Privacy Policy
Last updated: 4 June 2026
The Adjudicator ("**The Adjudicator**", "**we**", "**us**", "**our**") is a division of **Paintseal Australia Pty Ltd** (ABN: [INSERT ABN — Jonathan to supply before publishing]), based in Perth, Western Australia. We provide a pre-audit warranty adjudication platform (the "**Platform**") to business customers such as warranty underwriters, insurers, and original equipment manufacturers (OEMs).
We are committed to protecting your privacy and handling personal information in accordance with the **Privacy Act 1988 (Cth)** and the **Australian Privacy Principles (APPs)**.
This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in connection with our website useadjudicator.ai (the "**Website**") and our business operations. It also explains how we handle data when we process it on behalf of our business customers. By using our Website or engaging with us, you agree to the handling of your personal information as described in this Policy.
2. Two kinds of data we handle
It is important to distinguish between two roles we play:
**(a) When we act for ourselves (data controller).** In relation to our Website visitors, enquirers, business contacts, and suppliers, we determine how and why personal information is handled. This Policy governs that information.
**(b) When we act on behalf of a customer (data processor).** When a business customer (such as an insurer or OEM) uses the Platform to process warranty claims, that customer is the controller of any personal information involved, and we act as a processor on their behalf, under our agreement with them. In those cases, the customer's own privacy policy governs that information, and our handling is governed by our customer agreement and Data Processing Agreement. Where possible, the Platform is designed to operate on de-identified data, so that personal information is minimised or not required for the adjudication function.
3. What personal information we collect
Depending on how you interact with us, we may collect:
➔ **Contact and identity information** — name, email address, phone number, job title, employer, and business address (e.g. when you make an enquiry, request a demonstration, or correspond with us).
➔ **Business and commercial information** — details relevant to a potential or actual commercial relationship.
➔ **Website and technical information** — IP address, browser type, device information, pages visited, and similar analytics data collected automatically when you use the Website (see Cookies, below).
➔ **Communications** — records of correspondence and enquiries.
We do not seek to collect sensitive information (as defined in the Privacy Act) through the Website. Please do not send us sensitive information unless we specifically request it.
**Claims and Platform data:** When processing claims on behalf of a customer, the Platform handles vehicle, part, labour, and claim information supplied by that customer. This is handled in our role as processor (see section 2(b)) and, wherever possible, on a de-identified basis.
4. How we collect personal information
We collect personal information:
➔ Directly from you (e.g. when you contact us, request a demo, or enter into an agreement);
➔ Automatically through the Website (analytics and cookies);
➔ From our business customers (in our role as processor); and
➔ From third parties where you have consented or where otherwise permitted by law.
5. Why we collect and how we use personal information
We use personal information to:
➔ Respond to your enquiries and provide information you request;
➔ Provide, operate, maintain, and improve the Platform and our services;
➔ Manage our commercial relationships and communications; - Comply with our legal and regulatory obligations; and - Protect the security and integrity of our systems.
We will only use personal information for the purposes for which it was collected, for a reasonably related secondary purpose you would expect, or as otherwise permitted by law or with your consent.
6. Disclosure of personal information
We may disclose personal information to:
➔ Our service providers and contractors who assist us in operating our business and the Platform (including IT, hosting, and software providers — see Overseas section below);
➔ Our professional advisers (legal, accounting, insurance);
➔ A purchaser or potential purchaser of our business or assets;
➔ Government, regulatory, or law enforcement bodies where required or authorised by law.
We do not sell personal information.
7. Overseas storage and disclosure (cross-border)
Our Platform and business operations use cloud infrastructure and service providers that may store or process information outside Australia. In particular:
➔ **Data storage:** Platform data is stored in **Singapore**.
➔ **Processing:** certain processing functions, including hosting and AI-assisted document analysis, are currently performed using infrastructure located in the **United States**.
➔ Members of our technical team are located in the **Philippines** and may access systems to provide development and support services.
Where we disclose personal information overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles. Wherever possible, the Platform is designed to operate on **de-identified data**, reducing or removing the personal information involved in cross-border processing. For our business customers, specific data-location and handling arrangements are addressed in our Data Processing Agreement.
8. Cookies and Website analytics
Our Website may use cookies and similar technologies to operate the site, understand how it is used, and improve your experience. You can usually disable cookies through your browser settings, though some features of the Website may not function properly as a result. Our Website is built on the Wix platform, which uses essential and analytics cookies to operate and measure the site. If additional analytics tools are enabled, they will be listed here.
9. Data security
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including through secure infrastructure, access controls, and a locked audit log of activity within the Platform. No method of transmission or storage is completely secure, and while we strive to protect your information, we cannot guarantee absolute security.
In the event of a data breach likely to result in serious harm, we will comply with our obligations under the **Notifiable Data Breaches scheme** in the Privacy Act.
10. Retention of personal information
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, or to resolve disputes. When personal information is no longer required, we take reasonable steps to destroy or de-identify it. Data we process on behalf of customers is retained, returned, or destroyed in accordance with our agreement with that customer.
11. Accessing and correcting your information
You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading. To make a request, contact us using the details below. We will respond within a reasonable period and in accordance with the Privacy Act. There is generally no charge for making a request, though we may charge a reasonable fee for providing access in certain circumstances.
12. Complaints
If you have a concern or complaint about how we have handled your personal information, please contact us using the details below, and we will endeavour to resolve it. If you are not satisfied with our response, you may lodge a complaint with the **Office of the Australian Information Commissioner (OAIC)**:
➔ Website: www.oaic.gov.au
➔ Phone: 1300 363 992
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version will always be available on our Website, and the "Last updated" date will reflect the most recent changes. We encourage you to review it periodically.
14. Contact us
For any questions about this Privacy Policy or our handling of personal information:
**The Adjudicator — a division of Paintseal Australia Pty Ltd**
Privacy Officer
Email: sales@useadjudicator.ai
Phone: (08) 9355 0530
Perth, Western Australia