Privacy Policy

About SwiftRebate

Hawthorn Technologies Pty Ltd (ABN 35 694 551 098) ("we", "us", or "our") operates SwiftRebate, a software platform supporting the Australian residential energy upgrade industry.

This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when you use the SwiftRebate platform.

Hawthorn Technologies Pty Ltd is committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Google API Data Processing

SwiftRebate accesses limited user data through Google APIs (Gmail API) to provide the email-sending functionality you have explicitly authorized.

How We Use Google API Data

• We use Gmail API data solely to send emails on your behalf through the SwiftRebate platform.
• We do not use this data for advertising, marketing, or promotional purposes.
• We do not use this data to train, improve, or develop artificial intelligence or machine learning models.
• We do not use this data for any purpose other than providing the core functionality you have explicitly authorized.

How We Share Google API Data

• We do not sell, rent, or share your Gmail API data with third parties for their own purposes.
• Your data may be shared with our cloud infrastructure provider (Google Cloud) to store and process emails as part of providing the service. This is necessary to deliver the email-sending functionality.
• We do not transfer Gmail API data to third-party AI services.

Your Rights Over Google API Data

• You can disconnect your Gmail account from SwiftRebate at any time through the platform settings. This will revoke our access to your Gmail API data.
• You can also revoke access directly through your Google Account permissions page.

Mobile App Permissions and Location Information

The SwiftRebate mobile app requests certain device permissions to provide its installer, driver, and fleet/dispatch functionality.

Location

• We collect precise (GPS) location, including in the background while a job or delivery route is active, from users in installer and driver roles.
• Location is used to GPS-stamp compliance and installation photos, to confirm on-site presence at a job, and to allow a fleet manager or dispatcher to see live progress on a map and detect arrival at a job site or delivery stop.
• Background location is only collected while a job or route is actively in progress for that user's account. Before requesting background ("Allow all the time") location access, the app displays an in-app explanation of what is collected and why, separate from the device's own permission prompt.
• Location tied to a compliance record (for example, a GPS-stamped installation photo) is retained on the same basis as other compliance records — see Data Retention below. Other location data (such as live route tracking) is retained only as long as needed for job/route history, support, and dispute resolution.
• Location data is shared only with the user's own employer/organisation on the platform (for example, their fleet manager or dispatcher) and is not sold or used for advertising.
• You can disable location access at any time in your device settings. Doing so will disable job/route tracking, arrival detection, and GPS-stamping of compliance photos.

Camera, Photos, and Microphone

• We access the camera and photo library to capture and attach compliance and installation photos, and to scan barcodes and product labels.
• Barcode scanning and text recognition (OCR) are performed on-device; the underlying photo may separately be uploaded as part of a job or compliance record.
• The app requests microphone access for voice notes and future in-app features. Audio is not recorded unless a user actively uses a voice-note feature.

Biometric Authentication

• If a user enables App Lock, the app uses the device's built-in Face ID, Touch ID, or fingerprint prompt solely as a local re-authentication gate. This is a native operating-system prompt — SwiftRebate does not receive, store, or transmit biometric data.

Analytics, Crash Reporting, and Push Notifications

• We use Firebase (Google) to deliver push notifications (for example, job assignments, compliance requests, and schedule updates), to record app usage analytics, and to collect crash and diagnostic reports. This data is associated with the user's account.
• Known sensitive fields (such as names, emails, phone numbers, addresses, GPS coordinates, and licence/accreditation numbers) are automatically removed from diagnostic and crash logs before they are sent.
• We do not use advertising identifiers and do not use these services for cross-app tracking or advertising.

Personal Information We Collect

Platform Users

If you register for or use SwiftRebate, we may collect:

• Your full name
• Business and contact details, including business address, email address, and phone number
• Business information, including ABN, ACN, business name, and trading name
• Professional credentials, including trade licence, accreditation, and registration numbers
• Bank account details where required for payments or Recipient Created Tax Invoices
• Driver licence and vehicle registration information where required
• Login and authentication information
• Information about your use of the platform, including jobs created, documents signed, communications sent, and other platform activity

Residential Customers

Residential customers generally do not create accounts or directly access SwiftRebate. Their information may be entered into the platform by a retailer or other authorised party. This information may include:

• Full name
• Property address
• Email address
• Phone number
• National Metering Identifier (NMI)
• Electricity and gas consumption information
• Billing information
• Solar feed-in information
• Information contained in uploaded energy bills or other documents
• Electronic signatures and acceptance records
• Property and installation information
• Existing equipment information
• Installation and completion records

Automatic Information

When you use SwiftRebate, we may automatically collect technical and usage information such as your IP address, device information, browser or application type, pages accessed, timestamps, error logs, and security-related information.

Information We Do Not Collect

• SwiftRebate does not directly collect or store raw payment card numbers. Payment card processing is handled by our payment service provider.
• We do not intentionally collect health or medical information as part of the ordinary operation of the SwiftRebate platform.

How We Collect Personal Information

We may collect personal information:

• Directly from you when you register, onboard, or use SwiftRebate
• From a retailer or other authorised business that enters information into SwiftRebate on your behalf
• From publicly available professional and regulatory registers
• Through approved connections with relevant regulatory or verification services
• From documents uploaded to the platform
• Through the Consumer Data Right framework where a residential customer has provided the required consent
• From communications and interactions with us
• Automatically when you use the SwiftRebate website or platform

Where personal information is provided to us by another party, that party is responsible for ensuring it has the appropriate authority or consent to provide the information to us where required by law.

How We Use Personal Information

We use personal information to operate, maintain, secure, and improve SwiftRebate. Depending on the circumstances, we may use personal information for:

• Creating and managing user accounts
• Verifying trade licences, accreditations, and professional registrations
• Generating energy upgrade and solar proposals
• Designing solar and energy upgrade systems
• Scheduling and coordinating installations
• Assigning jobs to installers and contractors
• Coordinating deliveries and appointments
• Generating compliance documentation and certificates
• Submitting eligible claims, certificates, and related information to government agencies and regulatory bodies
• Generating invoices and Recipient Created Tax Invoices
• Processing payments to installers and contractors
• Sending job notifications, appointment confirmations, compliance updates, and other service-related communications
• Maintaining platform security and detecting fraud or unauthorised activity
• Providing customer support
• Troubleshooting and improving the platform
• Meeting legal, regulatory, contractual, and record-keeping obligations

We do not sell personal information.

We do not use residential customer personal information for direct marketing.

Consumer Data Right Energy Data

Where a residential customer separately provides the required consent, SwiftRebate may retrieve electricity account information through the Consumer Data Right framework.

This information may include meter information, electricity tariffs, consumption history, billing information, and solar feed-in information.

• CDR data is used to generate accurate solar system designs, energy modelling, and financial proposals for the customer.
• We do not use CDR data for purposes unrelated to the purpose for which the customer provided consent.
• CDR data is deleted when the customer's consent is withdrawn, the consent expires, or the purpose for which the data was collected has been completed, subject to any retention requirements under applicable law or the CDR Rules.

Artificial Intelligence and Machine Learning

SwiftRebate may use artificial intelligence or machine learning technologies and service providers for specific platform functions, such as optical character recognition, document information extraction, compliance photo review, and certificate generation.

• These technologies are used to support the operation of the platform and its compliance-related functions.
• We do not use Gmail API data to train or improve artificial intelligence or machine learning models.
• Where third-party AI or machine learning services are used, we take reasonable steps to ensure that providers handle information only for authorised purposes and apply appropriate security and confidentiality protections.

Disclosure of Personal Information

We may disclose personal information where necessary to provide SwiftRebate and its related services. Depending on the circumstances, information may be disclosed to:

• Cloud infrastructure and hosting providers
• Identity and authentication providers
• Payment processing providers
• Electronic signature providers
• SMS, email, and messaging providers
• Accounting and financial software providers where authorised
• Document processing, OCR, AI, and machine learning service providers
• Professional verification and accreditation services
• Mapping and location service providers
• Analytics, crash reporting, and push notification providers
• Government agencies and regulatory bodies
• Other service providers necessary to operate the platform

We require service providers handling personal information on our behalf to maintain appropriate confidentiality and security measures and to use information only for authorised purposes.

Government and Regulatory Disclosures

SwiftRebate may disclose personal information to government agencies and regulatory bodies where necessary to provide compliance and rebate-related services or where required by law.

This may include organisations and bodies responsible for administering or regulating programs such as the Victorian Energy Upgrades program, Solar Victoria programs, Small-scale Technology Certificate schemes, and relevant building, plumbing, electrical, and energy regulations.

Sharing of Information Within SwiftRebate

SwiftRebate uses role-based access controls to limit access to personal information.

• Retailers can generally access information relating to jobs and customers they manage.
• Installers and contractors can generally access information relating to jobs assigned to them.
• We aim to ensure that users can only access information that is reasonably necessary for their role and authorised activities.

Overseas Disclosure

• SwiftRebate primarily stores platform data in Australia.
• Some third-party service providers used by SwiftRebate may process information outside Australia as part of providing their services.
• Where personal information is disclosed to an overseas recipient, we take reasonable steps to ensure that the information is handled appropriately and in accordance with applicable Australian privacy requirements.

Data Security

We take reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, modification, disclosure, or destruction. Our security measures may include:

• Encryption of stored information
• Encryption of information transmitted over networks
• Role-based access controls
• Multi-factor authentication
• Access monitoring and logging
• Security monitoring and threat detection
• Secure authentication systems
• Regular review of security controls

No method of storing or transmitting information electronically is completely secure. While we take reasonable measures to protect personal information, we cannot guarantee absolute security.

If a data breach occurs that is subject to the Notifiable Data Breaches scheme, we will take the steps required by applicable law.

Data Retention

• We retain personal information only for as long as reasonably necessary to provide our services, comply with legal and regulatory obligations, maintain business records, resolve disputes, and enforce our agreements.
• Some records must be retained for longer periods because of government program or taxation requirements. For example, compliance and financial records may be retained for up to seven years where required by applicable regulatory or taxation obligations.
• CDR data is handled in accordance with the applicable CDR Rules and is deleted when the relevant consent or purpose ends, subject to applicable legal requirements.
• Security and access logs may be retained for a reasonable period to support security monitoring, investigations, and compliance.
• When personal information is no longer required, we take reasonable steps to securely delete or de-identify it.

Access and Correction

• You may request access to personal information we hold about you.
• You may also request that information that is inaccurate, incomplete, or out of date be corrected.
• To make an access or correction request, contact us using the details provided below.
• We may need to verify your identity before processing a request.
• In some circumstances, we may be unable to provide access to certain information where permitted or required by law, including where providing access would unreasonably affect another person's privacy.
• Residential customers whose information is held by SwiftRebate on behalf of a retailer should generally contact the relevant retailer first.

Privacy Complaints

If you believe we have handled your personal information in a way that does not comply with applicable privacy requirements, you may contact us and make a privacy complaint.

Email: privacy@swiftrebate.com.au

We will acknowledge your complaint and investigate it appropriately. We aim to provide a substantive response within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner:

• Website: https://www.oaic.gov.au
• Telephone: 1300 363 992

Cookies and Tracking

• The SwiftRebate platform may use session cookies that are necessary for authentication, security, and the operation of the platform.
• We do not use third-party advertising cookies within the SwiftRebate platform.
• Our public website may use analytics technologies to understand website traffic and improve the website experience.
• You can manage or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the website or platform.

Children's Privacy

• SwiftRebate is a business platform and is not intended for children.
• We do not knowingly collect personal information from children except where information is provided in connection with a legitimate business or service relationship and handled in accordance with applicable law.

Your Privacy Choices

Where applicable, you may:

• Request access to your personal information
• Request correction of inaccurate information
• Request deletion of information where we are not legally required to retain it
• Withdraw consent for services that rely on consent
• Disconnect authorised third-party accounts, such as Gmail
• Contact us about how your personal information is handled

Some information may need to be retained to comply with legal, regulatory, taxation, or government program requirements.

Changes to This Privacy Policy

• We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements, or privacy practices.
• The latest version will always be published on this page together with the applicable effective date.
• Where appropriate, we may notify registered users of material changes by email or through the SwiftRebate platform.

Contact Us

Hawthorn Technologies Pty Ltd

ABN: 35 694 551 098

Location: Delahey, Victoria 3037, Australia

Email: privacy@swiftrebate.com.au

Website: https://swiftrebate.com.au

If you have any questions about this Privacy Policy or how we handle personal information, please contact us using the email address above.