PRIVACY POLICY Broadgun Software Pty Ltd (‘Broadgun Software’) is an Australian Company. 1. We respect your privacy a. Broadgun Software respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information. b. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the EU General Data Protection Regulation (GDPR). c. “Personal information” is information we hold which is identifiable as being about you. This includes information such as your name, email address, or any other type of information that can reasonably identify an individual, either directly or indirectly. d. You may contact us via email [email protected] for further information about this Privacy Policy. 2. What personal information is collected a. Broadgun Software will, from time to time, receive and store personal information you submit to our website, provided to us directly or given to us in other forms. b. You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order. c. We may collect additional information at other times, including but not limited to, when you provide feedback, when you chat with us online using our chat system, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support. d. Additionally, we may also collect any other information you provide while interacting with us. 3. How we collect your personal information a. Broadgun Software collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy. b. By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy. 4. How we use your personal information Broadgun Software may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you. Broadgun Software will use personal information only for the purposes that you consent to. This may include to: a. provide you with products and services during the usual course of our business activities; b. administer our business activities; c. manage, research and develop our products and services; d. provide you with information about our products and services; e. communicate with you; and f. investigate any complaints. If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. 5. Disclosure of your personal information a. Broadgun Software may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy. Personal information is only supplied to a third party when it is required for the delivery of our services. b. If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy. 6. General Data Protection Regulation (GDPR) for the European Union (EU) a. Broadgun Software will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use. b. We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR. c. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it. d. We collect and process personal information only for specified, lawful purposes and limit it to what is necessary for those purposes. Where we rely on consent, we will request your specific consent. We will keep your data safe and secure. e. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation. f. We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law. g. We do not collect or process any personal information from you that is considered “Sensitive Personal Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR. h. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children. i. For individuals in the European Economic Area (EEA), we process personal information on the legal basis appropriate to the activity, including performance of a contract, compliance with a legal obligation, our legitimate interests (balanced against your rights), or your consent where consent is required. You may withdraw consent at any time without affecting processing already carried out lawfully. j. Where a business customer gives us personal information contained in its documents for processing on its behalf, the customer is normally the Controller and Broadgun Software is its Processor. We will process that information only to provide the requested service and on the customer's documented instructions, subject to applicable law. Broadgun Software does not enter into data processing agreements or other customer-specific data protection terms. If your organisation requires a data processing agreement under Article 28 GDPR before personal information may be processed on its behalf, do not enable or use the features described in section 15. k. For people in Germany, we also apply the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) where it applies, together with the GDPR. 7. Your rights under the GDPR Where the GDPR applies to our processing of your personal information, you have certain rights as to how that information is obtained and used. Broadgun Software will respect and facilitate those rights as required by the GDPR. Except as otherwise provided in the GDPR, you have the following rights: a. to be informed how your personal information is being used; b. access your personal information (we will provide you with a free copy of it); c. to correct your personal information if it is inaccurate or incomplete; d. to delete your personal information (also known as “the right to be forgotten”); e. to restrict processing of your personal information; f. to retain and reuse your personal information for your own purposes; g. to object to your personal information being used; and h. to object against automated decision making and profiling. Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy. We may ask you to verify your identity before acting on any of your requests. You also have the right to lodge a complaint with the data protection supervisory authority in the EEA country where you live or work, or where you believe an infringement occurred. In Germany, this will generally be the competent federal-state (Land) data protection authority. We encourage you to contact us first so that we can try to resolve your concern. 8. Hosting and International Data Transfers a. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. These may include, but are not limited to, Australia and Canada, where our hosting facilities reside, and countries in which our service providers (including Google for Gemini AI services) process data. b. Where GDPR-protected personal information is transferred outside the EEA to a country not recognised as providing adequate protection, we use an applicable transfer mechanism, such as the European Commission's Standard Contractual Clauses, together with supplementary measures where required. Further information about relevant transfer safeguards may be requested at [email protected]. 9. Security of your personal information a. Broadgun Software is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. b. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft. 10. Access to your personal information a. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected]. b. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law. 11. Complaints about privacy a. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to [email protected]. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. 12. Changes to Privacy Policy a. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy. 13. Website a. When you visit our websites (those with suffixes, but not limited to, broadgun.com, pdfmachine.com), we may collect certain information such as date and time, your device type, browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service. b. Cookies To improve your experience on our site, we use ‘cookies’. Cookies are an industry standard and most web sites use them. Cookies are very small files your browser stores on your computer which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. c. Website analytics Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics is a service which transmits website traffic data to Google servers in the USA. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google. d. Live Chat Our live chat may use google Gemini to handle AI queries. Chat history is stored on broadgun servers to assist in future customer service operations. e. Social Media Sharing Broadgun Software also uses interfaces with social media sites such as Facebook, Twitter and others. If you choose to “like” or “share” information from this website through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other Personal Information. f. Stripe and Paypal Broadgun Software uses the payment processing companies Stripe & Paypal to handle online payments. Broadgun Software does not have access to credit card numbers and expiry dates from these services. You may find Stripe's privacy policy https://stripe.com/au/privacy and; the Paypal privacy policy https://www.paypal.com/va/webapps/mpp/ua/privacy-full. h. Third party sites Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Broadgun Software is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information. 14. Google API's a. The "pdfMachine merge" product may use the following Google APIs: Gmail, Google Drive, Google Sheets. b. Google APIs use an OAuth consent mechanism which results in the user being presented with a webpage asking if it is ok for pdfMachine merge to access their data. The concept of scopes is used to restrict that access. pdfMachine merge only requests the scopes it needs to do the job at hand. The credentials for the granted access remain on the users machine. At no stage is any data obtained from Google APIs passed to any service or individual at Broadgun Software or any 3rd parties. The data is only used by pdfMachine merge to do its job. The following Google API scopes may be requested: c. gmail.send - Sending emails is core functionality in pdfMachine merge. If the user has a Gmail account, they may choose to use the Gmail API to send emails. d. spreadsheets.readonly - Spreadsheet data is core to pdfMachine merge. The user can choose to use data stored in a google sheet. e. drive.readonly - When the user decides to use a google sheet they are presented with a list of sheets on their google drive. f. drive - This is used when the user wants pdfMachine merge to upload email attachments to their drive account. 15. Optional use of artificial intelligence (AI) services in pdfMachine a. Some pdfMachine features use Google's Gemini models to process document text. These features are optional and pdfMachine can be used without them. They include AI filenaming (which suggests a filename for a newly created PDF), AI extraction of email attributes (which can suggest an attachment name, subject, message body and recipient email address), and AI assistance in our live chat. b. When you use AI filenaming or AI email attribute extraction, pdfMachine extracts only the text needed from the first page of the PDF; the PDF file and its remaining pages are not sent. The request is sent over an encrypted HTTPS connection to Broadgun Software's servers and includes your pdfMachine licence details. Broadgun Software then submits the extracted text, user-interface language and applicable instructions to Google for processing by a Gemini model. AI filenaming may include your custom filenaming instructions. AI email attribute extraction also includes your Windows locale and any custom extraction prompt you have entered. The first page may contain personal information, including names, postal addresses, email addresses, account details or other information contained in your document. c. Gemini processes the supplied content to generate the requested result. For AI filenaming, the result is a suggested filename. For AI email attribute extraction, the result may contain a suggested attachment name, email subject, email body and a single recipient email address found in the document. Google acts as an AI service provider/subprocessor for this processing and handles data under its applicable privacy and data-processing terms: https://policies.google.com/privacy . Processing may occur outside Australia or the EEA as described in section 8. d. Broadgun Software does not store or log the first-page document text submitted for these features; it is processed in memory to fulfil the request. To administer AI credits and operate the service, we keep a record containing your licence details, user and computer name, date and time, credits used, and the result returned. Accordingly, for email attribute extraction the retained result may include the generated attachment name, subject, body and recipient email address. For AI filenaming, we may also retain custom filenaming instructions. We retain these records only for as long as reasonably necessary for credit administration, support, security and legal obligations, after which they are deleted or de-identified. e. Gemini output may be inaccurate or may identify the wrong recipient. You are responsible for reviewing a suggested filename and all generated email fields before use. If you enable a separate setting that automatically sends an email when a recipient is present, an AI-supplied address may be used without another prompt; use that combination only after considering the risk. These features do not make decisions that produce legal or similarly significant effects about individuals on Broadgun Software's behalf. f. You can stop further document content being sent at any time. Turn off AI filenaming under Options | General by unticking "AI filenaming". Turn off automatic email extraction under Options | Email by unticking "AI Extraction enabled", and do not click "Auto fill using AI" in the compose window. Settings are maintained per pdfMachine printer. g. For individual users, processing is necessary to provide the optional feature that they request. For business use involving EEA personal information, the organisation using pdfMachine is responsible for establishing its lawful basis, giving any required notice to the people whose data appears in documents, limiting submitted content, and avoiding special-category or other highly sensitive data unless its use is lawful and appropriate. Broadgun Software processes customer document text on the customer's behalf as described in section 6. 15 September 2026