Privacy Policy for Xsights Asset Tracking System (XATS)

Last Updated: July 18, 2025

This Privacy Policy applies specifically to the XATS mobile application (referred to as “XATS App”), developed and operated by Xsights Digital Pty Ltd (ABN: 45 623 659 932), a hardware and software technology company based in Western Australia.

Xsights Digital Pty Ltd is committed to protecting the privacy of your personal information. This policy outlines how the XATS App collects, uses, and manages information, particularly concerning location data, in compliance with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth).

By using the XATS App, you agree to the collection and use of information in accordance with this policy.

1. Our Commitment to Your Privacy

We understand the importance of protecting your privacy. The XATS App is designed with a specific function: to track registered assets using Bluetooth Low Energy (BLE) Beacons. Our data collection practices within the app are strictly limited to this purpose.

2. Information Collected by the XATS App

The XATS App primarily collects the following types of information:
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Location Data

The XATS App collects real-time location data from your mobile device when the app is in use (both in the foreground and potentially in the background, depending on your device settings and app permissions). This location data is solely used for tracking registered assets equipped with BLE Beacons.
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Asset Tracking Data

Information related to the BLE Beacons and the assets they are attached to, including beacon IDs, signal strength, and proximity data, as detected by the XATS App.
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Account Information

If the XATS App requires user login, we may collect minimal account information such as a username and password (hashed) necessary to authenticate and manage your access to the asset tracking functionality. This information is separate from the location data associated with assets.
Important Note on Location Data and Personal Identification: The location data collected by the XATS App is NOT associated with your personal identification. Its sole purpose is to provide location updates for the registered BLE-enabled assets that you are tracking. We do not use this location data to identify or track individual users of the XATS App.

3. How Information is Collected

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Automatically via Device Permissions

Location data is collected automatically by the XATS App through your device’s location services, provided you have granted the necessary permissions. This is essential for the app’s core functionality of detecting and tracking BLE Beacons.
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Directly from User Input (Account Creation)

If applicable, account information (e.g., username, password) is collected directly from you when you create an account within the XATS App to access its features.

4. How Do We Use Your Information?

The information collected by the XATS App is used exclusively for the following purposes:
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Asset Tracking

To enable the core functionality of the XATS App, which is to detect, locate, and track registered assets equipped with BLE Beacons. This involves processing location data to provide accurate positions of your assets.
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Service Provision

To provide you with access to and maintain the functionality of the XATS App, including updating asset locations and managing your registered beacons.
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App Improvement

To monitor the performance and stability of the XATS App and make improvements to its tracking capabilities.
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Security

To protect the integrity and security of the XATS App and the data it processes.

5. Disclosure of Your Information

We will not disclose information collected by the XATS App to third parties unless:
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Service Providers

We may share data with third-party service providers who assist us in operating the XATS App (e.g., hosting providers, database management). These providers are contractually obligated to protect your information and only use it for the purposes for which it was disclosed.
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Legal Requirements

We may disclose information if required by law, court order, or governmental regulation, or if we believe such action is necessary to comply with legal obligations, protect our rights or property, or ensure the safety of our users or the public.
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With Your Consent

Where you have provided your explicit consent for us to do so.
Specifically, location data collected by the XATS App for asset tracking purposes is not shared with any third parties for marketing or other unrelated purposes.

6. Data Security

We implement reasonable technical and organisational security measures to protect the information collected by the XATS App from unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption of sensitive data where appropriate.
• Access controls and authentication procedures for app accounts.
• Regular security reviews.

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

7. Data Retention

We retain information collected by the XATS App only for as long as necessary to fulfil the purposes for which it was collected, including for asset tracking functionality and to comply with legal obligations. Once information is no longer required, we will take reasonable steps to securely destroy or de-identify it.

8. Your Control and Rights

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Device Permissions

You control the XATS App’s access to your device’s location services through your mobile device’s operating system settings. Disabling location services for the XATS App will prevent its ability to track BLE Beacons and registered assets.
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Account Deletion

If the XATS App includes an account feature, you may have the option to delete your account. This process will typically involve deleting personal information associated with your account, and disassociating any asset tracking data from your identity. Please refer to the app’s settings or contact us for specific instructions on account deletion.
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Access and Correction

You have the right to request access to and correction of any personal information we hold about you related to your XATS App account.

9. Children's Privacy

The XATS App is not intended for individuals under the age of 18. We do not knowingly collect personal information from children without parental consent. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.

10. Changes to This Privacy Policy

We may update this Privacy Policy for the XATS Mobile Application from time to time to reflect changes in our practices or legal obligations. We will notify you of any material changes by posting the updated policy within the XATS App or on our website with a revised “Last Updated” date. We encourage you to review this policy periodically.

11. Contact Us

If you have any questions, concerns, or complaints about this General Privacy Policy or our privacy practices, please contact us at:

Xsights Digital
Suite 7, Level 1, 6 Short Street
Fremantle WA 6160 Australia
Email: contact@xsights.com.au
Phone: 1300 490 931

12. Making a Complaint

If you are not satisfied with our handling of your privacy complaint, you can contact the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner (OAIC)
GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992
Website: www.oaic.gov.au