Privacy Policy

SHOPFRONT MEDIA: PRIVACY POLICY

Operated by Shopfront Media Ltd (UK Company No. 16928627) and Luxton Park Labs (ACN 650914579)

1. Introduction

1.1 This privacy policy is the official online privacy policy of Shopfront Media Ltd (UK Company No. 16928627) and Luxton Park Labs (ACN 650914579), collectively operating as Shopfront Media (we, our, us). This policy applies to all personal information collected, stored, used and processed by us.

1.2 Our Privacy Policy governs all personal information relating to our key functions and activities concerning the development, implementation and operation of Shopfront Media, an innovative advertising and analytics solution, and associated services.

1.3 In this Privacy Policy we explain how and why we collect your personal information, how we use it, and what controls you have over our use of it. We are committed to complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Australian Privacy Act 1988 (Cth).

1.4 For users in the United Kingdom, our supervisory authority is the Information Commissioner's Office (ICO) at ico.org.uk. For users in Australia, please refer to the Office of the Australian Information Commissioner at www.oaic.gov.au.

2. Collection of Information

2.1 Some information provided to us by clients, customers, contractors and other third parties (Users) might be considered private or personal. Depending on the particular circumstance, we may collect and hold a range of different information about you. This can include your name, contact details (including address, email address, phone number or mobile telephone number), occupation, username or password, financial information (for billing purposes), and information about how you use our services. This is not an exhaustive list. Without these details, we would not be able to carry on our business and provide our services to you.

2.2 By providing Personal Information to us, you may provide us with two types of information: Personal Information that you knowingly and voluntarily choose to provide and Anonymous Information (as defined below) that we automatically collect as you browse our website or interact with Shopfront Media.

2.3 Camera Data andShopfront Media: Our product, Shopfront Media, includes a camera component designed for purposes such as analyzing audience engagement, estimating foot traffic, or understanding generalized demographic profiles of viewers in real-time to optimize advertising content. Shopfront Media is built with privacy as a priority. Crucially,Shopfront Media does not record, store, or transmit any identifiable video footage or individual photographs to our servers or any third-party storage. Any data captured by the camera is processed either on-device or in transient memory for immediate analysis. The information that may be sent to our servers from the camera functionality, if any, consists only of anonymized and/or aggregated data (e.g., number of viewers detected, estimated attention time, general demographic categories if applicable, interaction counts). This data does not personally identify individuals and is used to provide analytics and improve our services.

2.4 Our web servers (if you interact with our website or management console) may automatically collect and store the name of the domain and host from which you access the internet and the internet protocol (IP) address of your computer. Additionally, we may collect information about the browser software you use; the type of operating system your computer uses; the date and time you access our services; the website you visited just prior to visiting our services; and the amount of time you spend on each website relating to our services (Anonymous Information). Anonymous Information may also include session cookies, your device IP address, and MAC address (for network-connected Shopfront Media devices solely for network management and device identification). We use this Anonymous Information to improve the performance of our services and make it more compatible with the technology used by our Users. This Anonymous Information may be combined with Personal Information you have provided to us.

2.5 We will only collect such Personal Information if it is necessary for one of our functions or activities. We retain the right to use or disclose Personal Information about you that is required in the provision of information about or the promotion or delivery of Shopfront Media and its services to the User, such as service updates, newsletters (if you opt-in), promotional materials or direct marketing campaigns relevant to the services that we offer. We may also disclose your Personal Information to a third-party payment processing provider in connection with payment or billing for the provision of services to the User.

2.6 The Privacy Act defines some types of Personal Information as sensitive. We do not commonly collect sensitive information, which includes, but is not limited to information about a person’s race, ethnic origin, political opinions, health, religious or philosophical beliefs and criminal history. In the event we require any sensitive information, we would only collect this with your permission, and we will only use it for the purpose for which you provided it. Note that aggregated, anonymized demographic estimations derived from camera data by Shopfront Media (e.g. general age group, gender) are not considered sensitive personal information as they do not identify specific individuals.

2.7 Personal Information about you may be collected by us from devices or browsers which you use to access our webpages, where we keep a record and a copy of your contact with us, where you submit information through web forms, by logging your IP address, by use of cookies, by recording phone numbers and email addresses from which you contact us, and in other ways which rely on technical access to information available from devices and operating systems that you might use.

2.8 We may also obtain your Personal Information from our affiliates or advertising partners, customers and other third parties that we consider helps us to deliver or advertise our services, understand online activity and collect information that we consider important to managing the quality or content of the services that we deliver.

2.9 We may store your information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our services providers. We take the privacy and security of your information seriously and we are committed to maintaining the security of your information under our control. We use a combination of technical solutions, security controls and internal processes to help us protect your information and our network from unauthorised access and disclosure. While we take these steps to maintain the security of your information, you should be aware of the range of information security risks that exist today and take appropriate care to help safeguard your information.

3. Use of Information

3.1 By using Shopfront Media’s services and website you consent to us using and disclosing your information both for the purposes for which we have collected it (including by providing your information to a third-party payment processing provider in connection with payment or billing for the provision of services to you) and for other purposes related to marketing and advertising our services and the services of other entities with whom we have relationships, where permitted by law and your consent.

3.2 We may use your information for a range of different purposes, including:

• to verify your identity and for fraud checking;
• to provide products and services to you, includingShopfront Media and its analytics features;
• to provide you with information about those products and services to assist you with enquiries or purchases;
• to enhance your experience with our services;
• to provide you with better customer service;
• to operate, maintain, and improveShopfront Media and our other services;
• to generate anonymized and aggregated statistical data, including from camera analytics, for research, service improvement, and reporting to clients (this data will not identify individuals).

3.3 We may transfer Personal Information to related bodies corporate and unaffiliated service providers in locations beyond Australia (including, but not limited to, countries where reputable cloud service providers host data, such as the United States of America, Singapore and New Zealand) in the course of storing that Personal Information and when using or disclosing it for one of the purposes referred to above. When transferring Personal Information to foreign jurisdictions, we may take steps to ensure the overseas recipient of the Personal Information does not breach the Australian Privacy Principles in relation to that Personal Information. However, we may be unable to ensure the overseas recipient may not be subject to privacy obligations equivalent to those under the Privacy Act and could be compelled by foreign law to make disclosure of the information. By using our services, you consent to us making the disclosure to overseas recipients on that basis.

4. How We Hold Your Information

4.1 We may store your information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers (e.g., secure cloud storage). We take the privacy and security of your information seriously and we are committed to maintaining the security of your information under our control. We use a combination of technical solutions, security controls (such as encryption, access controls) and internal processes to help us protect your information and our network from unauthorised access and disclosure.

5. Why We Disclose Your Information

5.1 We may disclose your information to third parties who provide services to us, including organisations and contractors that assist us with the purposes for which we use your information. These services include:

• customer/client enquiries and support;
• installation, maintenance and repair services forShopfront Media (if applicable);
• payment processing;
• data storage and cloud computing services;
• email delivery services (transactional and service-related communications);
• market research, marketing and telemarketing (where you have consented);
• as required or authorised by law; and
• to third parties who assist us to manage or develop our business and corporate strategies and functions, including our corporate risk or funding functions.

5.2 We will take reasonable steps to ensure that these third parties are bound by privacy obligations in relation to the protection of your Personal Information.

6. Links

6.1 Our services or website may contain links to other websites and those third-party websites may collect Personal Information about you. We are not responsible for the privacy practices of other businesses or the content of websites that are linked to our services. Luxton Park Labs encourages users to be aware when they leave our site or service and to read the privacy statements of each and every website that collects personally identifiable information.

7. Security and Storage

7.1 Luxton Park Labs places great importance on the security of all information associated with our customers and contractors. We have security measures in place to protect against the loss, misuse and alteration of Personal Information under our control. This includes technical safeguards like encryption, firewalls, and secure server environments, as well as procedural safeguards.

7.2 Personal information is de-identified or destroyed securely when no longer required by us for legal or business purposes.

7.3 Luxton Park Labs retains the information you provide to us including possibly your contact and credit card details (processed via secure third-party payment gateways) to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities.

7.4 Information stored within our computer systems can only be accessed by those entrusted with authority and protected by measures such as password sanctions and multi-factor authentication where appropriate.

7.5 No data transmission over the internet can be guaranteed to be 100 per cent secure. As a result, while we strive to protect users’ Personal Information, Luxton Park Labs cannot ensure or warrant the absolute security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Luxton Park Labs receives your transmission, it makes every effort to ensure its security on its systems.

7.6 Ultimately, you are solely responsible for keeping your passwords and/or account information secret. You should be careful and responsible whenever you are online.

8. Access to and Correction of Personal Information

8.1 Luxton Park Labs is committed to maintaining accurate, timely, relevant and appropriate information about our Users.

8.2 So long as your request for your Personal Information is in accordance with the Australian Privacy Principles, then we will give you access to that information.

8.3 Inaccurate information will be corrected upon receiving advice to this effect from you. To ensure confidentiality, details of your Personal Information will be passed on to you only if we are satisfied that the information relates to you.

8.4 If we refuse to provide you with access or correct the Personal Information held about you by us, then we will provide reasons for such refusal.

8.5 If you require to access or correct your Personal Information, please contact us at huw@shopfront.media.

9. Complaints

9.1 If you have a complaint about our Privacy Policy or the collection, use or safe disposal or destruction of your Personal Information, your complaint should be directed in the first instance to us, by emailing us at huw@shopfront.media.

9.2 We will investigate your complaint and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of Personal Information held by us about you in accordance with the Commonwealth Privacy legislation. If you are not satisfied with the outcome of this procedure then you may request that an independent person (usually the Commonwealth Privacy Officer) investigate your complaint.

10. Changes to Policy

10.1 If Luxton Park Labs changes its Privacy Policy, it will post changes on this Privacy Policy page so that users are always aware of what information is collected, how it is used and the way in which information may be disclosed. As a result, please remember to refer back to this Privacy Policy regularly to review any amendments.

11. Contacting Us & Data Deletion Requests

11.1 In accordance with global privacy standards, users have the right to request the deletion of their personal data. To initiate a data deletion request, please submit a written request via email to huw@shopfront.media. Ensure your request includes sufficient details to verify your identity, such as account information or other identifying factors.

11.2 Upon receipt of a valid request, we will promptly assess and fulfil the deletion process in compliance with applicable data protection laws. Please note that certain data may be retained for legal, regulatory, or legitimate business purposes (e.g., transaction records, compliance with legal obligations). We will inform you if this is the case.

11.3 We are committed to safeguarding your privacy and ensuring a transparent and efficient data deletion process across different jurisdictions.

11.4 Should you wish to read more information on privacy legislation or the Australian Privacy Principles we recommend that you visit the Australian Information Commissioner’s website at www.oaic.gov.au which contains important information about privacy laws in Australia.

11.5 For any other queries regarding this Privacy Policy or our privacy practices, please contact us at huw@shopfront.media.

12. Your Rights Under UK and EU Data Protection Law

12.1 If you are located in the United Kingdom or European Economic Area, you have additional rights under the UK General Data Protection Regulation (UK GDPR) and/or the EU General Data Protection Regulation (EU GDPR). These rights include:

• Right of Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request that we delete your personal data in certain circumstances.
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where we rely on legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time.

12.2 To exercise any of these rights, please contact us at huw@shopfront.media. We will respond to your request within one month.

12.3 You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.

13. Cookie Policy

13.1 Our website uses cookies and similar technologies. Cookies are small text files stored on your device that help us provide and improve our services.

13.2 We use the following types of cookies:

• Essential Cookies: These are necessary for the website to function properly, including session management and authentication. These cookies do not require consent.
• Analytics Cookies: We use PostHog to understand how visitors interact with our website. These cookies help us improve our services. We only set these cookies with your consent.

13.3 When you first visit our website, you will be presented with a cookie consent banner. You can choose to accept or reject non-essential cookies. You can change your preferences at any time by clicking the "Cookies" link in our website footer.

13.4 You can also control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling cookies may affect the functionality of our website.

14. Lawful Basis for Processing

14.1 Under UK and EU data protection law, we must have a lawful basis for processing your personal data. We rely on the following lawful bases:

• Contract: Processing necessary to perform our contract with you (e.g., providing our services, managing your account, processing payments).
• Legitimate Interests: Processing necessary for our legitimate business interests, where these are not overridden by your rights (e.g., improving our services, ensuring security, anonymized analytics from our display devices).
• Consent: Where you have given us explicit consent to process your data for a specific purpose (e.g., analytics cookies, marketing communications).
• Legal Obligation: Processing necessary to comply with our legal obligations (e.g., tax records, fraud prevention).

15. International Data Transfers

15.1 Our primary database infrastructure is hosted in the United Kingdom (London). Some of our service providers, including analytics and file storage services, are located in the United States.

15.2 When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK or EU authorities;
• The EU-US Data Privacy Framework for US-based processors;
• Transfers to countries with adequacy decisions; or
• Other legally recognised transfer mechanisms.

15.3 For more information about the safeguards we use, please contact us at huw@shopfront.media.

16. Acceptance

16.1 You accept that your use of this site and/or Shopfront Media services includes your acceptance of this Privacy Policy.