Privacy Policy

Dux Manufacturing Limited ABN 19 077 879 844 (Dux) values and respects the privacy of the people we deal with. Dux is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations, including the EU General Data Protection Regulation (GDPR) where applicable.

This Privacy Policy describes how we collect, hold, use and disclose your personal information when you use the Thermann C-Series Heat Pump Product Trainer (the Service), and how we maintain the quality and security of your personal information.

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether the information is recorded in material form or not.

The personal information we collect depends on the nature of your interaction with the Service. When you use the Thermann C-Series Heat Pump Product Trainer, we or our service providers may collect:

• Your work email address, which you provide to sign in — the Trainer is access-controlled and emails you a one-time verification code
• Voice and audio captured via your microphone during an active session, used to transcribe your spoken input in real time
• A written transcript of the session — your questions (typed or transcribed) and the AI trainer's responses
• Any rating or comment you submit as feedback at the end of a session
• A randomly generated session identifier for each session
• Sign-in records (your email, IP address and browser) kept as a security audit log
• Technical data such as IP address, browser type, device type, and connection quality
• Usage data such as which topics were navigated during the training session

Your live session is identified by a randomly generated session identifier rather than your name. However, because the Trainer requires sign-in, any feedback you submit and your sign-in audit records are associated with your work email address.

Where possible, you may interact with the Service without providing personal information (for example, by using the text input rather than the microphone).

We collect your personal information directly from you when you:

• Access and use the Thermann C-Series Heat Pump Product Trainer
• Enable your microphone to ask questions during a session
• Interact with the Service via text input
• Connect to the Service from your device (technical data collected automatically)

We use your personal information for the following purposes:

• To deliver the AI-powered training session in real time
• To process your voice input and generate relevant responses
• To authenticate your access and maintain a sign-in audit log for security
• To review session transcripts and the feedback you provide so we can improve the accuracy, content and knowledge base of the Trainer
• To produce aggregated insights about commonly asked questions, which may involve an AI provider analysing recent transcripts
• To improve the quality and performance of the Service
• To ensure reliable technical operation and security of the Service
• Internal administrative and analytical purposes

The Service relies on a number of third-party service providers to function. These providers act as data processors and may receive certain data — such as audio streams, session identifiers, or conversation content — in order to deliver the AI training experience.

We may also disclose your personal information to our IT providers, professional services advisors, and other parties involved in operating the Service, in accordance with this Policy and in circumstances where you would reasonably expect us to do so.

For a full list of the third-party services we use and the data they receive, please contact us at privacy@dux.com.au.

Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia, including in the United States and the European Union.

Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. We will only disclose to overseas third parties if:

• you have given your consent to the disclosure; or
• we reasonably believe the overseas recipient is subject to a law or binding scheme substantially similar to the Australian Privacy Principles and that law or scheme can be enforced; or
• the disclosure is required or authorised by an Australian law or court order.

Where required under the GDPR, international data transfers are governed by Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms under GDPR Chapter V.

Dux will take reasonable steps to ensure that the personal information we hold about you is kept confidential and secure, including by:

• Restricting access to only personnel who need that information to provide services to you
• Having technological measures in place such as encryption, firewalls, and secure protocols
• Ensuring third-party processors maintain appropriate security standards

Live voice audio is processed in real time for transcription and is not stored. However, the written session transcript, any feedback you submit, and your sign-in audit records are stored in a secured database operated for us by our hosting provider. Access to that stored data is restricted to authorised Dux administrators.

The Service uses cookies and local storage. A cookie is a small file of letters and numbers placed on your device. These are used solely to operate the Service and improve your experience — we do not use cookies to identify you personally.

Third-party services used during your session (such as embedded video content) may also set their own cookies. These are functional in nature and are activated only when relevant content is displayed.

Your privacy consent preference is stored in your browser's local storage so that the notice is not shown on every visit. You can clear this at any time through your browser settings.

If you do not wish to use cookies, you can amend the settings on your internet browser. However, disabling cookies may affect the functionality of the Service.

We will not keep your personal information for longer than we need to. Live voice audio is not retained. We do retain the written session transcript (your questions and the AI trainer's responses), any rating or feedback you submit, and your sign-in audit records, in a secured database, so that we can operate, secure and improve the Service. We keep this information only for as long as necessary for those purposes and then delete or de-identify it. You may request access to, or deletion of, this information using the contact details below.

Third-party service providers may retain data in accordance with their own retention policies. Contact us at privacy@dux.com.au for further details.

Dux will endeavour to keep your personal information accurate, complete and up to date. If you wish to access or correct the personal information we hold about you, please contact us using the details below. We will usually respond within 14 days.

For complaints about how Dux handles, processes or manages your personal information, please contact our Privacy Officer. Note we may require proof of your identity and full details of your request before we can process your complaint.

Please allow up to 14 days for Dux to respond to your complaint. If you are not satisfied with our response, you have the right to contact the Office of Australian Information Commissioner (OAIC) to lodge a complaint. If you are located in the EEA, you also have the right to lodge a complaint with your local data protection supervisory authority.

If you have a question or concern in relation to our handling of your personal information or this Policy, please contact us: