Privacy policy: ShareRing Solutions

Effective 15 October 2026.

This policy covers sharering.solutions and our three portals: Accountants (amlctf.sharering.solutions), Bookmakers (wagering.sharering.solutions) and Real Estate (realestate.sharering.solutions), including each business's own address on sharering.solutions.

1. Who we are

ShareRing Solutions is run by ShareRing Group Pty Ltd (ACN 674 152 080, ABN 59 674 152 080), "we" or "us" in this policy. We follow the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Your firm's contract for Solutions is currently with ShareRing Australia Pty Ltd (ABN 76 626 629 963), and our invoices come from ShareRing Pty Ltd (ABN 93 682 952 585). Both are ShareRing group companies. They handle your information only to provide Solutions, and they follow this policy.

Questions or requests: privacyofficer@sharering.network.

Our representative in the UK. We are not established in the UK. Our representative in the UK under Article 27 UK GDPR is Prighter Ltd (UK), 20 Mortlake High Street, London SW14 8JN, United Kingdom. You or the Information Commissioner can contact it about anything in this policy at support@prighter.com.

The ShareRing Me app has its own privacy policy, at https://sharering.network/privacy-policy/.

2. Who this policy is about

• People who visit sharering.solutions or our portal pages.
• People who work at a business that uses Solutions: the owner who signs the business up, and the staff they invite. We call the business a "firm".
• A firm's customers who are sent a link to verify their identity. Section 4 is for you.

3. What we collect from firms and their staff, and why

When a firm signs up

• The firm's name and the web address it picks (for example harbour-accounting.sharering.solutions).
• The owner's work email.
• If the owner signs in with Google or Microsoft: an account ID from Google or Microsoft and the email on that account. Google or Microsoft may share your name and photo during sign-in. We don't keep them.
• A promo or partner code, if you used one.
• How the owner found us: the campaign details in the web address they arrived from (for example, which ad or partner link), the Google Analytics ID from the cookie described in section 5, and when they arrived.

While the firm uses Solutions

• Staff emails and roles (owner, compliance officer, staff), and the sign-in method each person uses.
• The firm's ABN and branding, if added.
• Details of the firm's storage connection (Google Drive or Microsoft 365). The access key is encrypted.
• Case reference numbers and statuses, usage and credit records. These hold no customer names or details.
• Payment records. Card payments go through Stripe. We never see or store card numbers.
• Messages you send us by email or chat.

Why we use it

• To set up the firm's workspace and let the right people sign in.
• To send service emails: sign-in links, invitations, notifications and receipts.
• To bill the firm and keep tax records.
• To help when you contact us.
• To keep the service secure and fix problems.
• To credit a partner who referred the firm (see section 6).
• To see which ads and links bring firms to us and lead to paid use, so we know what our marketing costs.

We may send the owner and staff news about Solutions. Every one of those emails has an unsubscribe link, or email us to stop.

If you're in the UK, our legal grounds are: our contract with your firm (setting up the workspace, sign-in, service emails and billing), our legal duties (tax records), and our legitimate interests (keeping the service secure, helping when you contact us, sending news about Solutions, crediting partners, and seeing which ads and links bring firms to us).

If you don't give us this information, we can't set up a workspace or let you sign in.

4. If a firm asked you to verify your identity

Firms that must identify their customers under the AML/CTF Act use Solutions to do it. If a firm sent you a link, the firm is responsible for your information. It decides what to collect and keeps the records. Please read the firm's privacy policy and contact the firm first with any questions.

What we do for the firm:

• We send your invite. We email you the firm's link. We pass your name and email through to send it, and we don't keep them.
• ShareRing LINK checks your identity. You verify on your phone with the ShareRing Me app. LINK checks your ID document, matches your face to it, and checks sanctions and politically exposed person lists. You agree to this check on the first screen before it starts.
• The results go to the firm's own storage. Your verified details, document images, your answers to the firm's questions, the risk rating, the firm's decision and the report are saved straight into the firm's Google Drive or Microsoft 365. They are not saved on our systems.
• What we keep. Only a case reference number, the case status, and a one-way coded version of your email that lets the ShareRing Me app find your request. It can't be turned back into your email. LINK's own copy of a result is deleted 24 hours after the check.
• ShareRing LINK runs the checks itself. It doesn't pass your details to other identity verification companies.

The firm must keep these records for 7 years under the AML/CTF Act. To see or correct them, contact the firm. If you contact us, we'll pass your request to the firm.

5. Cookies, website analytics and advertising

We use Google Analytics 4 on sharering.solutions and on the public pages of our portals. It helps us see how many people visit, which pages they use, and where they drop out of signing up. We use this to improve the site.

Google Analytics places cookies on your device. These cookies hold a random ID. They don't hold your name or email address. Google Analytics collects information such as the pages you view, how you reached us (for example a search, an ad or a link in an email), your browser and device type, and your approximate location (city or country). Google Analytics 4 does not log or store your IP address.

We don't send your name, email address or account details to Google Analytics. We have turned off Google Signals, and we don't use Google Analytics data to personalise ads or to build advertising audiences. Google keeps this data for 14 months.

When a firm makes its first identity check, and each time it buys credit, our portal tells Google Analytics, along with the amount paid and the Google Analytics ID saved when the firm signed up (see section 3). This lets us see which ads and links lead to paid use. We don't send names, email addresses, the firm's name or ABN.

Google LLC processes this data on our behalf, and it may be stored in the United States and other countries. You can read how Google uses this data at https://policies.google.com/technologies/partner-sites. You can block these cookies in your browser settings, or install the Google Analytics opt-out add-on at https://tools.google.com/dlpage/gaoptout.

We advertise on Google Search. If you click one of our ads, Google adds a click ID to the web address, and the Google Ads tag on our site saves it in a cookie on your device for up to 90 days. If you then sign up, or your firm later buys credit, Google Ads counts it as a result of that ad. This tells us which ads and search terms work and what they cost.

The cookie holds the click ID, not your name or email address. We don't send your name, email address or account details to Google Ads. We don't use Google Ads to follow you with our ads on other websites (remarketing), and we have told Google not to use this data to personalise ads. Google LLC receives this data, including your IP address, and may store it in the United States and other countries. You can see and change how Google uses your information for ads at https://myadcenter.google.com.

We load Google Analytics and the Google Ads tag through Google Tag Manager. Tag Manager doesn't set cookies of its own.

The portals also use cookies to keep you signed in. They're needed for the portals to work.

6. Partner referrals

If a ShareRing partner sent you to us, First Promoter places cookies with a tracking ID and the partner's code. If you then sign up a firm, we tell First Promoter the owner's email so it can credit the partner. First Promoter stores this data outside Australia.

7. Support chat

The chat on our sign-in, signup and portal pages is run by Intercom. If you aren't signed in, the chat doesn't know who you are. If you are, Intercom gets a portal user ID, not your name or email. Whatever you type into the chat goes to Intercom. Intercom stores it in the United States.

8. Who we share information with

We don't sell personal information. We share it only with service providers who help us run Solutions, and only for that:

We may also share information when the law requires it, for example with a regulator or the police.

Sending information overseas. Some of our service providers, including Google, store data outside Australia, mainly in the United States. We take reasonable steps to make sure they handle it in line with the Australian Privacy Principles.

For information about people in the UK that we send to providers outside the UK, we use the UK international data transfer addendum to the standard contractual clauses, or UK adequacy regulations where they exist (such as the UK-US data bridge).

Visitors outside Australia. Our analytics, advertising and referral tools do not load for visitors from the European Union, the European Economic Area, Switzerland or the United Kingdom.

9. Keeping information safe, and for how long

• Access keys and sign-in secrets are encrypted. Sign-in and invitation links work once and expire.
• Our servers and Cloudflare record technical details such as IP addresses to keep the service secure. We keep these logs for up to 90 days.
• We keep firm and staff details while the firm uses Solutions, and billing records for as long as tax law requires (usually 5 years).
• When a firm closes its account, we delete its staff details and the Google Analytics ID saved when it signed up. We keep the billing records and the case reference numbers we need for our own records.

10. Seeing or correcting your information

You can ask what information we hold about you, or ask us to correct it. Email privacyofficer@sharering.network. We'll reply within 30 days. We won't charge you to ask. If we can't give you access or make a change, we'll tell you why.

If you're in the UK, you also have the right to ask us to delete your information, to object to or limit how we use it, and to get a copy to take to another service. Email privacyofficer@sharering.network. The 30 days pauses while we wait for anything we need to confirm it's you.

11. Complaints

If you think we've mishandled your information, email privacyofficer@sharering.network and tell us what happened. We'll look into it and reply within 30 days.

If you're not happy with our answer, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

If you're in the UK, you can also complain to the Information Commissioner's Office (ICO) at ico.org.uk or on +44 303 123 1113.

12. Changes

If we change this policy, we'll post the new version here with a new date. If a change matters for firms, we'll email the owner first.