Privacy Policy

Last Updated: 26.11.2025

1. Privacy Policy

CargoMax Pty Ltd ABN 93 626 171 051 (CargoMax, we, our, us) is committed to complying with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act).

If you are a resident of the European Union, European Economic Area or the United Kingdom, CargoMax is also committed to complying with the GDPR (as defined at section 16 of this Privacy Policy).

This Privacy Policy sets out the way in which CargoMax collects, uses, stores and discloses your personal information when you access or use our “CargoMax” software (Platform).

This Privacy Policy may be updated from time to time. If practical, we will endeavour to notify you of any updates to our policy (eg through push notifications within our website or software products, or via email).

2. What is personal information?

The Privacy Act defines personal information as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Personal information includes sensitive information, which is defined under the Privacy Act as information or an opinion about a person’s race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.

3. Types of personal information we collect

The particular types of personal information that we collect will depend on the way you use our Platform.

We may collect:

a. your full name, email address and other contact details, including mailing and billing address;
b. login credentials;
c. if you choose to upload a profile picture, your image and likeness; and
d. information relating to your use of our Platform that allow us to improve or personalise your use of our Platform, such as details about your interactions with the Platform, your account preferences and configurations or support tickets; and
e. device information, such as your IP address, operating system and hardware specifications.

4. How do we collect personal information?

We collect personal information from:

a. you directly, for example when you create an account on our Platform;
b. content you or other users provide through, or upload to, our Platform;
c. our suppliers, contractors, related entities, related bodies corporate or associated entities; and
d. from public records or other publicly accessible sources.

Unless it is impracticable, we will provide you with the source of your personal information if requested.

5. Anonymity and pseudo-anonymity

Due to the nature of our Platform, it is not practical for us to interact or communicate with you on an anonymous basis or using a pseudonym. We require your personal information in order to provide you access to our Platform, or respond to any questions, concerns or inquiries you may have.

6. Purpose of collecting personal information

6.1 General

We collect, use and hold your personal information for the following purposes:

a. to enable you to register to, and use, our Platform or other products and services within the Platform;
b. to request payments of subscription fees;
c. to carry out statistical analysis and improve or personalise our products and services to you;
d. to optimise device compatibility and security of the Platform;
e. to respond to your comments, requests and inquiries through the Platform;
f. for marketing (including direct marketing) and business development activities;
g. to conduct user surveys (such as, user satisfaction and quality assurance surveys);
h. to comply with a law, regulation, court order or other legal process;
i. to investigate or report suspected unlawful activity; and
j. to protect, enforce or defend our rights.

We will not use your sensitive information for direct marketing purposes.

6.2 Direct marketing

If you have provided your consent to receive direct marketing communications or it is otherwise within your reasonable expectation that we send you direct marketing communications in light of your interactions with us, we may use your personal information (but never your sensitive information) to provide you with information about our products or services that we believe may be of interest to you (including any newsletters, updates, offers, promotions or other benefits) via email, post, telephone or other direct contact methods.

If you no longer wish to receive any marketing communications or material from us, or do not want your information used or disclosed for direct marketing purposes, you may opt out by clicking the ‘Unsubscribe’ button in our communications to you.

7. Who do we share your personal information with?

We may share or disclose your personal information to:

a. the organisations and individuals who assist us to deliver or support our Platform or services, namely:

  • (i) Wilhelmsen Port Services AS, Hunter Marine Surveyors and our other related entities, related bodies corporate within our corporate group (Group Entities); and
  • (ii) our service providers and partners (such as IT or cloud storage service providers, marketing service providers or our third-party payment processing platform provider);

b. our professional advisers, eg lawyers and accountants;
c. law enforcement officers, regulators, courts and government agencies, if permitted or required:

  • (i) by law, regulation, court order or other legal process;
  • (ii) to assist in the prevention or detection of crime;
  • (iii) to improve the safety of our Platform;
  • (iv) in order to protect our or any user’s rights; or
  • (v) to prevent a threat to any person’s life, health or safety; and

d. any purchaser or prospective purchaser of our business, including in the case of bankruptcy, a merger, acquisition, reorganisation, sale of assets or assignments, or due diligence in respect of any such transactions.

8. Overseas disclosure of personal information

We may disclose your personal information to our overseas Group Entities and service providers who are located in countries outside of Australia (including, without limitation, Norway, Singapore, France, Germany and the Philippines) and assist us with providing and maintaining our Platform. However, we will only disclose your personal information to these locations and overseas entities if you have consented to us sharing your personal information with those entities to use, store or process, or if we are legally required or authorised to share your personal information with those entities.

By creating an account on our Platform, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that:

a. Australian Privacy Principle 8.1 does not apply to our disclosure of your personal information; and
b. countries outside of Australia do not always have the same privacy protection obligations as Australia in relation to personal information, and you may not be able to seek redress in an overseas jurisdiction. Additionally the overseas recipient is subject to foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority. However, we take reasonable steps to ensure that any third parties based outside Australia to whom we disclose your personal information, uses and holds your personal information in a secure manner.

If you do not agree to the disclosure of your personal information outside Australia, do not create an account or otherwise submit personal information to us.

9. Automated decision-making

We may process your personal information using semi- or fully- automated decision-making systems, being any computer program or artificial intelligence to make, or do something that is substantially and directly related to making a decision that could significantly affect the rights or interests of an individual. We have set out some examples below:

  • The billing address and banking information you provide to third-party payment processing software is assessed to determine your eligibility to access and use the Platform based on your banking location. If such software identifies that your billing address or bank is not located in the Included Countries (as listed on the Website), we will not allow you to register to or otherwise access or use the Platform.

If section 16 (GDPR) applies to you, you expressly consent to us Processing of your Personal Data using the automated decision-making systems as set out in this section 9.

10. Third-party websites

Our Platform may include links to other websites or services operated by third parties. This privacy policy does not apply to the data processed by such third-party websites or services, and we have no control over the actions of those third parties in respect of your personal information.

11. Cookies

When you use our Platform, we (either directly or through our third-party service providers) may use “cookies”, traffic measurement software or other similar technologies to personalise or improve your user experience, including:

a. Necessary. These cookies help us make the Platform usable by enabling basic functions such as, page navigation.
b. Preferences. These cookies allow us to recognise you when you access our Platform, and remember your selected preference.
c. Statistics. These cookies help us understand how you use our Platform, how effective our marketing campaigns are, or to help us customise our Platform for you.
d. Marketing. These cookies allow us to collect information about your activities on our Platform (including the content you viewed and links you clicked), so we can present advertisements based on your activities.

In using cookies, we may collect data including:

e. your name or username;
f. your IP address and device identifiers;
g. your account preferences and configurations;
h. your movements on the Platform (such as, content clicked);
i. the referring URL; and
j. campaign tracking information (such as, UTM parameters).

If you do not want your information to be collected through the use of cookies or traffic measurement software, your device and/or browser may enable you to delete or “turn off” cookies or some of the measurement software features. However some or all parts of our Platform may not function properly if these features are disabled.

12. De-identified data

We may use de-identified and aggregated forms of information for any purpose, including without limitation, statistical analysis, product or service development or any other commercial purpose. We take reasonable steps to remove or deidentify your personal information so that this data cannot be associated to you.

13. Data retention

We will store your personal information to manage your subscription to our Platform or as is required for some other purpose for which your information was collected, as set out in this Privacy Policy.

We will store your personal information as follows:

  • if you hold an Explorer Licence (as defined under the EULA available at: https://cargomax.pro/legal/eula): for 12 months after you sign up to use our Platform; or
  • if you hold or upgrade to an Individual Licence (as defined under the EULA): for as long as you hold an active subscription to our Platform and for 12 months after your subscription ends.

We will promptly remove or de-identify your personal information at the end of the applicable data retention period described above, unless:

a. we still require your personal information to carry out any purpose for which the information was collected;
b. required by law or for compliance with applicable law;
c. required for the prevention of fraud; or
d. required to resolve disputes or for other legitimate purposes.

14. Data security

We take reasonable steps to implement and maintain technical and organisational measures to protect your personal information in our custody or control.

In handling your personal information, we will refer to adequacy decisions of the respective privacy regulator or office, the Standard Contractual Clauses and our inter-company agreements, where appropriate.

However data transfers made over the Internet are never 100% secure and if you send us any information, you acknowledge this is done at your own risk.

15. Access and correction

You may request access to your personal information, or correct any inaccurate or out of date information by contacting us using the details at the end of this Privacy Policy.

No fees apply to making a request for access or correction of your personal information, but we may charge for reasonable administrative costs incurred in providing access.

Before we grant you access to, or correct, your personal information, we will make reasonable efforts to verify your identity.

We may refuse your request to access or correct your personal information for legitimate reasons, including if we believe that granting you access will endanger the life, health or safety of any person, would adversely impact the privacy of other individuals, that the request is frivolous or vexatious, or if your personal information is part of ongoing or pending legal proceedings between you and CargoMax.

16. GDPR compliance

16.1 Application to European Union, European Economic Area or United Kingdom residents

If you are a resident of the European Union, European Economic Area or United Kingdom, we are required to comply with the GDPR. In addition to the other sections of this Privacy Policy, this section 16 applies to our processing of your Personal Data.

For avoidance of doubt, where this section 16 applies, any reference to personal information in this Privacy Policy is a reference to Personal Data. This section will not apply if you reside outside the European Union, the European Economic Area or United Kingdom (as applicable).

16.2 Definitions

In this section 16:

“GDPR” means:

a. when used in the context of United Kingdom residents, means the UK General Data Protection Regulation as implemented by the Data Protection Act 2018 (UK);
b. when used in the context of European Union or European Economic Area residents, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 for the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC.

The terms “Controller”, “Data Subject”, “Personal Data”, “Processing”, and “Supervisory Authority” have the meaning given to those respective terms under the GDPR, and their corresponding terms will be construed accordingly.

16.3 Your rights as a Data Subject

As a Data Subject, you have the following additional rights:

a. Access. You may request access to any Personal Data we hold about you and information regarding our Processing of your Personal Data (including the purpose of processing, data retention period, and categories of data involved).
b. Rectification. You may ask us to correct or update any of the Personal Data we hold about you.
c. Erasure. You may request for the deletion of your Personal Data if we no longer require your data for the purpose for which it was collected, or if you withdraw your consent to Processing of your Personal Data and we have Processed your Personal Data without legitimate grounds.
d. Restriction. You may ask us to restrict the processing of your Personal Data, if:

  • (i) you are contesting the accuracy of the Personal Data and you enable the Controller to verify the accuracy of your data;
  • (ii) the Processing of your Personal Data is unlawful and you oppose the erasure of your data, but request a restriction instead;
  • (iii) the Controller no longer needs to process the Personal Data, but you require the Personal Data for legal proceedings; or
  • (iv) you have objected to Processing pursuant to Article 21(1) of the GDPR;

e. Objection. You may object to our Processing of your Personal Data under certain conditions.
f. Data Portability. You may request for us to:

  • (i) provide you your Personal Data in a machine-readable format; or
  • (ii) transfer any Personal Data we hold about you to you or a nominated third party.

16.4 How to exercise your Data Subject rights

If you wish to exercise any of your Data Subject Rights, please contact us using the details set out at section 18 below.

16.5 Complaints to a Supervisory Authority

If you have any concerns or complaints regarding our Processing of your Personal Data or the exercising of your Data Subject rights, you may contact a Supervisory Authority.

17. Complaints

You should contact us immediately if:

a. someone has gained unauthorised access to your personal information;
b. you believe we have breached our privacy obligations (including under the Privacy Act) or your privacy rights in any way; or
c. you wish to discuss any issues regarding our privacy policy or information handling processes.

You can find more information about your rights and obligations in respect of privacy at www.oaic.gov.au or by contacting the Office of the Australian Information Commissioner at:

18. Our contact details

You may contact us at info@cargomax.pro