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 AI 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 AI Product Trainer, we or our service providers may collect:

• Voice and audio data captured via your microphone during an active session
• Transcriptions of your spoken input and AI-generated responses
• A randomly generated, non-identifiable session identifier
• 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

We do not collect your name, email address, or any account credentials through the Trainer. Session identifiers are randomly generated and cannot be linked to a real identity.

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 AI 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 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

Session data (voice recordings, transcriptions, and conversation content) is processed in real time and is not persistently stored on our own servers after your session ends.

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. Session data processed through the AI Trainer is transient and discarded once your session ends. We do not retain voice recordings or conversation transcripts on our own servers.

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: