Privacy Policy

Version dated July 20, 2026

1. General provisions

This Privacy Policy has been developed in accordance with the Privacy Act № 119 1988 and the Australian Privacy Principles (the «APPs»).

It sets out how ALFABET LABS FZCO, a company duly registered under the laws of UAE (legal address: Unit №: O5-PF-CWC126, Detached Retail O5, Plot No: Level No 1, Jumeirah Lakes Towers, Dubai, United Arab Emirates) (referred to in this Privacy Policy as «we», «us», «our», or «Company») handles Personal Information.

We are committed to upholding the rights and freedoms of individuals when handling their Personal Information, including the protection of the right to privacy and confidentiality.

This Privacy Policy applies to our operations where we have an «Australian link», including where we carry on business in Australia or collect Personal Information within Australian territory.

This Privacy Policy applies to all Personal Information we collect through our Mobile Application, as well as other services we own or provide that link to this Privacy Policy.

2. Key definitions used in this Privacy Policy

Handling of Personal Information - any action or set of actions performed with or without the use of automation tools in relation to Personal Information, including collection, storage, use, disclosure, cross‑border disclosure, access, correction, destruction, de‑identification, and the implementation of security measures.

Personal Information - information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is recorded in a material form. This includes, but is not limited to name, address, phone number, email address, etc.

Sensitive Information - information or an opinion about an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or practices, criminal record, health information, genetic information, and biometric information that is to be used for the purpose of automated biometric verification or biometric identification.

User - an individual who uses our Mobile Application and whose Personal Information we handle in accordance with this Privacy Policy.

Mobile Application - the software application named «Alfalabs» available to Users through application stores (App Store and Google Play), subject to the terms of this Privacy Policy. The Mobile Application is for informational purposes and is designed for mobile devices running on Android and Apple iOS operating systems.

Applicable Law - the Privacy Act № 119 1988 and the Australian Privacy Principles.

3. Scope of the Privacy Policy and categories of Personal Information

We only handle Personal Information that falls under the category of «general Personal Information» (for example, full name, phone number, email address, etc.) and only in circumstances where:

(a) We have obtained your consent to the handling, which is voluntary, specific, and informed.

(b) We need the Personal Information to perform our obligations to you.

(d) Or the handling is reasonably necessary for our functions or activities.

If we ask you to provide Personal Information, we will explain why we are asking for it, whether the provision is mandatory, and the possible consequences if you do not provide it. We do not handle Sensitive Information (as defined above) unless we have obtained your express consent, which is required under APP 3.3.

If we become aware that we have collected Sensitive Information without proper consent, we will delete it within a reasonable period.

Handling of information about children

For individuals under 15 years of age, we do not rely on consent as the basis for handling. Instead, we rely on other lawful bases (such as the handling being reasonably necessary for our functions or activities), or we seek consent from a person with parental responsibility. For individuals aged 15 years or older, there is a presumption that they have the capacity to understand the nature of the handling and can provide their own consent, unless proven otherwise.

4. Methods of handling Personal Information

We handle Personal Information that has been lawfully obtained by us on lawful grounds through the Mobile Application, other services we own or provide that link to this Privacy Policy, as well as through exchanges of messages between you and us using email and/or phone.

Personal Information is handled with or without the use of automation tools, using the following methods:

Collection
Storage
Recording
Accumulation
Systematisation
Updating (renewal, modification)
Disclosure (provision, access) to third parties
Use within the organisation
Deletion
Blocking (restricting access)
Destruction
Extraction

5. Purposes of handling Personal Information

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

Purpose of handling	Types of Personal Information handled	Categories	Methods and duration of handling
User registration in the Mobile Application and subsequent identification and authentication for the purpose of granting access to the Mobile Application	General Personal Information (not Sensitive Information as defined in Section 6(1) of the Privacy Act № 119 1988) Personal Information: surname, given name(s) phone number date of birth	Users of the Mobile Application	Personal Information is handled using automated means Duration: until the purpose of handling has been fulfilled, or until you withdraw your consent (where applicable), or as required or authorised by or under Australian law
Establishing feedback with the User, including sending notifications, requests regarding the use of the Mobile Application, and processing User enquiries and requests through the online chat or email	General Personal Information (not Sensitive Information as defined in Section 6(1) of the Privacy Act № 119 1988) Personal Information: surname, given name(s) email address phone number date of birth address ID/passport details social media account details instant messaging account details	Users of the Mobile Application	Personal Information is handled using automated means Duration: until the purpose of handling has been fulfilled, or until you withdraw your consent (where applicable), or as required or authorised by or under Australian law
Providing User support when issues arise in connection with the use of the Mobile Application	General Personal Information (not Sensitive Information as defined in Section 6(1) of the Privacy Act № 119 1988) Personal Information: surname, given name(s) email address phone number	Users of the Mobile Application	Personal Information is handled using automated means Duration: until the purpose of handling has been fulfilled, or until you withdraw your consent (where applicable), or as required or authorised by or under Australian law
Subscription to the Company's news and updates	General Personal Information (not Sensitive Information as defined in Section 6(1) of the Privacy Act № 119 1988) Personal Information: email address	Users of the Mobile Application	Personal Information is handled using automated means Duration: until you unsubscribe or withdraw your consent, or until the purpose of handling has been fulfilled

6. Disclosure of Personal Information to third parties

We may disclose your Personal Information to third parties in the following circumstances:

to our service providers and contractors who assist us in operating our business (for example, cloud hosting providers, analytics platforms, and customer support services);
to law enforcement or regulatory bodies where required or authorised by law;
to our professional advisers (including lawyers and accountants);
to any person or entity with your consent.

Before we disclose Personal Information to a third party, we take reasonable steps to ensure that the recipient:

does not collect, use, or disclose the information for any purpose other than the purpose for which it was disclosed to them; and
complies with the Australian Privacy Principles or is subject to a substantially similar privacy regime.

7. Cross‑border disclosure of Personal Information

We may disclose Personal Information to recipients located outside Australia (including UAE, where our parent company is registered). When we do so:

We take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information (APP 8.1).
We require the overseas recipient to handle the information in a manner substantially like the requirements of the APPs (for example, through contractual obligations).
We notify you at the time of collection that your Personal Information may be disclosed overseas.

We do not disclose Personal Information to overseas recipients unless we are satisfied that the recipient has adequate privacy protections in place. We do not transfer health information.

8. Security of Personal Information

We take reasonable steps to protect the Personal Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure (APP 11.1). These steps include:

technical security measures (encryption, firewalls, access controls)
organisational measures (staff training, confidentiality obligations)
physical security measures (secure premises, locked filing cabinets)

We take reasonable steps to destroy or permanently de-identify Personal Information when it is no longer needed for any purpose for which it may be used or disclosed under the APPs (APP 11.2).

In the event of a data breach that is likely to result in serious harm, we will notify you and the OAIC in accordance with the requirements of the Privacy Act № 119 1988.

9. Access to and correction of Personal Information

You have the right to request access to the Personal Information we hold about you. We will respond to your request within a reasonable period and provide access in an appropriate and accessible manner. We may charge a reasonable fee to cover our costs in providing access, but we will not charge for the request itself.

If we refuse access, we will give you a written notice setting out the reasons for the refusal and the mechanisms available to complain about the refusal.

You have the right to request correction of the Personal Information we hold about you if it is inaccurate, out of date, incomplete, irrelevant, or misleading. We will take reasonable steps to correct the information in accordance with APP 13.

If we have corrected Personal Information that we previously disclosed to another organisation, and you request us to notify that organisation of the correction, we will take reasonable steps to give that notification unless it is impracticable or unlawful to do so.

If we refuse to correct the information as requested, we will give you a written notice setting out the reasons for the refusal and the mechanisms available to complain about the refusal. You may also request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant, or misleading.

To make a request for access or correction, please contact us using the details provided in Section 13 of this Privacy Policy.

10. Your rights and how to complain

Under the Privacy Act № 119 1988 and the Australian Privacy Principles, you have the right to:

Know what Personal Information we hold about you.
Know how we collect, use, and disclose your Personal Information.
Access your Personal Information.
Request correction of your Personal Information.
Make a complaint about our handling of your Personal Information.

If you have a complaint about our handling of your Personal Information, we ask that you:

Contact us first - please direct your complaint to us using the contact details in Section 13 of this Privacy Policy. We will acknowledge your complaint within a reasonable period and investigate it.
Escalate to the OAIC - if you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Contact details for the OAIC:

Website: www.oaic.gov.au
Phone: 1300 363 992
Postal address: GPO Box 5288, Sydney NSW 2001

11. Adoption, use or disclosure of Government related identifiers

We do not adopt, use, or disclose government related identifiers (such as Medicare numbers, driver's licence numbers, tax file numbers) as our own identifiers, except where required or authorised by Australian law (APP 9).

If we use a government related identifier for the purpose of verifying your identity, we do so only to the extent that it is reasonably necessary for our functions or activities.

12. Anonymity and pseudonymity

We give you the option of not identifying yourself, or of using a pseudonym, when dealing with us (APP 2), except where it is impracticable for us to provide our services to you, or it is required or authorised by Australian law.

13. Contact us

You can contact the Mobile Application administration regarding any questions related to Privacy Policy on: support-app@habitforgood.store, or by filling a contact form specified in a corresponding section of this Mobile Application. If you do not agree with this Privacy Policy, you cannot use the Mobile Application. In this case you should avoid using our Mobile Application.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated Privacy Policy on our website or through the Mobile Application, and by updating the «Version dated» at the top of this Privacy Policy. This Privacy Policy is valid indefinitely until replaced by a new version.

The current version of the Privacy Policy is publicly available at https://habitforgood.store/privacy/en/privacy-policy.html.

We encourage you to review this Privacy Policy periodically.