Client Fabric Tech Limited, Client Fabric Tech Pty Ltd and Client Fabric Tech Private Limited (India) are committed to doing right by you, and this policy explains how we look after your personal information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au

This policy covers the cddp.ai platform, the AFC Challenge and our AFC Programs. Client Fabric Tech Ltd in London is responsible for your information. We follow the Australian Privacy Principles and, for people in the UK, UK data protection law.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include – names, addresses, email addresses, phone, educational and employment information.

On the cddp.ai platform we also collect your profile details (such as years of experience and other certifications), your answers to assessments, your scores and reports, device and connection details, adjustment requests, and your conversations with Manu, our AI coach.

This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our websites www.clientfabric.com, www.cddp.ai, from enquiries and/or applications you submit, tests you complete, from your website, from media and publications, from other publicly available sources, from cookies, and from third parties. We don't guarantee website links or the policy of authorised third parties. We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing. When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership in a political association, religious or philosophical beliefs, membership in a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law

If you ask for adjustments to take an assessment, you may tell us about a health condition or disability. We use that information only to arrange those adjustments and for nothing else.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances, we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

How we use AI

We are an AI first platform, hence AI plays a big part in how our platform works. Here's what that looks like in practice.

In our assessments, AI helps us evaluate your answers across both the knowledge and skills. A human moderator oversees the scoring, and you can always ask for a person to review any result. Your Domain Mastery report is also generated with the help of AI, based on how you performed across several parameters.

Manu, our AI coach, is there to support your learning experience, guiding you through programs, answering questions, challenging your thinking and helping you build your skills. Your conversations with Manu are stored and used only to improve and tailor your learning experience and measure your curiosity quotient. We don't share the actual conversations with your enrolling organisation.

We also use AI to look at how groups of participants are performing, to understand domain mastery across the community, and to improve how our assessments and programs work. None of this is ever linked back to you as an individual.

Our platform uses AI tools built by other companies to power these capabilities — assessments, coaching, reporting and interaction. These tools process your answers and conversations but don't see who you are, and we only work with providers who agree to use your data to help us deliver our services and nothing else.

We don't use your answers, your conversations with Manu, or your profile details to train AI models, and we don't allow the companies that help us to do so either.

Disclosure of Personal Information

Your Personal Information may be disclosed in several circumstances including the following:

• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.

If an enrolling organisation paid for your AFC Challenge, they receive your full report. We'll tell you before you start. If you paid yourself, we share your report only when you say so.

We use other companies to help us run our services, for example payments, AI scoring, hosting and email. They only handle your information to do that job for us, under our instructions.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

Your information may be processed in the UK, Australia or other countries where we or our providers operate. We take steps to keep it protected wherever it goes.

If a data breach puts you at risk, we'll tell you as soon as we can and explain what we're doing about it.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. As a guide, here is how long we keep different types of information:

• Assessment answers, scores and reports: 3 years from completion.
• Conversations with Manu: duration of the program plus 3 years.
• Account and profile details: while your account is active plus 2 years.
• Payment records: 6 years from the transaction (as required by UK tax law).
• Support and complaint records: 3 years from resolution.

However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing. Under UK data protection law, access is normally free. To protect your Personal Information, we may require identification from you before releasing the requested information.

You can also ask us to delete your information, object to how we use it, or ask for a person to review any AI-assisted result. We'll respond within 30 days. If you're not happy with how we've handled things, you can complain to us, or to the Information Commissioner's Office in the UK or the Office of the Australian Information Commissioner in Australia.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Age

Our platform and programs are for people aged 18 and over. We don't knowingly collect information from anyone under 18.

Cookies

Our website and platform use cookies to make things work properly and to understand how people use them. You can manage cookies in your browser settings.

Policy Updates

This Policy may change from time to time and is available on our website. If we make a change that materially affects how we handle your information, we'll let you know.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy, please contact us at:

Client Fabric Tech Limited

128 City Road London EC1V 2NX

cddp@clientfabric.com