthorised access, loss, misuse, or alteration. These measures include encryption of data in transit (e.g., via HTTPS on our Site), firewalls and access controls to our servers, and internal policies to limit access to personal data on a need-to-know basis. We also ensure our service providers employ appropriate security standards. For example, our hosting providers and third-party services are carefully selected for their security practices.

Despite our efforts, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. In the unlikely event of a data breach that poses a significant risk to your rights (such as a breach resulting in unauthorised access to personal data), we will notify you and the relevant authorities as required by law. We also continuously review and update our security practices to tackle new threats and to ensure the ongoing confidentiality, integrity, and availability of our systems and data.

Children's Privacy

Our Services are not directed to children, and we do not knowingly collect personal information from individuals under the age of 13 (or a higher age threshold if applicable in certain jurisdictions, such as 16 under the GDPR without parental consent). If you are under the age of 13, please do not use our Site or provide any personal data to us. If we become aware that we have inadvertently collected personal information from a child under 13 without proper consent, we will take steps to delete that information as soon as possible.

Parents or guardians: if you believe that your child under 13 (or under the relevant age of consent in your region) has used our Site and provided personal information, please contact us at [email protected]. We will work with you to investigate and remove any such information. We encourage parents and legal guardians to supervise their children's internet usage and to help enforce this Privacy Policy by instructing their children never to provide personal information on this Site without permission.

Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will revise the "Effective Date" at the top of this Policy. If the changes are significant, we will provide a more prominent notice (such as by posting a notice on our homepage or, if we have your email contact, by emailing you) to inform you of the updates. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

Your continued use of the Site or our Services after any changes to this Policy constitutes acceptance of the revised terms, to the extent permitted by law. If we seek to use your personal information for a new purpose not originally disclosed to you, we will obtain your consent as required.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Barranjoey Capital Pty Limited (Dotty.cc)
Level 2, Westfield Chermside
Kittyhawk Drive, Chermside, QLD 4032
Australia

Email: [email protected]