Privacy Policy — ETHLOK App

Last updated: 28 April 2026

This Privacy Policy describes how Emphire Pty Ltd (ABN [insert ABN]),

trading as Empire Trailer Hire ("we", "us", "our"), collects, uses,

stores, and protects your personal information when you use the ETHLOK

mobile application ("the App").

The App is provided to authorised users (employees, contractors, and

maintenance technicians) for the purpose of managing Igloohome smart

locks deployed across our trailer hire fleet.

1. Information We Collect

When you use ETHLOK, we collect the following information:

Account Information

- Your name, email address, and assigned user role

- Login credentials (passwords are stored in encrypted form only)

Device Information

- Device type, operating system version, and unique device identifier

- Bluetooth identifiers required to connect to Igloohome locks

Lock and Usage Data

- Lock identifiers and location associations

- Sync logs, unlock events, and timestamps

- Activity logs from paired Igloohome locks (e.g. access events,

 battery status, firmware version)

Diagnostic Data

- Crash reports and basic usage analytics to help us improve the App

We do not collect payment information, contacts, photos, location data

beyond what is necessary for lock pairing, or any data unrelated to

the App's function.

2. How We Use Your Information

We use the information collected to:

- Authenticate authorised users

- Enable Bluetooth communication with Igloohome smart locks

- Maintain audit logs of lock access for security and compliance

- Diagnose technical issues and improve the App

- Comply with our legal and contractual obligations

3. How We Share Your Information

We share information only as necessary to operate the App:

- With Igloohome (the lock hardware manufacturer) to enable lock

 communication and synchronisation. Igloohome's privacy practices are

 governed by their own privacy policy at https://www.igloohome.co

- With service providers who support our infrastructure (e.g. cloud

 hosting), under confidentiality obligations

- Where required by law, regulation, or valid legal process

We do not sell, rent, or trade your personal information.

4. Data Storage and Security

Your information is stored on secure servers with encryption in transit

(HTTPS/TLS) and at rest. Access is restricted to authorised personnel

on a need-to-know basis.

While we take reasonable steps to protect your information, no system

is completely secure. You use the App at your own risk.

5. Data Retention

We retain account and lock activity data for as long as you remain an

authorised user, plus a period of up to seven (7) years thereafter to

meet record-keeping obligations under Australian law. Crash and

diagnostic data is retained for up to 90 days.

6. Your Rights

Under the Australian Privacy Act 1988, you have the right to:

- Request access to the personal information we hold about you

- Request correction of inaccurate information

- Request deletion of your information (subject to legal retention

 requirements)

- Lodge a complaint about how we handle your information

To exercise these rights, contact us at the address below.

7. Children's Privacy

ETHLOK is not directed at, and not intended for use by, anyone under

18 years of age. We do not knowingly collect information from minors.

8. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated"

date at the top reflects the current version. Continued use of the App

after changes are posted constitutes acceptance of the revised policy.

9. Contact Us

For privacy questions, complaints, or to exercise your rights:

Empire Trailer Hire (Emphire Pty Ltd)

Email: privacy@empiretrailerhire.com

Website: https://empiretrailerhire.com

If you are not satisfied with our response, you may contact the

Office of the Australian Information Commissioner (OAIC) at

https://www.oaic.gov.au.