Ainstein Privacy Policy

Last updated: 13 April 2026

In this Privacy Policy, 'us' 'we' or 'our' means ROI-AI Limited, (New Zealand company number 7836996) -- trading as Ainstein, a company registered in New Zealand. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information.

In this Privacy Policy 'You' may refer to either:

• Our Customers; or
• Prospective job seekers of our Customers (Job Seekers)

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

1. Definitions

In this Privacy Policy, the following capitalised terms have the following meanings:

Data Protection Laws mean the Privacy Act 1988 (Cth -- Australia), the GDPR and the UK GDPR.

GDPR means the General Data Protection Regulation (EU) 2016/679 and national laws implementing or supplementing it.

Non-personal Information means information that does not relate to a person and/or cannot be used to identify a person.

Online Platform means any website, application, platform, software, landing page, plugin, API or any other digital product, interface or service offered by us.

Personal Information means any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

Products mean any goods or services offered by us, which may include the provision of any Online Platform.

Services mean the provision of the Online Platforms and any other goods or services offered through the Online Platforms or by us on a payment or free-of-charge basis.

UK GDPR means the UK Data Protection Act 2018 and the UK General Data Protection Regulation.

User, you or your means any person using or registering on the Online Platforms whatsoever.

2. What Personal Information do we collect?

If you are a Customer of our Service, then we collect information about you and your interactions with us, for example, when you purchase or use any of our Services, communicate with us, interact with any of our Online Platforms or otherwise visit our website. This usually includes (without limitation) the following Personal Information:

1. your name and contact information such as email address, phone number and area code;
2. name of your organisation (if applicable);
3. history of purchases and use of our Services and details of enquiries or complaints you make; and
4. any Personal Information that is provided to us or uploaded onto our Online Platform by our clients so that we can provide the Services to them.

If you are a Job Seeker then we collect information about you from online public sources and interactions of our clients with us, including:

1. Name, email address (which we may infer) and sometimes mobile number;
2. Current employer and employment history;
3. Current and previous job titles;
4. Performance data (e.g. if emails sent to you bounced or a reply was received).

Information we automatically collect:We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Online Platforms ("Automatic Data"). Automatic Data includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address), characteristics about your access device and/or browser, statistics on your activities on the Online Platforms, details of the Products we have supplied to you or that you have enquired about, including any additional information necessary to deliver those Products and respond to your enquiries, or information about how you came to the Online Platforms. We collect Automatic Data based on your consent which was granted to us by you when you registered as a user and accepted this Privacy Policy.

Information we obtain from others: We may also collect or receive Personal Information from third-party sources, such as other users, suppliers, social media or other third-party integrations.

Non-Personal Information: When you interact with the Online Platforms, we may collect Non-Personal Information. The limitations and requirements of this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Information do not apply to Non-Personal Information. When you register to the Online Platforms or otherwise submit Personal Information to us, we may associate other Non-Personal Information (including Non-Personal Information we collect from third parties) with your Personal Information. At such instance, we will treat any such combined data as your Personal Information until such time as it can no longer be associated with you or used to identify you.

3. Why do we collect, use and disclose Personal Information?

We may collect, hold, use and disclose your Personal Information for the following purposes:

1. provide our clients with the Services and access to the Online Platforms. Our core Service is providing Job Seeker information and contact details to our clients to assist them in targeting potential job seekers for new employment opportunities. A key part of the Service is our Online Platform's ability to filter contacts effectively by sector and role;
2. manage our clients' use of the Services;
3. to send our Customer's service, support and administrative messages, reminders, technical notices, updates and security alerts;
4. to operate, protect, improve and optimise our Services, business and our users' experience, such as to perform analytics and conduct research;
5. to send our Customer's marketing and promotional messages and other information that may be of interest to them;
6. to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
7. to comply with our legal obligations, resolve any disputes that we may have with any of our Customers or Job Seekers, and enforce our agreements with third parties.

Automated Processing: The Online Platform is an AI-powered solution that enables our Customers to activate, organise, and utilise Job Seeker data within AI applications. Job Seeker information, including Personal Information, may be processed automatically by us to provide the Services to our Customers. You acknowledge and agree to this automated processing and understand that it is a core part of our Service.

Our AI-powered platform may perform automated processing including data transformation, classification, entity extraction, pattern recognition, and query responses generated by large language models. These processes are essential to the functionality of our Services.

Ainstein may also allow Customers to log in to certain of our Online Platforms using sign-in services such as Facebook Connect. These services will authenticate Customer identity and provide Customers the option to share certain Personal Information with us such as your name and email address to pre-populate our sign-up form.

4. To whom do we disclose your Personal Information?

Job Seekers

We may disclose the Personal Information collected to our Customers as part of our Services. Our Customers can use our Services to find job seeker prospects that are relevant to them and then transfer your business contact details to their own systems for use in their own marketing to you.

Our Customers are then directly responsible to you for their lawful use of your data.

Customers and Job Seekers

For us to provide the Services, we may disclose Personal Information for the purposes described in this Privacy Policy to:

1. our employees and staff members;
2. our related bodies corporate;
3. third-party suppliers and service providers who are relevant for our provision of the Services to you;
4. our professional advisers, dealers, stakeholders and agents;
5. our sponsors or promoters of any competition that we conduct via our Services;
6. anyone to whom our assets or businesses (or any part of them) are transferred;
7. anyone you have specifically agreed can receive Personal Information, or where such consent can be reasonably inferred from the circumstances; and/or
8. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

5. Do we use your personal information for marketing?

If you are a Customer or a prospect of Ainstein we will use your Personal Information to offer you Services we believe may interest you, but we will not do so if you tell us not to. These Services may be offered by us, our related companies, our other business partners or our service providers.

If you are a Job Seeker then we will not send you marketing communications ourselves, but our Customers may do so.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

6. Using our Online Platforms and cookies

We may collect Personal Information about you when you use and access our Online Platforms. While we do not use browsing information to identify you personally, we may record certain information about your use of our Online Platforms, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We also use cookies, web beacons and other tracking technologies to collect certain information about your equipment, browsing actions, and patterns.

What are cookies and web beacons?

Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors to their websites. A cookie contains a unique number, which is used to recognise your computer or mobile device when you return to our Online Platforms. Cookies can remain on your computer or mobile device for different periods of time. The cookies can be either "persistent" cookies or "session" cookies. Persistent cookies are stored by a web browser and remain valid until a set expiration date. Session cookies only exist while your internet browser is open and are automatically deleted once you close your browser.

Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files contained on pages of websites that permit companies to count users who have visited certain webpages on a website and are used for other related website statistics (e.g., recording the popularity of certain website content and verifying system and server integrity).

What do we use cookies and web beacons for?

We use a variety of cookies, web beacons and other tracking technologies for different purposes. Specifically, we use cookies and web beacons to enhance the experience of our visitors to our Online Platforms (for example, by remembering your preferences and letting you navigate between pages efficiently) and to better understand how our Online Platforms are used.

We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered Personal Information. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.

What types of cookies and web beacons are used by us?

We use both first-party and third-party cookies and web beacons. There are four categories of cookies and web beacons used by us:

1. Essential cookies, web beacons and other tracking technologies are necessary for the operation of our Online Platforms.
2. Performance cookies, web beacons and other tracking technologies collect information about how you have used our Online Platforms.
3. Functionality cookies, web beacons and other tracking technologies allow us to remember how you are logged into our Online Platforms.
4. Advertising cookies, web beacons and other tracking technologies are used by our third-party service providers to deliver advertising to you on other third-party websites.

What are your choices about cookies?

It is your choice as to whether or not to accept cookies. Most browsers allow you to configure the browser settings so that cookies from websites cannot be placed on your computer or mobile device. If you would like further information about cookies and how to manage and delete them, please visit www.allaboutcookies.org or www.youronlinechoices.eu.

7. How do we store and hold Personal Information?

We hold your Personal Information in electronic form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.

8. Processing and transfer of your Personal Information

Your information, including Personal Information, is processed at our operating office in Australia and in any other places where our staff members are located or where subprocessing takes place, which may include the United States for AI processing.

For UK and EU residents we process your Personal Information primarily in UK servers, but there might be access from New Zealand or Australia for technical support purposes.

Depending on where you are located, this may mean that your Personal Information is transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

We will take steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organisation or a country unless there are adequate controls in place including the security of your data and Personal Information.

If you are a UK or EU resident then we have in place appropriate transfer mechanisms to protect your Personal Information.

9. Retention

Ordinarily, we will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. If you are a registered user for any Online Platforms, then we usually will retain your Personal Information as long as you maintain your account and for a period of 12 months following the account's closure.

You may close your account by contacting us. However, we may sometimes retain Personal Information for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

If a Customer of Ainstein has uploaded your Personal Information onto our Online Platform to use our Services, then our client has control over the retention period.

If you are a Job Seeker, then we will hold your Personal Information for as long as it continues to be accurate (e.g. you change jobs), and then we will update it.

10. Exclusions

Links: Our Online Platforms may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another user or visitor through the Online Platforms or through any other means, or information posted by you to any public areas of the Online Platforms.

11. Accessing or correcting your Personal Information

You can access the Personal Information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.

If you think that any Personal Information we hold about you is inaccurate, please email us and we will take reasonable steps to ensure that it is corrected.

We will consider and respond to all requests in accordance with all applicable laws.

12. GDPR Privacy

To the extent that the GDPR or UK GDPR applies to us and your Personal Information, this clause applies.

Legal Basis for Processing Personal Information under GDPR

We may process Personal Information under the following conditions:

1. Performance of a contract: Provision of Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
2. Legitimate interests: Processing Personal Information is necessary for the purposes of the legitimate interests pursued by us which is not outweighed by undue prejudice to you.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Information is a requirement necessary to enter into a contract.

Your Rights under the GDPR

We undertake to respect the confidentiality of your Personal Information and to guarantee you can exercise your rights.

If your Personal Information has been uploaded to our Online Platforms by our Customers then you should contact our clients to exercise your GDPR rights.

If you are a Job Seeker then you have the right under this Privacy Policy, and by law if you are within the EU or the UK, to:

1. Request access to your Personal Information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request the deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the Personal Information we hold about you.
2. Request correction of the Personal Information that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
3. Object to processing of your Personal Information. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to our processing of your Personal Information on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
4. Request erasure of your Personal Information. You have the right to ask us to delete or remove Personal Information when there is no good reason for us to continue processing it.
5. Request the transfer of your Personal Information. We will provide to you, or to a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Exercising your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, if you are in the UK, please contact the Information Commissioner Office (ICO).

13. Making a complaint

If you think we have breached your local privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can contact us. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact your local regulator (Australia: the Office of the Australian Information Commissioner (www.oaic.gov.au), and the UK: Information Commissioner's Office (www.ico.org.uk)) for guidance on alternative courses of action which may be available.

14. Contact Us

For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us at: privacy@roi-ai.com

Effective: 1 April 2026 | Version: 2.0