Leisure Technologies Pty Ltd trading as WiTi

Effective Date: 1 April 2026 • Version 1.0

ABN 48 625 304 154

1. Introduction

Leisure Technologies Pty Ltd (ABN 48 625 304 154), trading as WiTi (“we”, “us”, or “our”), is committed to protecting the privacy of individuals who use our GPS tracking and telematics services (“Services”). This Privacy Policy explains how we collect, use, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy applies to all products and services we offer, including hardware devices, software platforms, mobile applications, and associated subscriptions.

2. What Information We Collect

2.1 Information You Provide

We collect personal information you provide directly to us, including:

• Name, email address, phone number, and billing address
• Business name, ABN, and contact details
• Payment information (processed securely via our payment provider; we do not store full card details)
• Account login credentials
• Communications and correspondence with our support team

2.2 GPS and Location Data

Our core Services involve the collection of GPS location data from tracking devices. This may include:

• Real-time and historical location data of tracked assets or vehicles
• Speed, heading, and movement data
• Geofence alerts and trip history
• Device status and diagnostic information

Where tracking devices are associated with individuals (e.g., drivers), GPS location data may constitute personal information. You are responsible for ensuring appropriate notice and consent is provided in accordance with applicable law.

2.3 Technical and Usage Data

We may automatically collect technical information when you access our platforms, including:

• IP address, browser type, and operating system
• Pages visited, features used, and session duration
• Device identifiers and app usage data
• Cookies and similar tracking technologies (see Section 8)

3. How We Use Your Information

We use the personal information we collect to:

• Provide, operate, and maintain the Services you have subscribed to
• Process payments, manage billing, and send invoices and renewal notices
• Authenticate users and manage account access
• Communicate with you regarding your account, service updates, and support requests
• Send promotional communications (only with your consent; you may opt out at any time)
• Monitor, analyse, and improve our Services and platforms
• Detect and prevent fraud, unauthorised access, and security incidents
• Comply with legal obligations and enforce our Terms of Service

4. Disclosure to Third Parties

4.1 Service Providers

We may disclose personal information to third-party service providers who assist us in delivering the Services, including:

• Mapping and geolocation providers (e.g., Google Maps, HERE, OpenStreetMap)
• Telematics data processing and analytics platforms
• Cloud hosting and infrastructure providers
• Payment processors and billing platforms
• Customer support and communication tools
• Email and SMS notification services

These providers are authorised to use your information only as necessary to provide services to us and are required to maintain appropriate security standards.

4.2 Legal and Regulatory Disclosure

We may disclose personal information where required or permitted by law, including to government agencies, regulatory bodies, courts, or law enforcement authorities.

4.3 Business Transfers

If we merge with, acquire, or are acquired by another entity, personal information may be transferred as part of that transaction. We will notify you of any such transfer and any material changes to this Policy.

4.4 No Sale of Personal Information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

5. GPS Data and Tracking

GPS location data is central to our Services. We treat this data with heightened care:

• Location data is used only to provide and improve the Services you have engaged us for
• Location data is not disclosed to third parties other than as described in Section 4 or where you have expressly authorised us
• Historical location data is retained in accordance with Section 7 of this Policy

If you deploy tracking devices to monitor individuals (such as employees or contractors), you must comply with all applicable workplace monitoring laws, including obtaining any required consent and providing appropriate notice.

6. Cross-Border Data Transfers

Our infrastructure and some third-party providers may be located outside Australia, including in the United States and the European Union. Where we transfer personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, including relying on contractual protections or equivalent overseas frameworks.

7. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law:

• Account information is retained for the duration of your subscription and for 7 years after termination for legal and compliance purposes
• GPS and location data is retained for up to 12 months by default; extended retention may be available on request
• Billing and transaction records are retained for 7 years as required by Australian tax law

When personal information is no longer required, we securely delete or de-identify it.

8. Cookies and Tracking Technologies

Our websites and applications may use cookies, web beacons, and similar technologies to enhance your experience, analyse usage, and deliver relevant content. You can manage your cookie preferences through your browser settings. Disabling cookies may limit some functionality of our platforms.

9. Security

We implement commercially reasonable technical and organisational security measures to protect personal information from loss, misuse, unauthorised access, disclosure, alteration, and destruction. These include encrypted data transmission (TLS/HTTPS), access controls, secure cloud infrastructure, and regular security assessments.

No data transmission over the internet is completely secure. While we take steps to protect your information, we cannot guarantee absolute security.

10. Your Privacy Rights

Under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or outdated personal information
• Make a complaint about how we have handled your personal information
• Opt out of direct marketing communications at any time

To exercise any of these rights, please contact our Managing Director using the details in Section 14. We will respond within 30 days.

11. Complaints

If you believe we have not complied with the Australian Privacy Principles or this Policy, please contact us in the first instance. We will investigate and respond within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

12. Children’s Privacy

Our Services are not directed to children under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected such information, we will take steps to delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. We will notify you of material changes by email or by posting a notice on our website. The effective date at the top of this Policy will be updated accordingly.

14. Contact Us

For any privacy-related enquiries, access requests, or complaints, please contact our Managing Director:

Managing Director

Leisure Technologies Pty Ltd (trading as WiTi)

37 Royal Scot Loop, Currambine WA 6028

Sales: sales@witi.com.au

Website: witi.com.au

This Privacy Policy was last updated on 1 April 2026.