Privacy Policy.

This Privacy Policy applies to all Services owned and operated by BWN Group, including:

• briceneilson.com (personal portfolio and writing)
• bwn.group and any subdomains
• Cordint (Software Service)
• BriefedOnline (Software Service)
• ProctorID (Software Service)
• GiftYour.name (Online Service)
• CrowdCollectable.com (Online Service)
• SleepSquare (Software Service and Companion Device)
• Ravendoc (Software Service)
• The Price of Life (publishing project)
• The Cost of Lies (publishing project)
• Any other product, service, application, or work owned or operated by BWN Group

This catch-all policy applies until a Service publishes its own product-specific privacy policy, in which case the product-specific policy will prevail for that Service.

We collect personal information that you provide to us directly, that we generate through your use of the Services, and that we receive from third parties. The categories include:

Information you provide

• Identity information — name, username, date of birth, profile photo
• Contact information — email address, postal address, phone number
• Account credentials — password (stored hashed), security questions, multi-factor authentication tokens
• Payment information — billing name and address, last four digits of payment card; full card data is processed by our PCI-compliant payment processor and is never stored by us
• Content you submit — messages, comments, files, documents, designs, journals, sleep logs, collectables, gift requests, and other user content
• Identity verification information — for ProctorID, government-issued ID images, biometric facial templates, and session recordings

Information generated through use

• Device information — IP address, device identifiers, operating system, browser type, screen resolution, time zone
• Usage information — pages visited, features used, clicks, session duration, referring URLs, in-app events
• Sensor and device data (SleepSquare) — sleep stage, heart rate, ambient light, ambient temperature, audio environment metrics, device pairing identifiers
• Location information — coarse location derived from IP address; precise location only when you grant explicit permission
• Cookies, tags, pixels, and similar technologies

Information from third parties

• Authentication providers (e.g. Sign in with Apple, Google) — limited profile data you authorise
• Analytics, advertising and attribution partners
• Identity verification and fraud prevention partners
• Public sources (e.g. ABN registers, professional directories) where relevant for B2B services

We use personal information to:

• provide, operate, and maintain the Services and any companion devices;
• authenticate users and secure accounts;
• process transactions, subscriptions, and refunds;
• personalise content and recommendations;
• communicate with you about updates, security alerts, and customer support requests;
• conduct identity verification and fraud prevention (including for ProctorID sessions);
• diagnose technical issues and improve product quality;
• conduct research, analytics, and aggregate reporting;
• comply with legal obligations, respond to lawful requests, and enforce our Terms of Service;
• where you have consented, send marketing communications about BWN Group products you may be interested in.

We rely on the following legal bases (where GDPR or UK GDPR applies): performance of a contract, legitimate interests, legal obligation, and your consent.

We do not sell personal information. We share personal information only as described below:

• Service providers — cloud hosting, analytics, payment processing, email delivery, customer support, identity verification, and other vendors who process data on our behalf under written agreements.
• Within BWN Group — across our portfolio of products to enable shared functionality (e.g. a single sign-on across BWN Group services), where lawful.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality safeguards.
• Legal and safety — where required by law, court order, or to protect the rights, property, or safety of BWN Group, our users, or the public.
• With your consent — for any other purpose disclosed at the time of collection.

Our Services are hosted primarily in Australia and the United States. Your personal information may be transferred to, stored, and processed in countries other than your country of residence. Where we transfer personal information internationally, we use contractual safeguards (including the EU Standard Contractual Clauses where applicable) and take reasonable steps to ensure protections consistent with the APPs.

We retain personal information only for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. When personal information is no longer needed, we delete or de-identify it.

For ProctorID identity verification artifacts (ID images, biometric templates, session recordings), retention follows the customer institution’s configured retention schedule, with a default of 90 days unless a longer period is required by the customer or by law.

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorised access, alteration, disclosure, or destruction. These include encryption in transit (TLS 1.2+) and at rest, role-based access control, audit logging, multi-factor authentication for staff, and regular vulnerability management. No method of transmission over the internet or method of electronic storage is 100% secure; we cannot guarantee absolute security.

Depending on where you live, you may have the right to:

• access the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• object to or restrict certain processing;
• request portability of information you have provided to us;
• withdraw consent at any time where processing is based on consent;
• opt out of marketing communications;
• lodge a complaint with a regulator (in Australia, the Office of the Australian Information Commissioner — oaic.gov.au).

To exercise any of these rights, contact us at privacy@bwn.group. We will respond within the timeframe required by applicable law.

The Services are not directed at children under 13 (or under 16 in the EEA/UK), and we do not knowingly collect personal information from such children. If you believe a child has provided personal information to us, please contact privacy@bwn.group and we will take reasonable steps to delete it.

We use cookies, local storage, and similar technologies to operate the Services, remember preferences, perform analytics, and (where you have consented) measure marketing performance. You can manage cookie preferences in your browser settings. Some cookies are strictly necessary and cannot be disabled.

When you download or use a BWN Group app distributed through the Apple App Store, Apple may collect certain information per its own privacy policy. Where we use Apple frameworks such as Sign in with Apple, HealthKit, or App Tracking Transparency, we comply with Apple’s requirements and only collect data with your express permission. For SleepSquare, any health-related data we receive from HealthKit is used solely to provide the Service to you and is not used for advertising or sold.

We may update this Privacy Policy from time to time. Where the changes are material, we will provide reasonable notice (for example, in-app notice or by email). The “Effective” date at the top of this policy reflects the most recent revision.

For privacy questions, requests, or complaints, contact us at:

BWN Group Proprietary Limited
Suite 781, Shop 1536A / 2 Hooker Boulevard
Broadbeach Waters QLD 4218, Australia
Phone: +61 (07) 3088 3453
Privacy: privacy@bwn.group
Legal: legal@bwn.group
Support: support@bwn.group