隐私政策

1.0 OUR COMMITMENT
This privacy statement describes A Future Corporation Pty Ltd (A.C.N. 078 538 002, of Unit 1.19 999 Nepean Hwy, Moorabbin VIC 3189, Australia, referred herein as “Future Corporation”, “FC”, “AFC”, “our”, “ours”, “us” or “we”) information practices and the choices available to you regarding Future Corporation’s use of information that can be used to identify you (hereafter “Personal Data”).

1.1 COUNTRY SPECIFIC TERMS IN ADDITION/SUPPLEMENTAL TO THIS PRIVACY STATEMENT
For those terms in addition and/or supplemental to this privacy statement for residents in:

• California, USA – please see section 12.0 (below).
• China – please see section 13.0 (below).
• European Union – please see section 14.0 (below).
• United Kingdom – please see section 15.0 (below).
• India – please see section 16.0 (below).
• Australia – please see section 17.0 (below).

1.2 FUTURE CORPORATION GLOBAL INTERNET PRIVACY POLICY
It is Future Corporation’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our employees, customers, business partners and dealers, and others who share their personal information with us. This Global Internet Privacy Policy (the “Policy”) describes how Future Corporation protects your privacy when we collect personal information on Future Corporation Internet sites. As used in the Policy, Personal Data means information that identifies you personally, alone or in combination with other information available to us. The Policy applies, in general, to all Internet sites operated by or on behalf of Future Corporation and its business units worldwide (each a “Future Corporation Internet site”). The Policy also applies to Personal Data processed by Future Corporation in connection with the Software, licensing, accounts, purchases, Technical Support and associated services described in this Privacy Statement.

Please note that when you access any external links from this Internet site (including links to other sites), they may have different privacy policies specific to those sites. We encourage you to read all applicable privacy policies.

1.3 PRIVACY STATEMENTS
Although the Policy applies to all Future Corporation Internet Sites generally, each Future Corporation Internet Site has a different purpose and different features. If additional or different disclosures are required with respect to a specific Future Corporation Internet site, we will provide those disclosures on the site itself or in a separate website privacy statement (“Privacy Statement”) posted on that site. Each individual disclosure or Privacy Statement supplements and amends the Policy, but only with respect to the Future Corporation Internet site on which it is posted.

2.0 YOUR CONSENT
This Privacy Statement gives you notice of the ways in which your personal information may be collected, used and disclosed. By using any Future Corporation Internet site or providing personal information to us, you and any legal entity or entities you represent and/or are using the Internet Site on behalf of (referred collectively herein as “you” or “your”) acknowledge that your personal information may be handled as described in the Policy and any applicable Country or Privacy Statements. Where consent is the applicable lawful basis under the law that applies to you, we rely on your consent only to that extent, and you may withdraw it as described in this Privacy Statement. Other processing described in this Privacy Statement may occur without consent where it is necessary for: (i) the performance of a contract with you, or steps taken at your request before entering into a contract; (ii) compliance with legal obligations; (iii) legitimate interests recognised by applicable law, including the operation, licensing, security and support of our Internet sites and Software, fraud prevention and the enforcement of legal rights; or (iv) another lawful ground permitted in the relevant jurisdiction. NO AGREEMENT: If you do not agree to the handling of your personal information as described in the Policy (and any applicable Country or Privacy Statements), do not use Future Corporation Internet sites. Instead contact Future Corporation (See Contact Us below).

2.1 WHAT PERSONAL INFORMATION DO WE GATHER FROM THOSE WHO VISIT OUR SITE AND/OR USE OUR SOFTWARE PRODUCTS?
When you use our Internet sites or Software, information may be provided to Future Corporation in two principal ways: Personal Data that you knowingly provide to us, including when purchasing Software, creating or maintaining an account, registering a Software License, communicating with us or requesting Technical Support; and technical or Automatic Data generated or transmitted by the Software in connection with its operation, licensing, activation, validation, support, security and related functions, as follows:

2.1.1 PERSONAL DATA – THIS INCLUDES YOUR:

• Name
• Email address
• Time zone
• Password (you enter but we cannot access)
• Address (used for calculating taxes)
• Telephone number
• Payment and transaction information, such as payment method and type, transaction status, invoice details and payment-processor transaction references. Your credit-card and other payment credentials are held and processed by external payment providers and financial institutions; we do not store your credit-card information, and we cannot access or use your payment credentials to process a payment.

2.1.2 AUTOMATIC DATA GENERATED BY THE SOFTWARE
The Software (including its Windows and macOS applications and related components) may automatically generate or transmit the following technical information in connection with its operation, licensing, activation, validation, Technical Support, security and related functions described in this Privacy Statement and the Software License Agreement. This information may be transmitted to servers operated by or on behalf of Future Corporation. It includes:

• Date and time of relevant Software/server communications, activations, validations or other Software events
• Operating system/version
• Device hardware/version
• IP address associated with Software or server communication
• Software product/version and serial/license number
• Hardware, computer, and/or machine ID
• User ID
• Diagnostic and Performance Report information (statistical information produced by the Software when in use, which may be associated with a license, device or account identifier – see section 6.1 below)

This information may be combined with other personal information you have provided. The Software installed on your computer may communicate with servers operated by or on behalf of Future Corporation for the purposes described in this Privacy Statement and the Software License Agreement.

Future Corporation does not use cookies or similar website tracking technologies on its Internet Sites. Our Internet Sites do not use, request or require cookies, and we do not use analytics, performance, advertising or tracking cookies or services.

2.1.3 EMAIL
In several areas of our Internet sites, you also have an opportunity to communicate with us by email. You may also choose to provide your email address to receive communications from us or third parties. You may also opt out from certain email communications (see section 11.0 OPT IN/OPT OUT below).

3.0 HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information to transact and communicate with you, if and when necessary, in connection with your use of our Internet site, process your orders, to respond to your questions, or to send you material and information you request. We may use your information to:

• Provide, operate and improve the content, products and services we make available to you, and deliver the product information you request.
• Process, provide details thereof, and assist you to track and manage your purchases.
• Inform you of upcoming payments that you are scheduled to make and/or when a payment fails.
• Consider your suggestions and feedback. Possibly respond directly to you for clarification.
• Process your request for materials and/or information if you make one.
• Try to and answer your questions if you ask them.
• Register you for Support and Membership to our various services/products if you request it.
• Provide you with email messages and other information regarding upcoming events, new services, Software updates, patches and upgrades and any other general information about our products and services.
• Provide, license, activate, validate and verify the Software and your Software Licenses, in accordance with the Software License Agreement.
• Provide Technical Support and related services.
• Administer billing, payments, subscriptions, instalments, non-payment and chargeback matters.
• Maintain security, prevent fraud, investigate suspected Software piracy, and enforce our legal rights.
• Comply with applicable law and lawful requests from courts, regulators and law-enforcement authorities.
• Operate diagnostic and Performance Reporting functions as described in section 6.1 (below) and the Software License Agreement.

We may also use technical records necessarily generated in the ordinary operation of our Internet sites to diagnose problems and/or faults with those sites.

Note: You may elect not to receive certain communications, either when you initially register at our site, or at any time thereafter. See section 11.0 Opt In/Opt Out (below).

3.1 ACCESS TO PERSONAL INFORMATION
You may review, correct, and update the personal information that you provide to us at a Future Corporation Internet Site by accessing your User Profile (if you have one) provided at the Future Corporation Internet Site(s).

3.2 RETENTION OF PERSONAL INFORMATION
Future Corporation retains Personal Data processed under this Privacy Statement only for as long as necessary for the purposes for which it was collected or otherwise processed, including the provision of Software, Software licensing, accounts, purchases, Technical Support and associated services, or as required or permitted by applicable law. Personal Data that is no longer required for those purposes and is not required to be retained by applicable law will be securely destroyed or de-identified, where appropriate.

Without limiting the foregoing, retention periods are determined having regard to: (i) the purposes for which the information was collected; (ii) legal, accounting and tax obligations (for example, transaction records such as invoices, payment records and license activations are retained for at least the period required by applicable tax and commercial law); (iii) contractual requirements, including the administration of your Software Licenses for their duration; (iv) the establishment, exercise or defence of legal claims and the enforcement of our rights; (v) security and fraud-prevention needs; and (vi) legitimate business record-keeping.

3.3 CHILDREN AND PARENTS
Future Corporation Internet Sites are general-audience sites and are not directed to children. Future Corporation does not knowingly solicit or collect personal information from or about children contrary to applicable law, and where applicable law requires the consent of a parent or guardian (or of another holder of parental responsibility) for the processing of a child’s personal information, Future Corporation relies on that consent. A “child” for these purposes means a person below the minimum age prescribed by the law applicable to them. If your child has submitted personal information and you would like to request that such information be deleted from our records, you may do so by writing to privacy@fcl.software (also see section 18.0 Contact Us below).

3.4 ARTIFICIAL INTELLIGENCE AND MACHINE LEARNING
Future Corporation does not use your personal information, your account data, or the content, designs or work files you create or process using the Software to train generative artificial intelligence (AI) or machine-learning (ML) models, except: (i) where you have given your express consent; or (ii) in an aggregated and/or de-identified form that does not identify you and from which you cannot reasonably be re-identified. Where the Software includes an AI- or ML-assisted feature, any content or input you provide to that feature is processed only as necessary to provide that feature and its output to you, and is not used to train models for other users except as stated above. Future Corporation does not sell or disclose your content or personal information to any third party for the purpose of training that third party’s AI or ML models. If Future Corporation introduces new AI or ML features (including in future versions of the Software), this Privacy Statement will be updated to describe the relevant processing before those features are made available to you, and Future Corporation will obtain your consent where required by applicable law. This section operates in addition to, and does not limit, the restrictions on AI and ML training set out in the Software License Agreement.

4.0 DISCLOSING YOUR PERSONAL INFORMATION TO OTHERS
Except in the limited circumstances stated in this section and as permitted or required by applicable law, we do not sell, rent, license, trade or otherwise disclose Personal Data we process to third parties. We may disclose your information to service providers who assist us in facilitating and/or operating the Internet site or conducting our business, including hosting providers, payment processors, technical and licensing infrastructure providers, support service providers, professional advisers and other authorised service providers performing functions for Future Corporation. Where reasonably necessary for the supply, licensing, activation, technical support or servicing of your Software or Software License, or for communications relating to them, we may also disclose relevant license, account and contact information to the authorised dealer or other authorised channel participant (as described in the Software License Agreement and the Terms and Conditions of Sale) involved in the supply, licensing or support of your Software. We may disclose information about you if and when we believe it is necessary to comply with any law, rule, court order, or subpoena, or to enforce our legal rights or the rules of this Internet site, or to protect our business, real property, intellectual property and operations, or in connection with a sale, acquisition, merger or other business combination of our business with a third party. Some areas of the Internet site may allow you to conduct E-commerce transactions. In connection with these transactions, we collect data necessary to complete the transaction that is furnished by you. This information may be furnished to a third party in order to facilitate the transaction.

5.0 LINKS TO OTHER SITES
We may create links to other Internet sites that we think may be of interest to you. We do not endorse any other Internet sites, and our privacy policy applies only to your use of our Internet site. We have not reviewed the privacy policies of any Internet sites we link to our Internet site, and you should read the privacy policies of each site you visit to determine what information that site may collect about you.

6.0 WEBSITE STATISTICAL USE
Future Corporation does not use cookies, third-party analytics, advertising, behavioural profiling or tracking technologies on its Internet Sites. Future Corporation does not monitor individual website visitors or use website browsing behaviour for advertising, profiling or behavioural analytics, and does not collect statistics concerning the interests, browsing behaviour or dwell time of individual visitors. Technical records necessarily generated in the ordinary operation and security of Future Corporation’s Internet Sites may be used for technical administration, security and fault diagnosis. We do not sell or share any such technical records with third parties for analytics, advertising or marketing purposes.

6.1 PERFORMANCE REPORTING
The Software may collect and periodically transmit to Future Corporation, or to an authorised service provider acting on its behalf, secure performance and diagnostic information about the operation of the Software (a “Performance Report”). A Performance Report consists of statistical information produced by the Software when in use and may be associated with a license, device or account identifier. Performance Reports are handled in accordance with this Privacy Statement and applicable law. You may opt out of Performance Reporting at any time via the Software’s preferences or settings, or by writing to Future Corporation. Performance Reporting is described further in the Software License Agreement.

7.0 SECURITY
Since we are committed to your privacy and security, we maintain reasonable technical, organisational, physical and administrative safeguards, having regard to applicable law and the nature of the information, designed to protect against unauthorised access, maintain data security, and ensure the correct use of the information we collect online. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be secure absolutely. As a result, while we take reasonable steps to protect your personal information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. When you place an order or access your personal information, we offer the use of a secure server. To the extent permitted by applicable law, we disclaim and deny any liability to you or any other party (See our Terms of Use). Nothing in this section excludes any liability or obligation that cannot lawfully be excluded under applicable privacy law.

8.0 VERIFICATION OF SOFTWARE LICENSES
Future Corporation, directly or through authorised service providers acting on its behalf, will use your information to activate, validate, verify and update any Product and/or Software Licenses you have, and for related security, fraud-prevention, non-payment, Software piracy and compliance purposes, in accordance with the Software License Agreement and/or EULA applicable to you. The Software License Agreement remains the principal instrument governing your Software License.

9.0 SOFTWARE PIRACY
Software Piracy is a matter we take very seriously since it harms not only our businesses but the global economy more generally and stifles research and development. If you know of any piracy and decide to report it to us, you may do so anonymously: you are not required to provide your name or contact details, and if you report anonymously we do not require or record your identity. Please note that technical data (such as an IP address) may arise automatically from the ordinary operation of networks and our systems and is handled in accordance with this Privacy Statement. If, however, you wish to assist us pursue an individual or other legal entity who is engaged in Software Piracy you may provide your contact details so the appropriate authorities can contact you for you to provide them with specific details which may be used in a prosecution and possible conviction of such offender(s). If you choose to report piracy and do provide us with your contact details, you acknowledge and agree that to the extent permitted by applicable law that the information you provide will be given to the appropriate authorities for the purposes as described in the section.

10.0 CHANGES TO THIS POLICY AND OUR PRIVACY STATEMENTS
Future Corporation reserves the right to update or modify the Policy, at any time and without prior notice, by posting the revised version of the Policy on our Future Corporation Internet sites. We also reserve the right to update or modify our Country specific or Privacy Statements, at any time and without prior notice, by posting the revised Privacy Statement on the applicable Future Corporation Internet site. If we modify the Policy or any Privacy Statement, the modifications will apply from the time we post the revised Policy or Privacy Statement on the applicable Future Corporation Internet site. To the extent that a modification applies to personal information collected before it was posted, we will provide any notice, or obtain any consent, required by applicable law.

11.0 OPT IN/OPT OUT
Our site provides users the opportunity to opt-in or opt-out of receiving certain communications from us at the point where we request information about the visitor. You have the following options for reviewing or removing your information from our database to no longer receive communication from us. If you request that your account information be deleted from our database, we will retain and maintain information about your sales transactions as required under applicable law.

You can send an email to: privacy@fcl.software

You can call: +613-9583-2331

You can also mail correspondence to the postal address listed in section 18.0 (below).

Please note that due to email production schedules, you may receive an email message from us after you have provided your opt-out notice.

12.0 CALIFORNIA (USA) RESIDENTS
Future Corporation does not sell consumer personal information for monetary or other valuable consideration. Although Future Corporation is not presently subject to the thresholds that make a business subject to the California Consumer Privacy Act as amended by the California Privacy Rights Act 2020 (hereafter collectively “CCPA/CPRA”), Future Corporation voluntarily extends the following privacy rights to California residents, which Future Corporation will uphold:

• The right to know what personal information is being collected, used, shared, or sold.
• The right to know if personal data is being sold or shared, and to whom.
• The right to opt out of the sale or sharing of personal data.
• The right to access one’s own personal information.
• The right to correct inaccurate personal information held by Future Corporation.
• The right to delete personal information, subject to certain exceptions.
• The right to limit the use and disclosure of sensitive personal information.
• The right to non-discrimination for exercising any of the above rights.

Any Customer wishing to exercise a right to access personal information held by Future Corporation must submit a verifiable consumer request to Future Corporation by either:

Emailing Future Corporation at privacy@fcl.software

Calling Future Corporation at +613-9583-2331

You can also mail correspondence to the postal address listed in section 18.0 (below).

Please note that only an individual who is a resident of California (or the legal guardian of such individual in the case of a minor child) may make a request under the CCPA/CPRA.

12.1 OTHER US STATES:
In addition to California (above), Future Corporation extends similar privacy rights to residents of other US states that have enacted comprehensive consumer privacy laws (including, for example, Virginia, Colorado, Connecticut, Utah and Texas), in each case subject to the applicable thresholds and exceptions under each state’s law, and including any further such state privacy laws as they come into force.

Subject to applicable verification requirements and exceptions under each state’s law, residents of these states have the following rights:

• The right to confirm whether Future Corporation processes their personal data and to access that data.
• The right to correct inaccurate personal data.
• The right to delete personal data, subject to applicable exceptions.
• The right to data portability, in a portable and (where technically feasible) readily usable format.
• The right to opt out of the sale of personal data. Future Corporation does not sell personal data for monetary or other valuable consideration.
• The right to opt out of the processing of personal data for the purposes of targeted advertising. Future Corporation does not process personal data for targeted advertising.
• The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. Future Corporation does not engage in such profiling.
• The right to non-discrimination for exercising any of the above rights.

To exercise any of these rights, contact Future Corporation using the details set out in section 18.0 (below). You may also designate an authorised agent to exercise rights on your behalf where permitted by applicable state law. Future Corporation will respond to verified requests within the period prescribed by applicable state law.

Sensitive personal data: Some states (including Virginia, Colorado, and Connecticut) require opt-in consent for the processing of certain categories of sensitive personal data. Future Corporation processes sensitive personal data only as described in this Privacy Statement and only with consent where required by applicable state law.

Right to appeal: Some states grant residents the right to appeal a denial of a privacy request. To appeal a decision made by Future Corporation in response to your request, please contact us using the details set out in section 18.0 (below). Future Corporation will respond to appeals within the period prescribed by applicable state law.

13.0 CHINA RESIDENTS
Pursuant to the laws of the People’s Republic of China (excluding Hong Kong SAR, Macau SAR and Taiwan unless expressly stated otherwise) (hereafter “PRC”) and the Personal Information Protection Law of China (hereafter “PIPL”), we are providing additional information to residents in the PRC. Please read this information together with our Privacy Statement herein. This section applies to the processing of personal information of individuals in the PRC that is protected by the PIPL.

All terms not defined here have the meaning prescribed in our Terms of Use or the Software License Agreement, as applicable.

Where Future Corporation processes personal information of individuals in the PRC in connection with its products, Internet sites and services, Future Corporation is the personal information handler for that processing.

You are not legally required to provide Future Corporation with the Personal Data described in this Privacy Statement. Further, the contractual relationship that you might have entered into with us by purchasing our Software products does not imply any obligation to provide your Personal Data. However, you will not be able to purchase our Software products if you do not provide us with certain data or object to the use of this data. Personal Data of Future Corporation’s customers in the PRC is stored on secure infrastructure located within the PRC and is not stored outside the PRC, and Future Corporation does not require that Personal Data to be exported outside the PRC for its ordinary operations. If any cross-border transfer of PRC personal information were required, it would be made only in accordance with the applicable cross-border transfer requirements of the PIPL and related regulations.

13.1 USER PROFILES
We do not use your Personal Data for “Profiling”, to make tailored offers based on your previous behaviour, or to serve you personalised advertisements. We do not process or analyse your Personal Data in a way that would lead to an automated decision that has a legal effect on you or significantly impairs you in a similar way.

Your rights regarding the processing of your Personal Data

As a natural person within China, you have certain rights. You may assert the following rights under the PIPL:

• Your right to restriction of processing.
• Your right to access to information and a copy of data.
• Your right to rectification.
• Your right to erasure.
• Your right to withdraw your consent (Please note that if you withdraw your consent, we may be unable to provide you with our Software products and/or access to our Internet Site).
• Your right to data portability.
• Your right to request an explanation of the rules governing the processing of your Personal Data, and;
• Your right to object to our use of your Personal Data.

If you have any questions about how your Personal Data is processed or if you want to exercise one of your rights, you can contact Future Corporation using the details set out in section 18.0 (below).

14.0 EUROPEAN UNION RESIDENTS
Pursuant to the laws of the European Union (hereafter “EU”) you are not legally required to provide Future Corporation with the Personal Data described in this Privacy Statement. Further, the contractual relationship that you might have entered into with us by purchasing our Software products does not imply any obligation to provide your Personal Data. However, you will not be able to purchase our Software products if you do not provide us with certain data or object to the use of this data.

The data controller for the processing described in this Privacy Statement is A Future Corporation Pty Ltd (ACN 078 538 002) of Unit 1.19 999 Nepean Hwy, Moorabbin VIC 3189 AUSTRALIA.

14.1 OUR LEGAL BASIS FOR PROCESSING
When processing your Personal Data, we rely on the General Data Protection Regulation (hereafter “GDPR”), an EU legal framework for the standardisation of data protection. Future Corporation processes data as a controller, for the purposes explained in section 3.0 of this Privacy Statement. Depending on the purpose, our processing is based on one or more of the lawful bases described in this section, including our legitimate interests under Article 6(1)(f) of the GDPR where applicable. At the same time, some of the Personal Data we process is necessary for us to perform a contract or agreement with you or in order to take steps at your request prior to entering into a contract or agreement with you. For example, if you express your interest in purchasing one of our Software products, such as by filling an online form, we will process the Personal Data submitted to process your request. This may include sharing your Personal Data with an authorised service provider or authorised seller involved in the transaction, who will then use your Personal Data to complete the purchase transaction. In addition, we are legally obliged to provide certain information to criminal prosecution or tax authorities in individual cases upon request. In these cases, the legal basis for the processing is compliance with legal obligations under Article 6(1)(c) of the GDPR or, where applicable, our legitimate interests under Article 6(1)(f) of the GDPR. Where we process your Personal Data with your explicit consent, pursuant to Article 6(1)(a) of the GDPR, this declaration of consent will be the legal basis for processing your Personal Data.

14.1.2 TRANSFERRING YOUR DATA OUTSIDE THE EU OR THE EEA
Future Corporation’s principal place of business is in Australia, which is a “Third Country” under the GDPR and is not the subject of a European Commission adequacy decision. Transfers of Personal Data outside the European Economic Area to Australia, or to any other country for which an applicable adequacy decision does not apply, are made in accordance with the international-transfer requirements of Chapter V of the GDPR, using the Standard Contractual Clauses adopted by the European Commission (Commission Implementing Decision (EU) 2021/914) or another lawful transfer mechanism recognised under applicable EU law, where required. Future Corporation takes appropriate steps to ensure that its service providers and other authorised recipients are subject to appropriate data protection obligations consistent with those required under the GDPR.

14.2 USER PROFILES
We do not use your Personal Data for “Profiling”, to make personalised offers based on your previous behaviour(s), or to serve you personalised advertisements. We do not process or analyse your Personal Data in a way that would lead to an automated decision that has a legal effect on you or significantly impairs you in a similar way.

14.2.1 YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA
As a natural person, you have certain rights as a “Data Subject”. You can assert the following rights against us under the GDPR:

• Your right to information and access under Article 15 of the GDPR.
• Your right to rectification under Article 16 of the GDPR.
• Your right to erasure under Article 17 of the GDPR.
• Your right to restriction of processing under Article 18 of the GDPR, and;
• Your right to data portability under Article 20 of the GDPR.

In addition, you have the right to lodge a complaint with a competent data protection supervisory authority under Article 77 of the GDPR.

Please note that, where you have granted us your consent to process certain Personal Data, you are free to withdraw this declaration of consent with future effect at any point in time. This also applies to the withdrawal of declarations of consent issued to us prior to the validity of the GDPR.

14.2.2 BREACH NOTIFICATION
In the event of a personal data breach affecting EU residents that is likely to result in a risk to the rights and freedoms of natural persons, Future Corporation will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, in accordance with Article 33 of the GDPR. Where the breach is likely to result in a high risk to the rights and freedoms of natural persons, Future Corporation will also notify the affected individuals without undue delay, in accordance with Article 34 of the GDPR.

14.3 INFORMATION ABOUT YOUR RIGHT OF OBJECTION UNDER ARTICLE 21 OF THE GDPR.

14.3.1 RIGHT OF OBJECTION IN INDIVIDUAL CASES
In addition to the rights already mentioned, you have the right, for reasons arising from your particular situation, to object at any time to the processing of Personal Data relating to you, which is processed on the basis of Article 6(1)(f) of the GDPR (data processing on the basis of a balance of interests); this also applies to any profiling based on that provision within the meaning of Article 4(4) of the GDPR. If you file an objection, we will no longer process your Personal Data unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims. Please note that, if we terminate the processing due to your objection, our Software products and/or Internet Sites may no longer be available to you, or only to a limited extent.

14.3.2 THE RIGHT TO OBJECT TO THE PROCESSING OF DATA FOR ADVERTISING PURPOSES
You also have the right to object at any time to the processing of your Personal Data for the purpose of direct marketing, including any subscription to our newsletters; this also applies to Profiling, insofar as it is associated with such direct marketing. If you object, we will no longer process your Personal Data in the future.If you have any questions about how we process your Personal Data or if you want to exercise one of your rights, you can contact us using the details set out under section 18.0 Contact Us (below) or Opt Out (see section 11.0 OPT IN/OPT OUT above).

14.4 EU REPRESENTATIVE UNDER ARTICLE 27 OF THE GDPR:
Pursuant to Article 27 of the GDPR, Future Corporation (being established outside the European Union and offering goods and services to data subjects in the European Union) has designated the following entity as its EU representative: GDPRLocal Ltd. (UK Company No. 12969035), of 12A Lower Main Street, Lucan, Co. Dublin, K78 X5P8, Ireland. The EU representative may be contacted in respect of matters relating to the processing of personal data of EU data subjects via https://gdprlocal.com/contact/. The designation of the EU representative is without prejudice to any legal proceedings that may be brought directly against Future Corporation.

15.0 UNITED KINGDOM RESIDENTS

Pursuant to the United Kingdom General Data Protection Regulation (UK GDPR) as retained in UK law by the European Union (Withdrawal) Act 2018, and the Data Protection Act 2018, Future Corporation provides additional information to residents in the United Kingdom. Please read this information together with our Privacy Statement herein. The data controller for personal information of UK residents processed as described in this Privacy Statement is A Future Corporation Pty Ltd (ACN 078 538 002) of Unit 1.19 999 Nepean Hwy, Moorabbin VIC 3189 AUSTRALIA.

15.1 LEGAL BASIS FOR PROCESSING
Future Corporation processes personal data of UK residents on the same legal bases as described in Section 14.1 of this Privacy Statement, applying the corresponding provisions of the UK GDPR.

15.2 CROSS-BORDER TRANSFERS
Restricted transfers of personal data of UK residents outside the United Kingdom — to Australia or to any other country not covered by UK adequacy regulations — are made in accordance with the international-transfer requirements of the UK GDPR and the Data Protection Act 2018, using the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses or another lawful safeguard or transfer mechanism recognised under applicable UK law, where required.

15.3 YOUR RIGHTS UNDER UK GDPR
UK residents have the same rights as EU residents as set out in Section 14.2.1 of this Privacy Statement, applying the corresponding provisions of the UK GDPR. These rights include the right to information and access, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability, and the right to object.

15.4 RIGHT TO LODGE A COMPLAINT

UK residents have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/ if you consider that the processing of your personal data infringes the UK GDPR or the Data Protection Act 2018. If you have any questions about how we process your personal data or wish to exercise any of your rights, please contact us using the details set out under section 18.0 Contact Us (below).

15.5 RIGHT TO COMPLAIN DIRECTLY TO FUTURE CORPORATION (DUAA 2025):
Pursuant to the Data (Use and Access) Act 2025, UK residents have the right to lodge a complaint directly with Future Corporation in respect of the processing of their personal data, in addition to (and without prejudice to) the right to lodge a complaint with the Information Commissioner’s Office set out in section 15.4 (above). To lodge such a complaint, please contact Future Corporation using the details set out in section 18.0 (below). Future Corporation will acknowledge your complaint within thirty (30) days of receipt and will substantively respond within the period prescribed by applicable law.

15.6 CHILDREN’S HIGHER DATA PROTECTION MATTERS (DUAA 2025):
Where Future Corporation’s Internet sites or Software are likely to be accessed by children, Future Corporation takes into account “children’s higher protection matters” in the design and operation of its services, as required by the UK GDPR as amended by the Data (Use and Access) Act 2025. This includes consideration of (i) how children of different ages may understand the proposed processing; (ii) the different needs of children at different stages of development; (iii) the desirability of supporting and promoting children’s interests; and (iv) appropriate safeguards including age-appropriate design and presentation of information.

15.7 AUTOMATED DECISION-MAKING (DUAA 2025):
The UK GDPR as amended by the Data (Use and Access) Act 2025 modifies the rules governing solely automated decisions that produce legal or similarly significant effects for data subjects. Future Corporation does not currently subject UK residents to such decisions. Where Future Corporation introduces solely automated decision-making in the future, Future Corporation will (i) provide meaningful information about the logic involved and the significance and envisaged consequences for the data subject; (ii) implement appropriate safeguards, including the right to obtain human intervention, express your point of view, and contest the decision; and (iii) comply with all applicable safeguards required by the UK GDPR as amended from time to time.

15.8 RESPONSE TIMEFRAMES AND REASONABLE SEARCHES (DUAA 2025):
Future Corporation will respond to verified data subject requests within the timeframes prescribed by the UK GDPR as amended by the Data (Use and Access) Act 2025. In responding to a data subject access request, Future Corporation will carry out a reasonable and proportionate search for the requested information, having regard to the circumstances of the request, and will provide the information it is able to provide on the basis of that search. Where a request is manifestly unfounded or excessive, Future Corporation may charge a reasonable fee or refuse to act on the request, to the extent permitted by applicable law.

15.9 UK REPRESENTATIVE UNDER ARTICLE 27 OF THE UK GDPR:
Pursuant to Article 27 of the UK GDPR, Future Corporation (being established outside the United Kingdom and offering goods and services to data subjects in the United Kingdom) has designated the following entity as its UK representative: GDPRLocal Ltd. (UK Company No. 12969035), of 1st Floor Front Suite, 27-29 North Street, Brighton, England, BN1 1EB. The UK representative may be contacted in respect of matters relating to the processing of personal data of UK data subjects via https://gdprlocal.com/contact/. The designation of the UK representative is without prejudice to any legal proceedings that may be brought directly against Future Corporation.

16.0 INDIA RESIDENTS

Pursuant to the Digital Personal Data Protection Act 2023 (DPDPA) of India and the rules made thereunder, in each case to the extent in force and applicable from time to time, Future Corporation provides additional information to residents in India. Please read this information together with our Privacy Statement herein. The Data Fiduciary for personal data of Indian residents is A Future Corporation Pty Ltd (ACN 078 538 002) of Unit 1.19 999 Nepean Hwy, Moorabbin VIC 3189 AUSTRALIA.

16.1 PURPOSE LIMITATION
Future Corporation processes personal data of Indian residents only for the purposes described in this Privacy Statement and will not process such data for any other purpose without a lawful basis under the DPDPA.

16.2 YOUR RIGHTS UNDER THE DPDPA
Indian residents have the following rights:

• The right to access information about personal data being processed.
• The right to correction and erasure of inaccurate, incomplete, or no longer necessary personal data.
• The right to grievance redressal: you may register a grievance with Future Corporation using the contact details in section 18.0 and receive a response within the period prescribed by applicable law.
• The right to nominate another individual to exercise your rights in the event of your death or incapacity.

16.3 CONSENT
Where Future Corporation processes your personal data on the basis of consent under the DPDPA, you have the right to withdraw consent at any time. Withdrawal of consent will not affect the lawfulness of processing prior to withdrawal, but may affect our ability to provide software products or services.

16.4 CHILDREN'S DATA
Future Corporation does not knowingly collect personal data of children under 18 years of age in India. If you believe a child under 18 has provided personal data to Future Corporation, please contact us using the details in section 18.0 below so that we may take appropriate action.

16.5 GRIEVANCE OFFICER
For grievances related to the processing of personal data of Indian residents, you may contact Future Corporation using the details in section 18.0 Contact Us below.

17.0 AUSTRALIAN RESIDENTS

Pursuant to the Privacy Act 1988 (Cth) as amended by the Privacy and Other Legislation Amendment Act 2024 (Cth), and the Australian Privacy Principles (“APPs”) in Schedule 1 to the Privacy Act, Future Corporation provides additional information to residents in Australia. Please read this information together with our Privacy Statement herein. The APP entity for personal information of Australian residents is A Future Corporation Pty Ltd (ACN 078 538 002) of Unit 1.19 999 Nepean Hwy, Moorabbin VIC 3189 AUSTRALIA.

17.1 PURPOSES OF COLLECTION AND USE:
Future Corporation collects personal information of Australian residents for the purposes described in sections 1, 2, and 3 of this Privacy Statement, including (i) provision of Future Corporation Software products and services; (ii) communications relating to your account, purchases, and support; (iii) software licensing, activation, and verification; (iv) diagnostic and statistical analysis of Software-related technical information and Performance Reports to improve our products and services; and (v) compliance with applicable Australian law.

17.2 OVERSEAS DISCLOSURE:
Pursuant to Australian Privacy Principle 8 (Cross-border disclosure of personal information), Future Corporation may disclose your personal information to overseas recipients in connection with the operation of our business, including (i) service providers in jurisdictions including the United States, the United Kingdom, the European Economic Area and other jurisdictions where our service providers operate; (ii) cloud hosting providers; (iii) payment processors; (iv) an authorised dealer or other authorised channel participant located outside Australia, where that person is involved in the supply, licensing or support of your Software; and (v) regulatory authorities where required by law. Future Corporation takes reasonable steps to ensure that overseas recipients handle personal information in accordance with the APPs.

17.3 YOUR RIGHTS UNDER THE PRIVACY ACT:
You have the following rights under the Privacy Act 1988 (Cth):

• The right to access your personal information held by Future Corporation (APP 12).
• The right to correct inaccurate, incomplete, out-of-date, irrelevant, or misleading personal information (APP 13).
• The right to anonymity or pseudonymity in dealings with Future Corporation, where lawful and practicable (APP 2).
• The right to withdraw consent to the processing of your personal information.
• The right to make a complaint to Future Corporation or to the Office of the Australian Information Commissioner (OAIC).

To exercise any of these rights, contact Future Corporation using the details set out in section 18.0 (below).

17.4 STATUTORY RIGHTS:
Nothing in this Privacy Statement limits any right or remedy you may have under the Privacy Act 1988 (Cth), including the statutory cause of action for serious invasions of privacy introduced by the Privacy and Other Legislation Amendment Act 2024 (Cth).

17.5 CHILDREN’S DATA:
Future Corporation will comply with the Australian Children’s Online Privacy Code when it comes into force, and applies appropriate protections to the personal information of children in accordance with the Privacy Act 1988 (Cth). Where Future Corporation’s Internet sites or Software are likely to be accessed by children, additional safeguards are applied in accordance with applicable Australian law.

17.6 BREACH NOTIFICATION:
Pursuant to Part IIIC of the Privacy Act 1988 (Cth) (Notifiable Data Breaches scheme), in the event of an eligible data breach affecting Australian residents that is likely to result in serious harm, Future Corporation will notify the Office of the Australian Information Commissioner (OAIC) and the affected individuals as soon as practicable and in any event in accordance with the requirements of the Notifiable Data Breaches scheme.

17.7 COMPLAINTS:
If you have a complaint about how Future Corporation handles your personal information, please contact Future Corporation using the details set out in section 18.0 (below). Future Corporation will acknowledge your complaint promptly and will respond within a reasonable period, and in any event within any period required by applicable law. If you remain dissatisfied with Future Corporation’s response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

17.8 AUTOMATED DECISION-MAKING:
From 10 December 2026, where Future Corporation uses a computer program to make, or to do a thing that is substantially and directly related to making, a decision that could reasonably be expected to significantly affect your rights or interests, Future Corporation will, in accordance with the Privacy Act 1988 (Cth) (as amended), set out in this Privacy Statement the kinds of personal information used in the operation of such programs and the kinds of decisions made, or substantially and directly made, by those means. Examples may include the automated validation of Software Licenses and automated measures to detect and prevent fraud, chargeback abuse, software piracy or non-payment (see the Software License Agreement and section 9.0 above), where and to the extent that such a measure makes, or does a thing substantially and directly related to making, a decision of that kind. Where such automated decision-making applies to you, you may contact Future Corporation using the details in section 18.0 (below) to request information about the decision and, where applicable, to seek human review.

18.0 CONTACT US

18.1 GENERAL QUESTIONS: If you have any questions about the Policy, please contact us in one of the following ways:

(i) Email us at: privacy@fcl.software
(ii) You can call us on: +613-9583-2331
(iii) Write to our Privacy Contact at:

Privacy Contact
A Future Corporation Pty Ltd
GPO Box 3431
Melbourne, VIC 3001
AUSTRALIA

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