Privacy Policy
Cleverer is committed to protecting personal information and handling it responsibly. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when providing the Cleverer platform and related services.
At a glance
1. Who this policy applies to
This Privacy Policy applies to Cleverer, operated by GenFit RealRewards Pty Ltd (ABN 28 600 349 648) trading as Cleverer. It applies to personal information collected through our website, platform, communications, customer onboarding, account administration, certificate verification features, and related services.
Contact details
Cleverer
Operated by GenFit RealRewards Pty Ltd
Sunshine Coast, QLD, Australia
General enquiries: hello@cleverer.au
Privacy enquiries: hello@cleverer.au
Phone: 1300 540 271
2. What personal information we collect
The information we collect depends on how you interact with Cleverer and whether you are a website visitor, account owner, administrator, team member, or certificate verifier.
Account and organisation information
This may include names, email addresses, phone numbers, organisation name, team size, billing contact details, and other information provided during enquiry, onboarding, subscription, or account administration.
Compliance and platform information
This may include user roles, assigned learning paths, completion status, certification records, compliance tracking data, report activity, evidence records, follow-up activity, and certificate verification details.
Technical and usage information
This may include IP address, browser type, device information, access timestamps, activity logs, page visits, and other information reasonably required to operate, secure, and improve the platform and website.
3. How we collect personal information
We collect personal information in a number of ways, depending on how you use Cleverer.
Directly from you
When you submit an enquiry, request a demo, create an account, subscribe, or contact us.
From your organisation
When an account owner or administrator adds team members or assigns platform access.
Automatically
Through website and platform usage, security logs, cookies, analytics, and related technologies.
From service operations
As part of billing, support, compliance reporting, certificate verification, and security monitoring.
4. Why we collect, use, and hold personal information
We collect, use, and hold personal information where reasonably necessary to operate Cleverer, provide our services, support customers, maintain security, and meet legal and business obligations.
To provide the service
Including account creation, organisation setup, user access, compliance tracking, certificate issuance, reporting, customer support, and service communications.
To maintain security and reliability
Including monitoring platform activity, detecting misuse, maintaining backups, managing vulnerabilities, applying updates, and protecting customer data.
To meet legal and operational obligations
Including billing administration, record keeping, responding to lawful requests, and managing issues relevant to privacy, compliance, and service delivery.
5. How we use artificial intelligence
Cleverer may use artificial intelligence tools to support internal operations, improve service delivery, assist with content development, and help us maintain and improve the platform. We use AI as a support tool, not as a replacement for human oversight, business judgement, or legal responsibility.
Current internal use
We may use AI to assist with drafting and refining educational content, website copy, support materials, internal planning, software development, testing, documentation, and operational improvement. Material used in the Cleverer platform is subject to human review.
No automated compliance decisions
Cleverer does not use AI to make automated decisions about an individual’s compliance status, employment status, suitability, legal obligations, access rights, or other outcomes that materially affect individuals. The platform records, organises, and reports information; it does not replace organisational responsibility or human decision-making.
Possible future use
In future, we may use AI to assist with features such as summarising compliance data, identifying possible gaps, improving support responses, generating draft reminders, or helping users understand platform information. If we introduce new AI features that materially change how personal information is handled, we will review and update this policy.
AI safeguards
We do not intentionally use customer personal information to train public or external AI models. Where AI tools are used, we take reasonable steps to limit the personal information involved, apply human oversight where appropriate, and assess privacy, confidentiality, security, and operational risk. We also aim to ensure that AI use remains consistent with the purposes explained in this Privacy Policy.
6. When we may disclose personal information
We may disclose personal information where reasonably necessary to operate the service, support customer accounts, process payments, maintain security, use approved service providers, or comply with legal obligations.
Service providers
We may disclose relevant information to carefully selected service providers that support hosting, infrastructure, communications, payment processing, analytics, security, backups, AI-assisted internal operations, and platform operations.
Payment processing
Payments are processed through third-party payment providers such as Stripe. Those providers handle payment information in accordance with their own terms and privacy practices.
Legal and compliance reasons
We may disclose information where required or authorised by law, including where necessary to respond to lawful requests, protect rights, investigate misuse, or address security issues.
7. How we store and protect personal information
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure.
Australian hosting
Customer data is hosted on Australian infrastructure.
Role-based access
Access is controlled according to role and operational need.
Encryption
Data is protected in transit and at rest using appropriate technical measures.
Security operations
We use backups, logging, patching, and ongoing vulnerability management practices.
8. Overseas disclosure
Cleverer is designed to store customer platform data in Australia and we do not intentionally store core customer platform data outside Australia. If this position changes in future, we will update this policy accordingly.
Important note
Some third-party providers involved in communications, analytics, infrastructure, payment processing, support, security, or AI-assisted internal operations may operate internationally or use international support or sub-processing arrangements. Where relevant, we seek to work with providers that apply appropriate privacy and security controls.
9. Access, correction, and privacy enquiries
You may request access to personal information we hold about you, or ask us to correct information that is inaccurate, incomplete, or out of date.
Access and correction requests
To request access to or correction of personal information, please contact us using the details below. We may need to verify your identity before responding.
Privacy complaints
If you believe we have handled your personal information in a way that does not meet your expectations, please contact us first so we have an opportunity to investigate and respond.
10. Cookies and related technologies
Our website and platform may use cookies and similar technologies to support functionality, security, performance, analytics, and user experience.
Functional use
To remember preferences, maintain sessions, and support core website or platform functions.
Security use
To help detect abuse, protect accounts, and support secure operation of the service.
Analytics and improvement
To understand how users interact with the site or platform and improve performance, usability, and communications.
11. How long we keep personal information
We keep personal information for as long as reasonably necessary to provide the service, maintain records, support customer accounts, meet legal and operational obligations, resolve disputes, and protect the integrity of the platform.
Retention approach
Retention periods may vary depending on the type of information, the nature of the service, the customer relationship, and any legal, regulatory, security, or evidentiary requirements. When information is no longer reasonably required, we will take appropriate steps to delete or de-identify it where practicable.
12. How privacy complaints are handled
If you have a concern about how Cleverer has handled your personal information, please contact us using the details below. We will review your concern and respond within a reasonable time.
Escalating a complaint
If you are not satisfied with our response, you may be able to contact the Office of the Australian Information Commissioner (OAIC). Information about making a privacy complaint is available from the OAIC at oaic.gov.au.
13. Updates to this policy
We may update this Privacy Policy from time to time to reflect changes to our services, legal obligations, operational practices, AI use, service providers, or security measures. The latest version will be published on this page.
Privacy Act, Australian Privacy Principles, and data breaches
Cleverer handles personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs) where they apply to us.
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, and disclosure.
If Cleverer becomes aware of a data breach involving personal information, we will assess the incident and, where required by the Notifiable Data Breaches scheme, notify affected individuals and the Office of the Australian Information Commissioner (OAIC).
Questions about privacy?
For privacy enquiries, access requests, correction requests, or complaints, contact Cleverer at hello@cleverer.au or call 1300 540 271.
