CROOZN Privacy Policy

CROOZN is a road-safety and driver-education web app operated by Nexefy Pty Ltd. This policy explains what information we collect when you use CROOZN, why we use it, who we share it with, and the choices available to you.

1. Who we are

CROOZN is built and operated by Nexefy Pty Ltd (ABN 48 660 650 135) (“Nexefy”, “we”, “us” or “our”).

Our registered office is Suite 1.11, The Precinct, 315 Brunswick Street, Fortitude Valley QLD 4006, Australia.

This policy applies to the CROOZN website and web app, including CROOZN Daily (together, the “Services”). It applies whether you use CROOZN as a guest or through an account.

2. Information we collect

We collect different information depending on how you use CROOZN. You can use parts of the Services without creating an account.

2.1. If you use CROOZN as a guest

• A randomly generated identifier that lets the web app recognise the same guest session or browser without using your name.
• Gameplay information, such as the challenges attempted, answers selected, time taken, hints used and incorrect attempts.
• Technical and usage information, such as browser type, device type, pages viewed, timestamps, diagnostic information and an approximate location derived from your internet connection. We do not collect precise GPS location.

2.2. If you create or use an account

We collect the guest information described above and:

• Your email address and account authentication information.
• Limited information received from Google or Facebook if you choose social sign-in, such as your email address, display name or provider account identifier, depending on the provider and the permissions you approve. We only retain what is needed to authenticate you and manage your CROOZN account.
• Your streak, completion history and progress across challenges.
• Information you provide when you contact us, ask for support or make a privacy request.

We do not intentionally collect financial information, government identifiers, health information or other sensitive information through the Services. Please do not send us sensitive information unless we specifically ask for it and explain why it is needed.

3. How we collect information

We collect information directly from you when you create an account, sign in or contact us. We also collect gameplay and technical information automatically through the web app, cookies, local storage and similar technologies. If you use social sign-in, we receive limited account information from the provider you select.

4. How we use information

We use personal information to:

• create, authenticate and manage your CROOZN account;
• run challenges, preserve your progress and calculate streaks;
• keep the Services secure, reliable and working as intended;
• understand how people find and use CROOZN, troubleshoot problems and improve the experience;
• communicate with you about your account, support requests, security matters or important changes to CROOZN;
• prevent misuse and enforce our Terms of Use; and
• comply with legal obligations and respond to lawful requests.

We do not use personal information to make automated decisions that have a legal or similarly significant effect on you. We do not use account or gameplay information for targeted advertising.

5. Analytics, partners and de-identified information

We use Google Analytics to understand matters such as how people find CROOZN, which pages and challenges are used, and general engagement patterns. Google Analytics may use cookies or similar technologies and may receive technical and usage information.

We may provide insurers, automotive organisations, sponsors or road-safety partners with aggregated or de-identified insights. These insights may describe patterns across groups of users, such as completion rates or common challenge responses. We do not provide these partners with information that identifies an individual, and we do not sell personal information.

We may retain and use information that has been aggregated or de-identified so that it no longer reasonably identifies you, including for research, product improvement and partner reporting.

6. When we share information

We may disclose personal information to:

• service providers that support authentication, hosting, databases, security, customer support and analytics, including Supabase, Amazon Web Services and Google;
• Google or Meta when you choose to use their sign-in service;
• professional advisers and authorities where reasonably necessary to protect rights, investigate misuse, comply with law or respond to valid legal processes; and
• a buyer, investor or successor if Nexefy is involved in a merger, acquisition, financing, reorganisation or sale of assets, subject to appropriate confidentiality and privacy protections.

We require service providers to handle information only for the services they provide to us and to protect it appropriately.

7. Overseas processing and disclosure

We operate from Australia, but some providers used for authentication, analytics, hosting and technical operations may store or process information in the United States. Information may also pass through global infrastructure operated by those providers.

Where the Australian Privacy Principles apply, we take reasonable steps to ensure overseas recipients handle personal information consistently with applicable Australian privacy requirements.

8. Children and young people

CROOZN is designed to be useful to young people, including pre-driver learners aged 14 to 16. A person must be at least 13 years old to create a CROOZN account. Young people aged 13 or older may create their own account.

We apply additional care to information about younger users:

• we limit collection to information reasonably needed to provide and improve CROOZN;
• we do not use younger users’ information for targeted advertising or direct marketing;
• we do not sell personal information; and
• we share partner insights only in aggregated or de-identified form.

Parents, guardians and young users may contact us to ask what information we hold, request a correction or request deletion. We may need to verify the requester and, where appropriate, the relationship between a parent or guardian and the young person.

9. Cookies and similar technologies

CROOZN uses cookies, local storage and similar technologies to keep you signed in, remember challenge progress and streaks, maintain security and understand use of the Services. Some are necessary for CROOZN to function; others support analytics.

You can control or delete cookies through your browser settings. Blocking some technologies may prevent sign-in, progress tracking or other parts of CROOZN from working correctly.

10. Storage, security and data breaches

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These steps include access controls and encryption where appropriate.

No online service can guarantee absolute security. If an eligible data breach occurs, we will assess and respond to it and, where required, notify affected individuals and the Office of the Australian Information Commissioner under the Notifiable Data Breaches scheme.

11. How long we keep information

We retain account information while your account is active and for as long as reasonably needed to provide the Services, meet legal obligations, maintain security, resolve disputes and enforce agreements.

If you close your account or ask us to delete it, we will delete or de-identify personal information within a reasonable period unless we are legally required or otherwise permitted to retain it. Aggregated or de-identified information may be retained for longer because it no longer reasonably identifies you.

12. Access, correction and complaints

You may ask to access personal information we hold about you or request that inaccurate, out-of-date, incomplete, irrelevant or misleading information be corrected. You may also ask questions, request deletion or make a privacy complaint.

Contact us using the details below. Please describe your request and provide enough information for us to identify you and the relevant records. We may need to verify your identity. We aim to acknowledge and respond to privacy complaints within a reasonable period, generally within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au.

13. Changes to this policy

We may update this policy as CROOZN, our providers or applicable laws change. We will post the current version with a revised last-updated date. If a change materially affects how we handle personal information, we will provide reasonable notice through the Services or by email where appropriate.

14. Contact us

Privacy enquiries, access or correction requests, deletion requests and complaints can be sent to:

Email: systems@croozn.com

Post: Nexefy Pty Ltd, Suite 1.11, The Precinct, 315 Brunswick Street, Fortitude Valley QLD 4006, Australia