Privacy policy

Version Effective Date: 23 October 2026

MakerX Pty Ltd (ABN 54 651 621 966) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you or when you use one of our platforms, including QRX Codes (Platform).

This Privacy Policy takes into account the requirements of thePrivacy Act 1988 (Cth). In addition to the Australian laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679 (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR). Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity Data including your name, age, and gender.
• Contact Data including your address and email.
• Financial Data including bank account and payment card details (through our third party payment processor, who stores such information and we do not have access to that information).
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies), and communications with our website.
• Profile Data including your username and password for the Platform, profile picture, purchases or orders you have made with us, content you have generated using the Platform, and support requests you have made.
• Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional dataincluding where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
• Sensitive informationis a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

• when you provide it directly to us, including face-to-face, over the phone, over email, or online;
• when you complete a form, such as registering for any events or newsletters, or responding to surveys;
• when you use any website we operate (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);
• when you scan a QR code made with QRX: the time of the scan, the approximate city and country your internet (IP) address places you in (the address itself is not kept), the kind of device, its operating system and browser, your preferred language, and the site or app the link was opened from. The code’s owner sees these as scan analytics, with nothing that identifies you;
• from third parties, such as our payment processor or user management system provider; or from publicly available sources.

Why we collect, hold, use and disclose personal information

We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Our disclosures of personal information to third parties

Personal information:We may disclose personal information to:

• our employees, contractors and/or related entities;
• IT service providers including Clerk, data storage, web-hosting and server providers;
• marketing or advertising providers;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators or processors;
• our existing or potential agents or business partners;
• if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser's advisers and may be among the assets transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytics providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics

We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.

You can opt-out of Google Analytics Advertising Features from the cookie consent banner displayed when you first visit the site or by specifying your cookie consent preferences.

To find out how Google uses data when you use third party websites or applications, please see here.

Overseas disclosure

We store your personal information in Australia. Where we disclose your personal information to third parties, those third parties may store, transfer or access personal information overseas. We will only disclose your personal information overseas in accordance with the applicable laws.

Your rights and controlling your personal information

• Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.
• Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
• Restrict and unsubscribe:To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
• Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
• Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect 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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of online payment services.
• Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our website and to see how visitors move around our website when they are using them. This helps us to improve the way our online Services work, for example, by ensuring that users find what they are looking for easily.
• Targeting and advertising cookies.These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use, their category, and the purposes for which we use them in the table below:

You can choose to opt out of all non-essential cookies via the cookie banner or by specifying your cookie preferences. Alternatively, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party's websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from single sign-on accounts

If you connect your account with us using a single sign-on account, such as Google, we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.

We use the personal information we receive from the single sign-on provider to create a profile for you on our Platform.

Using QRX through AI assistants

You can use the Platform from AI assistants such as ChatGPT and Claude, and from other apps that support the Model Context Protocol (MCP), through our MCP server. When you do, the following applies in addition to the rest of this Privacy Policy.

• What we receive: only what your assistant sends to our tools when it makes or looks up a code for you: the prompt describing the picture, the destination link, the style, the change you ask for in a variation, and the ids of your codes. We also receive your account identity, through the sign-in token your assistant obtains when you sign in with your QRX account (OAuth), or through the API key you have given it.
• What we do not receive: your chat history, the rest of your conversation, files you share with the assistant or your other apps and tools. The assistant's provider handles your conversation under its own privacy policy.
• What we keep: codes made through an assistant are stored in your account with their prompt, destination link, style and generated image, in the same way as codes made on our website, and count towards your account's usage. We also keep counts of the requests made from your account, for rate limits and usage reporting.
• Sign-in tokens and API keys: we verify the sign-in token or API key on each request to identify your account. We do not store sign-in tokens beyond the request they come with. API keys are stored only in a form that cannot be turned back into the key.
• What we return: the details of your codes (such as their status, image, short link and destination), how many codes your account has left, and, when your assistant asks, the name and email address of the connected account.
• Disconnecting: you can disconnect QRX from your assistant at any time, and revoke an API key on the API keys page. Codes you made stay in your account until you ask us to delete them.

The picture behind each code

When we make a code, we also keep the picture it was drawn from, without the code in it (the base image). The following applies to it in addition to the rest of this Privacy Policy.

• Kept privately: base images are kept in private storage, apart from your codes' images. We never show them publicly, and they are not part of the code details we show on our website or return through our API or MCP server.
• How we use them: only to make a variation of a code when its owner asks for one, and for support and abuse review by QRX staff.
• Deleting them: we delete your codes' base images when your account is deleted, and the base image of any picture that fails our content checks. In the rare case that a storage error stops a deletion, the image can stay in private storage, where it is still never shown publicly.
• Pictures you upload: if you make a code from your own picture, we check the picture (and any description you add) with Microsoft Azure AI Content Safety before we use it, and we do not keep a picture that fails the check. If you do not describe the picture, an AI model describes it so the code has a description. The uploaded file is kept in private storage for about a day while your codes are made and is then deleted, normally within 25 hours of the upload; each finished code keeps the picture as its base image, as described above.

Feedback you send us

You can send us feedback from our website and our apps. Feedback is private: it goes only to the QRX team, and we never show it to other users or publish it. The following applies to it in addition to the rest of this Privacy Policy.

• What you send: the kind of feedback (an idea, a problem or something else), your message, and, if you add them, an email address for our reply and a screenshot or photo.
• What is sent with it: the page you sent it from, the version of the website or app, a short description of your device or browser (such as “iPhone, iOS 18.2”), your account ID and whether you have a paid plan if you are signed in (or the anonymous ID described under Cookies if you are not), and the code it is about if you sent it from a code. The form shows this before you send it. We use your IP address only to limit how often feedback can be sent, and do not keep it with your feedback.
• Who sees it: the QRX team, through our internal tools: our database and our team chat (Slack), where each message is posted for the team to read.
• Images: we check an attached image with Microsoft Azure AI Content Safety before we keep it, and do not keep or share one that fails the check. A kept image is stored in private storage without its metadata (such as its location), and shown only to the QRX team.
• Your email address: we use it only to reply to your feedback, never for marketing.
• How long we keep it: 12 months, after which we delete it, with any image, from our database and our team chat. If you delete your account, we delete the feedback you sent while signed in at the same time. To have your feedback deleted sooner, email hello@qrx.codes.

Using the QRX browser extension

You can make codes from our extension for Chrome and Edge. When you do, the following applies in addition to the rest of this Privacy Policy.

• The page's address: when you click the QRX button, the extension reads the address of the tab you are on and shows it as the link for your code. It is sent to us only if you make a code with it, and we store it as that code's destination, in the same way as codes made on our website. The extension does not read the content of the page, your other tabs or your browsing history.
• Your prompt and style: the picture description and style you choose are sent to us to make the code and are stored with the code.
• While a code is being made: the extension keeps the request (the link, prompt and style) in your browser's extension storage until the code is finished, so it can carry on if the browser pauses the extension.
• Sign-in tokens and API keys: when you sign in, the extension receives an access token and a refresh token from our sign-in provider, or uses an API key you paste into its settings. It keeps them in your browser's extension storage. It sends the access token or API key to us to identify your account, and the refresh token to our sign-in provider to renew your sign-in. Signing out of the extension deletes them from your browser.
• No tracking: the extension has no advertising, analytics or tracking. We do not sell this information, and we share it only with the service providers described above that help us make, store and deliver your codes.

Using the QRX mobile apps

You can make codes from our QRX apps for iPhone, iPad and Android. When you do, the following applies in addition to the rest of this Privacy Policy.

• Signing in: the app signs in with your QRX account through our sign-in provider (OAuth). It keeps the sign-in tokens it receives in your device's secure storage (the iOS Keychain, or storage backed by the Android Keystore), and deletes them when you sign out.
• What you type: the picture description (prompt), the link and the style you choose are sent to us to make the code, in the same way as on our website.
• Saving and sharing images: the app downloads a finished code's image only when you tap Save or Share, to save it to your photo library or share it. It asks only for permission to add photos to your library, not to read them.
• Notifications: the app schedules its notifications on your device. It does not send us a push token or any device identifier.
• Reports: if you report an image, the report and any reason you give are sent to us so we can review it.
• Feedback: if you send feedback from the app, it is handled as described in Feedback you send us above, including the app’s version and build and your device’s model and system version. To attach a photo, you take it or choose it with the system’s camera or photo picker, and the app reads only that photo.
• No tracking: the apps have no advertising and no analytics or tracking tools, and we do not sell your information.
• Deleting your account: you can delete your account in the app (Account, then Delete account), or as described in How do I delete my account? on our support page.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as 'special categories of data' under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.

Data Transfers

The privacy protections available in the countries to which we send data for the purposes listed above may be less comprehensive than what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

• only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
• including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.

For any questions or notices, please contact us at:

MakerX Pty Ltd (ABN 54 651 621 966)

Email: hello@qrx.codes