Privacy Policy

1.Background

Thanks for visiting our Privacy Policy (Policy), we are Quillx Pty Ltd ACN 700 644 668 (we, our, us and other similar terms). We are committed to providing quality products and services to you and this Policy outlines our ongoing obligations in respect of how we manage your Personal Information. It applies to the terms of use of our suite of artificial intelligence - powered chat and messaging products, agents and related services, collectively known as “Quillx” (Quillx), and other agreements we may form with you.

When we talk about Personal Information, we mean information or an opinion about an identifiable individual (not a company), whether or not that information or opinion is true or in a material form (Personal Information).

2.Disclaimer

While your privacy is important to us, nothing in this Policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

3.Collection of Personal Information

3.1How we collect Personal Information

We collect Personal Information in the ordinary course of our business, which is the provision of Quillx. Personal Information is collected when you:

(a)contact or correspond with us via email, telephone, social media, our website or any of our Quillx products through a supported messaging channel;

(b)subscribe to our newsletters or complete surveys and online forms;

(c)provide feedback regarding Quillx;

(d)subscribe to, use or interact with any one of our Quillx products; and/or

(e)seek support in relation to Quillx.

Information will otherwise only be collected directly from you when you engage with us or use Quillx, unless you authorise another person, to provide the information on your behalf.

3.2What Personal Information is collected?

The types of Personal Information we collect from you will depend on your interactions with us and which Quillx product you use. This may include your name, address, email, mobile or messaging telephone number, country, language, the content of the messages you send to and receive from our Quillx chatbots and agents, information and preferences you provide during your interactions with us directly or through Quillx, any device and technical identifiers such as your IP address and any additional information you provide to us.

Where you contact us on behalf of your employer or using work email addresses, the information you provide often contains information about your employment, position and employer’s contact details. In those circumstances certain employment information is collected.

Some of our Quillx products may also collect sensitive information including but not limited to information about your health, and information about your religious or philosophical beliefs. For example, our BibleJoy product may record your religious denomination or preferences in order to personalise responses, and a medication-related product may record the medication names, dosages and schedules that you provide. We only collect sensitive information when you use our Quillx products, where you consent to that collection and where it is reasonably necessary for our functions or activities as set out in this Policy.

By providing us with any Personal Information, you consent to us collecting and handling it as described in this Policy. If you do not want us to process this information according to this Policy, you should not provide us with such information, though this may limit how Quillx works for you.

3.3Children and young people

Quillx products are not intended for use by, or directed at, children under 13 years of age. We do not knowingly collect Personal Information from a child under 13. You should not provide us with the Personal Information of children unless you are authorised to provide it.

In all cases where we collect Personal Information we handle that information having regard to their capacity to understand the collection, to their best interests and according to applicable laws.

4.How we use Personal Information

4.1Why we collect Personal Information

We collect your Personal Information for the primary purpose of providing Quillx. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.

Examples of when we may use your Personal Information include:

(a)informing you about Quillx;

(b)providing you with Quillx;

(c)improving Quillx and developing new Quillx products, features and functionality;

(d)personalising responses and experiences in relation to Quillx;

(e)administration needs in relation to providing you with Quillx, including the administration of your account;

(f)dealing with requests, enquiries or complaints and other customer care related activities; and

(g)carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on us, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.

4.2Direct marketing

Where you provide us with consent to do so (e.g. if you have subscribed to our email or SMS lists or have indicated that you are interested in receiving offers or information from us), we may send you marketing communications by email and SMS about products and services that we feel may be of interest to you.

You can opt-out of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

4.3Surveys or market research

We (or an appointed third party) may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys will provide us with information that allows improvement in the type, quality and the manner in which our goods and services are offered to you.

You can opt out of participating in such surveys or market research using the facilities made available to you.

4.4Use of de-identified data

The data we collect may have analytical value to us, our business partners and our related entities. Such information may allow us to improve Quillx products and the quality of the outputs they generate. We reserve the right to process or distribute information we collect through our services. However, we will only distribute data which has been de-identified or otherwise in accordance with this Policy.

4.5Automated processing and artificial intelligence

Quillx uses third party language models to generate responses, power Quillx chatbots and agents and to interpret information you provide. When you interact with a chatbot or agent, a limited subset of your Personal Information, typically your most recent messages, a summary of your conversation and certain preferences, is provided to our artificial intelligence provider so that a response can be generated.

This means a computer program processes your Personal Information, including the messages you send and your profile details, to produce these outputs. These outputs are generated to support you and are provided as information and suggestions only. The responses our chatbots and agents generate do not decide anything about you. You decide what to do with the outputs. On this basis, we do not use Quillx to make automated decisions that produce legal effects for you, or that otherwise significantly affect your rights or interests.

5.Cookies and browser analytics

5.1What are cookies

Cookies are small text files that are placed on your computer by the websites you visit. They are processed and stored by your web browser. When you visit a website or engage with a business through social media, certain information is collected by cookies. This is generally anonymous information and it does not reveal your identity. In and of themselves, cookies are harmless and serve crucial functions. They are widely used in order to make websites work more efficiently and improve the user experience, as well as to provide information about the use of a website.

5.2Why we use cookies

By storing and using information about your use of our website, including preferences and habits, we are able to make your visit to our website more productive. For example, some cookies remember your language or preferences so that you do not have to repeatedly make these choices.

5.3We use the following types of cookies:

(a)Required cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that pass information from one web page to another and to use online forms.

(b)Analytical cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are able to find what they are looking for easily. We also use third party cookies, such as those provided via the Google Analytics service. The information passed back to such third party providers is anonymous.

(c)Marketing cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences. These cookies also record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and communications sent to you more relevant to your interests.

5.4How can I remove cookies

Your web browser can choose whether or not to accept cookies. Most web browser software is initially set up to accept them. If you do not want your browser to use cookies, you can manage and control their use through your browser, including removing cookies by deleting them from your "browser history" (cache) when you leave the site. However, if you choose to reject cookies some parts of our website may not work properly.

6.Data retention and security

6.1Security mechanisms we employ

Generally, we store your Personal Information using secure servers protected from unauthorised access, modification and disclosure. However, like most businesses, we hold some information on our staff’s computers (such as emails from you) and where necessary as hard copy files (such as printed invoices).

Subject to 7.2 (Offshore Transfers), our systems are located in Australia, Singapore and the United States and are managed by us and our service providers. Personal Information that we store or transmit is protected by technical security and access controls, including username and password authentication, multi-factor authentication, and data encryption (such as TLS) where appropriate.

We also implement organisational security measures to protect Personal Information. These include limiting staff access to Personal Information to what is reasonably necessary to operate the platform and maintaining confidentiality over Personal Information.

In our dealings with third party service providers, we take care to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

6.2How long we keep your Personal Information

We retain your Personal Information for as long as is necessary to provide Quillx, as required for our internal business operations, and to comply with our legal obligations. Because Quillx is designed to recognise returning users and to improve over time, we may retain your conversation history and associated Personal Information on an ongoing basis for these purposes and for quality assurance.

If we hold Personal Information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the Australian Privacy Principles (APPs) and the European Union General Data Protection Regulation (GDPR), unless we are prevented from doing so by law.

Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions associated with those records are completed.

If you no longer want us to use your Personal Information, you can request that we erase it and, where you have an account with us, close your account. Where possible we will do so in accordance with the APPs and GDPR. However, where you request the erasure of your Personal Information we will retain information as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations or requests by government, a court of law, or law enforcement authorities, enforce the terms of service and take other actions permitted by law. Any information we retain will be handled in accordance with this Policy.

7.Disclosure of your Personal Information

7.1Who we share your Personal Information with?

Your Personal Information may be disclosed to:

(a)our employees, a related company and our professional advisers (lawyers, accountants, financial advisers, etc.);

(b)regulators and government authorities in connection with our compliance procedures and obligations, including law enforcement agencies to assist in the investigation and prevention of criminal activities;

(c)a third party, in order to enforce or defend our rights, or to address financial or reputational risks;

(d)third party contractors, partners, suppliers and service providers with whom we have a business association, including:

(i)payment gateway providers, such as Stripe, Inc.

(ii)messaging and communications infrastructure providers (such as LoopMessage);

(iii)language model providers (such as Google, in respect of the Google Gemini model);

(iv)administration service providers;

(v)marketing service providers; and

(vi)information technology service providers, including cloud application providers and code repository providers .

(e)We will not disclose your Personal Information other than in accordance with this Policy without your consent.

7.2Offshore transfers

We may store or distribute your Personal Information to third party contractors, service providers and suppliers with whom we have a business association. Our engagement of service providers, such as those who operate cloud services, may have international data centres and disaster recovery sites. Consequently, these providers may have access to your information offshore including in Singapore and the United States of America. We rely solely on reputable organisations for such cloud services.

8.Anonymity and use of pseudonyms

If you contact us with a general enquiry, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the supply of goods or provision of services. You agree you will provide accurate information if we require it.

9.Access to Personal Information and corrections

We endeavour to only hold Personal Information that is accurate, complete and up-to-date. You have the right to make a request to access Personal Information which we hold about you and to request corrections of any errors in that data. To make an access or correction request, contact us using the contact details provided at the end of this Policy or by messaging the relevant Quillx chatbot and asking us to access, correct or erase your Personal Information.

If you have an account with us, you can access some of the Personal Information that we collect about you. By logging into your account, you can update or correct certain information.

In order to protect your Personal Information, when you contact us, we may require identification from you before releasing the requested information or making the correction.

10.Additional rights for EU residents and citizens

For the purposes of the GDPR, we are a ‘data controller’ of Personal Information. If you’re a citizen or resident of the European Economic Area, the following rights apply to you.

You are entitled to ask us to port your Personal Information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your Personal Information to comply with legal or contractual obligations, then provision of such data is mandatory and if you do not provide it then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In those cases, you must provide us with your Personal Information, otherwise the provision of requested Personal Information is optional.

If you have unresolved concerns, you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority in the country:

(a)of your habitual residence;

(b)of your place of work; or

(c)in which you consider the alleged infringement has occurred.

11.Communications and privacy concerns

Your privacy is important to us. If you have any complaints, concerns or questions about our handling of your Personal Information, we ask that you first contact our privacy officer whose contact details are listed below. We will investigate your complaint and reply to you in writing if you provide us with contact details and request us to do so.

Email: support@quillx.ai

Online: https://www.biblejoy.ai/contact

If, after we have conducted our investigations, you are still not satisfied, then we ask you to consult with the Office of the Australian Information Commissioner:

Email: enquiries@oaic.gov.au

Telephone: 1300 363 992 (from overseas +61 2 9284 9749)

Post: GPO Box 5218

Sydney NSW 2001

12.Variations to this Policy

We will need to change this Policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the Policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this Policy will always be available on this page.

This Policy was last updated on 17 August 2026.