Privacy Policy

Enkisonics Pty Ltd (ABN 48 688 943 106)

Trading as GunGov - Australia's Premier Firearms Range Booking Platform

Enkisonics Pty Ltd is committed to protecting your privacy and handling your personal information with care, transparency, and in accordance with Australian law. This comprehensive Privacy Policy explains how we collect, use, disclose, store, and protect your personal information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

Effective Date: November 2025 | Last Updated: November 2025

1. About This Privacy Policy

This Privacy Policy applies to all personal information collected, used, and disclosed by Enkisonics Pty Ltd through:

• The GunGov website (gungov.com.au)
• The GunGov mobile applications (iOS and Android)
• Any related services, features, content, or applications operated by us
• Interactions with our customer support team
• Third-party platforms where we have a presence (e.g., social media)

By using the GunGov platform or providing us with your personal information, you consent to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree with any part of this policy, please do not use our services.

2. What Personal Information We Collect

"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable. We collect the following types of personal information:

2.1 Information You Provide Directly

When you register an account, book range time, or use our services:

• Identity information: Full name, date of birth, gender
• Contact information: Email address, mobile phone number, residential address, postal address
• Firearms licensing information: Licence number, licence type, issuing state/territory, expiry date, licence status
• Account credentials: Username, password (stored as hashed values only)
• Club affiliations: Memberships, club names, member numbers
• Payment information: Payment card tokens (not full card details - see Security Policy)
• Range attendance records: Booking history, attendance logs, firearms compliance activity
• Communication records: Messages sent through our platform, support tickets, emails

2.2 Information Collected Automatically

When you access and use the GunGov platform, we automatically collect:

• Device information: Device type, operating system, browser type and version, unique device identifiers
• Usage data: Pages visited, features used, time spent on platform, navigation patterns, click data
• Technical data: IP address, geolocation data (city/state level), time zone, network connection type
• Log data: Access times, error logs, API requests, authentication events
• Cookies and tracking data: Session cookies, preference cookies, analytics cookies (see Section 11)

2.3 Information from Third Parties

We may receive personal information from:

• Firearms clubs: If you join a club through GunGov, the club may provide your membership details
• Payment processors: PowerBoard by CommBank provides transaction success/failure notifications
• Social media platforms: If you connect your social media accounts (optional)
• Public sources: We do not typically collect information from public sources, but may verify firearms licences with state registries if legally required

2.4 Sensitive Information

We recognize that firearms licensing information may be considered sensitive personal information under Australian privacy law. We collect this information only with your explicit consent and as necessary to provide our services. This information is encrypted, access-controlled, and never shared with third parties except as required by law or with your authorization.

3. How We Use Your Personal Information

We collect, hold, use, and disclose your personal information for the following purposes:

3.1 Service Provision

• Creating and managing your GunGov account
• Processing range bookings and event registrations
• Managing club memberships and subscriptions
• Processing payments and refunds
• Verifying your identity and firearms licensing status
• Maintaining compliance records and attendance logs
• Providing customer support and responding to enquiries

3.2 Platform Improvement and Analytics

• Analyzing platform usage to improve user experience
• Identifying bugs, errors, and performance issues
• Conducting research and development for new features
• Understanding user behavior and preferences
• Testing new features and functionality

3.3 Communication

• Sending booking confirmations and receipts
• Notifying you of upcoming events and bookings
• Sending licence expiry reminders (if you enable this feature)
• Providing important platform updates and service announcements
• Responding to your questions and support requests
• Sending marketing communications (only with your consent - see Section 10)

3.4 Security and Fraud Prevention

• Detecting and preventing fraud, abuse, and security incidents
• Monitoring for suspicious activity and unauthorized access
• Protecting the safety and security of our users and platform
• Investigating and responding to security threats
• Enforcing our Terms & Conditions and user policies

3.5 Legal Compliance

• Complying with applicable laws, regulations, and legal processes
• Responding to lawful requests from government authorities
• Establishing, exercising, or defending legal claims
• Maintaining records as required by law (e.g., financial records for tax purposes)

4. How We Disclose Your Personal Information

We do NOT sell, rent, or trade your personal information to third parties for marketing purposes. We may disclose your personal information in the following limited circumstances:

4.1 Firearms Clubs and Organizations

If you are a member of a firearms club using GunGov, we share your information with that club to:

• Process your membership and bookings
• Allow the club to manage member records
• Enable compliance reporting (e.g., range attendance logs)
• Facilitate club communications with members

Important: Your data is shared only with clubs you have joined or authorized. Clubs are bound by confidentiality obligations and may only use your information for legitimate club management purposes.

4.2 Service Providers

We engage trusted third-party service providers to assist with platform operations. These providers have access to personal information only as necessary to perform their functions and are contractually obligated to protect your information:

• Payment processing: PowerBoard by CommBank (for payment transactions only)
• Cloud hosting: Australian-based infrastructure providers (for data storage and computing)
• Email services: Email delivery platforms (for sending notifications and communications)
• Analytics providers: Web analytics tools (for usage analysis - see Section 11 on Cookies)
• Customer support tools: Help desk software (for managing support tickets)

All service providers are required to sign data processing agreements and are prohibited from using your personal information for any purpose other than providing services to GunGov.

4.3 Legal Requirements and Law Enforcement

We may disclose your personal information if required or permitted by law:

• When compelled by a valid court order, subpoena, or warrant
• To comply with legal obligations under Australian law
• To prevent imminent harm to life, health, or safety
• To investigate suspected criminal activity or fraud
• To respond to lawful requests from government agencies

Transparency Commitment: We do not voluntarily report your firearms range attendance or compliance records to government authorities. We will only disclose such information when legally required and, where permitted, will notify you of such disclosures.

4.4 Business Transfers

If Enkisonics Pty Ltd is involved in a merger, acquisition, asset sale, or bankruptcy, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our platform before any such transfer occurs, and you will have the opportunity to delete your account before the transfer if you do not consent.

4.5 With Your Consent

We may disclose your personal information to other third parties with your explicit consent. For example, if you request that we share information with a particular organization or service, we will do so only after obtaining your clear and informed consent.

5. Data Security and Protection

We implement comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, and destruction. For detailed information about our security practices, please refer to our Security Policy at gungov.com.au/security.

Key security measures include:

• Encryption: All data transmitted to/from our platform uses TLS 1.2+ encryption. Data at rest is encrypted using AES-256.
• Access controls: Strict role-based access controls ensure only authorized personnel can access personal information.
• Password security: Passwords are hashed using bcrypt with unique salts.
• Network security: Firewalls, intrusion detection, DDoS protection, and regular vulnerability scans.
• Data isolation: Multi-tenant architecture ensures your data cannot be accessed by other users or clubs.
• Regular audits: Quarterly security assessments and penetration testing by independent experts.

While we implement industry-leading security measures, no system is 100% secure. We encourage you to use strong passwords, enable two-factor authentication, and promptly report any suspicious activity.

6. Data Retention and Deletion

6.1 Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law:

• Active accounts: Personal information retained while your account is active
• Inactive accounts: Personal information retained for 12 months after last login, then automatically deleted
• Closed accounts: Personal information deleted within 30 days of account closure (except as noted below)
• Payment records: Retained for 7 years to comply with Australian tax and financial record-keeping requirements
• Audit logs: Security and access logs retained for 12 months
• Communication records: Support tickets and correspondence retained for 3 years

6.2 Secure Deletion

When personal information is deleted:

• Data is securely wiped from all production systems
• Data is removed from backups within the backup retention cycle (90 days)
• Cryptographic erasure techniques ensure deleted data cannot be recovered
• Deletion is logged and auditable for compliance purposes

7. Your Privacy Rights

Under the Privacy Act 1988 (Cth) and Australian Privacy Principles, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request access to the personal information we hold about you. You can access most of your personal information directly through your GunGov account dashboard. To request a comprehensive copy of all your personal information, contact us at support@gungov.com.au.

7.2 Right to Correction

You have the right to request correction of inaccurate, incomplete, or out-of-date personal information. You can update most information directly through your account settings. If you cannot update certain information (e.g., firearms licence details that require verification), contact us for assistance.

7.3 Right to Deletion ("Right to be Forgotten")

You can request deletion of your personal information by closing your account. We will delete your personal information within 30 days, except where we are legally required to retain certain records (e.g., financial records for tax purposes).

7.4 Right to Data Portability

You can request a copy of your personal information in a structured, commonly used, machine-readable format (e.g., CSV or JSON). This allows you to transfer your data to another service provider if desired.

7.5 Right to Withdraw Consent

Where we process your personal information based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing before withdrawal.

7.6 Right to Complain

If you have concerns about how we handle your personal information, please contact us first so we can address your concerns. If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• OAIC Website: www.oaic.gov.au
• OAIC Phone: 1300 363 992
• OAIC Email: enquiries@oaic.gov.au

8. How to Exercise Your Rights

To exercise any of your privacy rights or make a privacy-related request:

1. Email us at support@gungov.com.au with the subject line "Privacy Request"
2. Provide your full name, email address, and account username (if applicable)
3. Clearly describe your request (e.g., "I would like to access all my personal information")
4. Provide proof of identity if we request it (to prevent unauthorized access)

We will respond to your request within 30 days. If we need more time, we will notify you of the extension and the reasons for it. There is no fee for making a privacy request, unless the request is manifestly unfounded, excessive, or repetitive.

9. Data Breach Notification

In accordance with the Notifiable Data Breaches (NDB) scheme under the Privacy Act, if we experience a data breach that is likely to result in serious harm to you:

• We will notify the Office of the Australian Information Commissioner (OAIC) within 72 hours of becoming aware of the breach
• We will notify affected individuals via email as soon as practicable
• Our notification will include details of the breach, the personal information involved, the likely consequences, and steps you should take
• We will provide support to affected individuals (e.g., credit monitoring if payment data was compromised)

For more information about our security incident response procedures, refer to our Security Policy at gungov.com.au/security.

10. Marketing Communications

10.1 Consent Required

We will only send you marketing communications (promotional emails, newsletters, feature announcements) if you have explicitly opted in to receive them. We comply with the Spam Act 2003 (Cth) and will never send unsolicited commercial electronic messages.

10.2 Opting Out

You can opt out of marketing communications at any time:

• Click the "Unsubscribe" link at the bottom of any marketing email
• Update your communication preferences in your account settings
• Email support@gungov.com.au with the subject "Unsubscribe"

Important: Opting out of marketing communications does not affect transactional emails (booking confirmations, receipts, account security alerts, etc.), which are necessary for the operation of our services.

11. Cookies and Tracking Technologies

11.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help us provide, secure, and improve our services. We use the following types of cookies:

• Essential cookies: Required for platform functionality (e.g., session management, authentication). These cannot be disabled.
• Performance cookies: Collect anonymous usage statistics to help us improve the platform.
• Functional cookies: Remember your preferences (e.g., language, theme settings).
• Analytics cookies: Track page views and user behavior to analyze platform performance.

11.2 Managing Cookies

You can control cookies through your browser settings:

• Block all cookies (may affect platform functionality)
• Delete existing cookies
• Allow cookies only from specific websites
• Receive notifications when cookies are set

For instructions on managing cookies, consult your browser's help documentation.

12. Children's Privacy

GunGov is not intended for use by individuals under 18 years of age. We do not knowingly collect personal information from children. Our Terms & Conditions require users to be at least 18 years old and hold a valid firearms licence.

If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete that information as soon as possible. If you believe we have collected information from a child, please contact us immediately at support@gungov.com.au.

13. International Data Transfers

Data Sovereignty: All personal information collected through GunGov is stored on servers located exclusively within Australia. We do not transfer your personal information to overseas countries. This ensures:

• Your data remains subject to Australian privacy laws
• Your data is not subject to foreign government surveillance or access laws
• Compliance with APP 8 (Cross-border disclosure of personal information)

If our data storage arrangements change in the future, we will update this Privacy Policy and notify you in advance.

14. Third-Party Links and Services

The GunGov platform may contain links to third-party websites, applications, or services (e.g., social media platforms, firearms dealers, range facilities). This Privacy Policy applies only to GunGov and does not cover third-party services.

We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third-party services before providing them with your personal information.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

• Our data collection, use, or disclosure practices
• Australian privacy laws and regulations
• Our business operations or services
• Technology and security best practices

When we make material changes to this Privacy Policy:

• We will update the "Last Updated" date at the top and bottom of this policy
• We will notify you via email (to the email address associated with your account)
• We will display a prominent notice on the GunGov platform
• We may require you to review and accept the updated policy before continuing to use our services

Your continued use of the GunGov platform after changes to this Privacy Policy indicates your acceptance of the updated policy.

16. Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:

Effective Date: November 2025 | Last Updated: November 2025

This Privacy Policy complies with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Spam Act 2003 (Cth).