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Data Processing Agreement (DPA)

Last updated: 15 March 2026

This Data Processing Agreement (“DPA”) forms part of the agreement between Zupply Technologies ( ACN 695 799 163) (“Zupply”, “Processor”) and any business using the

Zupply Platform (“Customer”, “Controller”).

This DPA applies where Zupply processes personal data on behalf of the Customer when providing services through the Zupply platform (“Platform”).

This agreement is intended to comply with applicable privacy and data protection laws including:

  •  Australian Privacy Act 1988 (Cth)
  • Australian Privacy Principles (APPs)
  • General Data Protection Regulation (GDPR) where applicable

1. Definitions

Personal Data 

Any information relating to an identifiable individual. 

Processing 

Any operation performed on Personal Data including collection, storage, use, or disclosure. 

Controller 

The entity that determines the purposes and means of processing Personal Data. 

Processor 

The entity that processes Personal Data on behalf of the Controller.

2. Scope of Processing

Zupply processes Personal Data solely to provide the Platform services, including:

  • account management
  • order processing
  • supplier communication
  • analytics and reporting
  • platform security and monitoring

Types of Personal Data processed may include:

  • names
  • email addresses
  • phone numbers
  • business contact details
  •  order and transaction records

3. Obligations of Zupply

Zupply agrees to:

  • process Personal Data only in accordance with Customer instructions
  • implement appropriate technical and organisational security measures
  • ensure personnel handling Personal Data are bound by confidentiality obligations
  • assist Customers with privacy compliance where reasonably required

4. Security Measures

Zupply maintains reasonable security practices including:

  •  encrypted data transmission
  • access control systems
  • infrastructure monitoring
  • secure cloud hosting environments
  • periodic security reviews

5. Subprocessors

Zupply may use trusted third-party service providers (“Subprocessors”) to support platform operations, including:

  • cloud infrastructure providers
  • payment processors
  • analytics providers
  • communications platforms

Zupply will ensure Subprocessors are subject to appropriate data protection obligations.

6. International Transfers

Personal Data may be processed or stored in jurisdictions outside Australia where Zupply or its service providers operate infrastructure.

Where cross-border transfers occur, Zupply will take reasonable steps to ensure Personal Data remains protected.

7. Data Breach Notification

In the event of a data breach affecting Personal Data, Zupply will:

  • investigate the incident
  • notify affected Customers where required by law
  • cooperate with regulatory obligations

8. Data Retention

Zupply retains Personal Data only for as long as necessary to:

  • provide the Platform services 
  • comply with legal obligations 
  • resolve dispute

Upon termination of services, data may be deleted or anonymised according to Zupply’s data retention policies.

9. Customer Responsibilities

Customers remain responsible for:

  • obtaining necessary consent to collect Personal Data
  • ensuring lawful use of the Platform
  • complying with applicable privacy laws

10. Governing Law

This DPA is governed by the laws of New South Wales, Australia.

AI Usage Policy

Last updated: 15 March 2026

This AI Usage Policy governs the use of artificial intelligence features available through the Zupply Platform.

1. AI Features

Zupply may provide artificial intelligence tools including:

  • product recommendations
  • automated purchasing suggestions 
  • supplier matching 
  • analytics insights 
  • messaging or content assistance
  • forecasting tools

These features may use machine learning or automated decision systems.

2. AI Output Disclaimer

AI-generated outputs may not always be accurate, complete or reliable. 

Users are responsible for reviewing and verifying AI-generated results before making business decisions. 

Zupply does not guarantee the accuracy or suitability of AI outputs.

3. Responsible Use

Users must not use AI features to:

  • generate unlawful content 
  • produce misleading product listings 
  • manipulate marketplace behaviour 
  • conduct spam or abusive communications

4. Training Data

Zupply may use aggregated and anonymised platform data to improve AI systems. 

Zupply will not use identifiable personal information for AI training unless permitted by law.

5. AI Limitations

AI systems may:

  • produce inaccurate outputs 
  • generate incomplete recommendations 
  • require human review

Users should not rely solely on AI-generated outputs when making financial or operational decisions.

6. Suspension of AI Access

Zupply may suspend access to AI features where misuse is detected or where AI systems require maintenance or updates.

Marketplace Buyer Terms

Last updated: 15 March 2026

These Buyer Terms apply to businesses purchasing goods or services through the Zupply Platform (“Buyers”).

These terms operate alongside the Zupply Terms of Service.

1. Buyer Accounts

Buyers must create an Account to place Orders on the Platform. 

Buyers are responsible for:

  • maintaining accurate account information 
  • securing login credentials 
  • ensuring authorised use of their Account

2. Placing Orders

When placing an order (“Order”) through the Platform:

  • the Order is submitted to the Supplier 
  • the Supplier may accept or reject the Order 
  • a binding agreement forms between the Buyer and Supplier once accepted

Zupply is not the seller of goods unless explicitly stated.

3. Payment Obligations

Buyers must:

  • pay the full price listed for Orders 
  • use authorised payment methods 
  • ensure payment information is valid

Failure to complete payment may result in cancellation of Orders or suspension of Accounts.

4. Buyer Conduct

Buyers must not:

  • submit fraudulent Orders 
  • intentionally disrupt supplier operations 
  • misuse supplier information 
  • attempt to circumvent Platform fees

5. Returns and Disputes

Return and refund policies may vary between Suppliers. 

Buyers should review supplier-specific terms before placing Orders. 

Disputes regarding goods or services must primarily be resolved between the Buyer and Supplier. 

Zupply may assist with dispute resolution but is not responsible for supplier performance.

6. Buyer Reviews

Buyers may leave reviews and ratings regarding Suppliers and products. 

Reviews must be:

  • truthful 
  • based on genuine transactions 
  • free from abusive or defamatory content

Zupply may remove reviews that violate platform policies.

7. Order Limits

Zupply may impose limits on:

  • order quantities 
  • purchasing frequency 
  • transaction values

These limits may be used to prevent fraud or abuse.

8. Suspension

Zupply may suspend Buyer accounts where: 

  • fraudulent activity is suspected 
  • platform rules are violated 
  • payment obligations are not met

9. Governing Law

These Buyer Terms are governed by the laws of New South Wales, Australia.

For any questions or notices, please contact us at:

admin@zupply.com.au
Zupply Technologies (ACN 695 799 163)