Privacy Policy

FRACTIONUS

PRIVACY POLICY

Last Updated: April 2, 2026

This Privacy Policy describes how Fractionus Group Pty Ltd ABN 37 688 359 926 (“Fractionus,” “Company,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes Personal Information in connection with the Fractionus website, platform, applications, and related services (collectively, the “Services”). This Privacy Policy applies to Personal Information collected from companies and their representatives that use the Services to identify, engage, and manage fractional talent, from professionals who apply to join or participate in the Fractionus network, and from other individuals who access or interact with the Services.

Fractionus operates a platform that helps companies identify, evaluate, engage, and manage fractional talent and allows professionals to apply to join the Fractionus network, create profiles, and participate in matching and engagement opportunities. By accessing or using the Services, you acknowledge the practices described in this Privacy Policy.

CONTENTS

1. Collection of Information

2. Use of Information

3. Data Retention

4. Disclosure of Information

5. Third-Party Service Providers

6. Targeted Advertising and Analytics

7. User Rights and Privacy Choices

8. Security Measures

9. Children’s Privacy

10. Links to Other Sites

11. Cookies and Tracking Technologies

12. Do Not Track Signals

13. California Privacy Rights and Other U.S. State Privacy Rights

14. International Data Transfers

15. Changes to This Privacy Policy

16. Contacting Fractionus

1. Collection of Information

1.1. Information You Provide to Us.

Fractionus may collect Personal Information from and about you in the following ways:

(a) Information You Provide to Us. Fractionus collects Personal Information directly from you when you submit a contact form, request a match, apply to join as talent, create an account, enter into an engagement, communicate with us, or otherwise use the Services.

(b) Information You Provide as a Client or Prospective Client. If you are a client or prospective client, Fractionus may collect your name, company name, job title, work email address, phone number, company size, hiring needs, desired role or expertise, project scope, timing, budget range, engagement preferences, onboarding details, contract details, billing contacts, and the contents of your forms, messages, and communications.

(c) Information You Provide as Talent or an Applicant. If you apply to join the Fractionus network or otherwise participate as talent, Fractionus may collect your name, contact information, professional background, résumé or CV information, work history, areas of expertise, references, portfolio materials, biography, profile photo, availability, rate preferences, interview notes, and other information relevant to evaluating, presenting, or matching you for opportunities.

(d) Account, Profile, and Communications Information. Fractionus may collect account credentials, account settings, profile information, records of platform activity, and information you provide when you contact Fractionus for support or otherwise communicate with us.

(e) Payment and Transaction Information. Fractionus and its payment service providers may collect billing details, transaction records, invoices, payout information, and related financial or tax information. Payment card information generally is processed by third-party payment processors rather than stored by Fractionus directly, although Fractionus may receive limited payment or transaction metadata needed to administer the Services.

(f) Information Collected Automatically. When you access or use the Services, Fractionus may automatically collect information such as IP address, browser type, device type, operating system, referring and exit pages, date and time stamps, page views, clicks, session activity, and similar technical and usage data. Fractionus may also derive approximate location information from IP address or browser or device signals.

(g) Information Collected Through Cookies and Similar Technologies. Fractionus may use cookies, web beacons, pixels, local storage, and similar technologies to operate the Services, maintain sessions, remember preferences, understand usage, improve performance, prevent fraud, support analytics, and support targeted advertising or related marketing activities. You can control certain cookies through your browser settings and, where offered, a cookie preference tool on the Services. Blocking certain cookies may affect platform functionality.

(h) Information from Other Sources. Fractionus may receive Personal Information from other users, referral partners, service providers, payment processors, identity or security vendors, scheduling or communications tools, referral sources, and other third parties that support the operation of the Services.

(i) Biometric Information. If Fractionus uses identity-verification services that collect biometric identifiers or biometric information (such as facial geometry derived from photographs or government-issued identification), Fractionus will disclose such collection at or before the point of collection, obtain any consent required by applicable law, and will not sell, lease, or trade biometric information. Fractionus will permanently destroy biometric information when the initial purpose for collection has been satisfied or within three (3) years of the individual’s last interaction with the Services, whichever comes first, unless retention is required by law.

1.2. Categories of Personal Information We Collect.

Depending on how you use the Services, Fractionus may collect the following categories of Personal Information:

(a) Contact Details and Identifiers, such as name, email address, phone number, account credentials, and similar information;

(b) Client and Project Information, such as company details, hiring needs, engagement scope, budget ranges, and onboarding information;

(c) Commercial and Transaction Information, such as engagement details, invoices, payment status, payout details, and related records;

(d) Communications Content;

(e) Internet or Other Electronic Network Activity Information;

(f) Inferences or Preferences Derived from the Foregoing to improve matching, user experience, and platform operations.

(g) Professional, Employment, and Profile Information, such as job title, employer, work history, biography, portfolio materials, areas of expertise, availability, rate or engagement preferences, and other application or profile information;

(h) Sensitive Personal Information. Depending on how you interact with the Services, Fractionus may collect information that is classified as “Sensitive Personal Information” under applicable state law, such as account log-in credentials in combination with security or access codes, precise geolocation, or other categories defined by applicable state privacy law. Fractionus does not intentionally collect sensitive categories such as racial or ethnic origin, religious beliefs, health information, sexual orientation, or citizenship or immigration status. Where Fractionus collects Sensitive Personal Information, it will do so only as permitted by applicable law and will provide any required notice or obtain any required consent at or before the point of collection.

1.3 Data Minimization. Fractionus collects only the Personal Information that is reasonably necessary and proportionate to the purposes for which it is processed, as described in this Privacy Policy. Fractionus does not collect or process Personal Information beyond what is necessary to provide, operate, improve, and secure the Services and to comply with legal obligations.

2. Use of Information

2.1. How We Use Personal Information.

Fractionus uses Personal Information for the following purposes:

(a) to provide, operate, maintain, support, troubleshoot, and improve the Services;

(b) to manage accounts, profiles, and platform functionality;

(c) to review and vet talent applications and assess fit;

(d) to introduce or recommend talent to clients and facilitate matching and engagements;

(e) to administer onboarding, contracting, billing, payment collection, and payout flows;

(f) to respond to inquiries and provide customer support;

(g) to send administrative, transactional, and service-related communications;

(h) to send marketing or promotional communications consistent with your preferences and applicable law;

(i) to authenticate users and maintain platform security;

(j) to detect and investigate fraud, abuse, unauthorized activity, and security incidents;

(k) to enforce agreements and policies;

(l) to comply with legal, tax, accounting, reporting, and regulatory obligations; and

(m) to analyze how the Services are used in order to improve matching quality, user experience, debugging, quality assurance, and new or improved features.

2.2. Automated Decision-Making and AI. Fractionus may use algorithmic tools, scoring models, or artificial intelligence to support matching, ranking, or recommending talent to clients, or to improve platform operations, fraud detection, and user experience. Fractionus does not use automated processing as the sole basis for decisions that produce legal or similarly significant effects on individuals without human review. Where required by applicable law, Fractionus will provide notice of the use of automated decision-making technology and offer the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. Fractionus does not use Personal Information to train or develop general-purpose AI models. Fractionus maintains human oversight of automated systems used in connection with the Services.

3. Data Retention

3.1. Retention.

Fractionus retains Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to maintain accounts; review applications; facilitate matches and engagements; document transactions; comply with legal obligations; resolve disputes; enforce agreements; protect against fraud and abuse; and maintain appropriate business and financial records. Retention periods may vary depending on the type of information, the context in which it was collected, and applicable legal requirements. To determine the appropriate retention period, Fractionus considers the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which it is processed; whether those purposes can be achieved through other means; and applicable legal requirements. Fractionus will delete or de-identify Personal Information when it is no longer needed for the purposes described in this Privacy Policy, subject to applicable legal obligations.

4. Disclosure of Information

4.1. How We Disclose Personal Information.

Fractionus may disclose Personal Information in the following circumstances:

(a) Disclosures Between Clients and Talent. Because the Services are designed to connect companies with fractional talent, Fractionus may disclose Personal Information between clients and talent as needed to facilitate matching, interviews, and engagements. For example, Fractionus may share a talent profile, experience summary, availability, or rate information with a prospective client, and may share a client’s hiring brief, project scope, company information, or scheduling details with prospective talent.

(b) Service Providers and Contractors. Fractionus may disclose Personal Information to service providers and contractors that perform services on Fractionus’s behalf, such as hosting providers, cloud storage providers, customer support tools, scheduling and communications vendors, payment processors, security vendors, analytics vendors, customer relationship management tools, and similar providers.

(c) Professional Advisors. Fractionus may disclose Personal Information to lawyers, accountants, auditors, insurers, financing sources, and other professional advisors as reasonably necessary for business, legal, tax, compliance, or transaction purposes.

(d) Legal and Safety Disclosures. Fractionus may disclose Personal Information if Fractionus reasonably believes disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request; enforce agreements or policies; protect the rights, property, or safety of Fractionus, users, or others; or detect, prevent, or address fraud, security incidents, or technical issues.

(e) Corporate Transactions. Fractionus may disclose or transfer Personal Information in connection with a merger, acquisition, financing, due diligence process, reorganization, bankruptcy, dissolution, or sale of some or all of the business or assets, subject to customary protections and applicable law.

(f) Disclosures at Your Direction. Fractionus may disclose Personal Information for other purposes at your direction or with your consent.

(g) Aggregated, Deidentified, and Similar Information. Fractionus may create, use, and disclose aggregated, deidentified, or otherwise non-identifiable information for lawful business purposes, including analytics, benchmarking, service improvement, and business planning. Fractionus will not attempt to reidentify deidentified information except as permitted by applicable law.

(h) Advertising and Analytics Partners. Fractionus may disclose or make available certain Personal Information (such as cookie identifiers, device identifiers, IP address, and page-view data) to third-party advertising networks, social media platforms, and analytics providers to deliver targeted advertising, measure advertising effectiveness, and perform audience analytics. These disclosures may constitute “selling” or “sharing” of Personal Information under certain state privacy laws. For information about opting out of such disclosures, see Sections 6.3, 12.2, and 13.5.

5. Third-Party Service Providers

5.1. Third-Party Service Providers.

Fractionus uses third-party service providers to help operate, provide, secure, and improve the Services. These providers may include hosting and cloud infrastructure providers, communications and scheduling tools, payment processors, customer relationship management tools, analytics providers, security and fraud-prevention vendors, customer support tools, and similar vendors that support the operation of the Services. These providers may process Personal Information on Fractionus’s behalf subject to contractual restrictions and applicable law. Fractionus’s current third-party service providers include, without limitation: [Payment Processor Name] for payment processing; [Hosting Provider Name] for cloud hosting and infrastructure; [Analytics Provider Name] for analytics; [CRM Provider Name] for customer relationship management; and [Communications Tool Name] for scheduling and communications. You may refer to each provider’s privacy policy for information about how they process Personal Information. This list may change from time to time as Fractionus engages new providers or discontinues existing ones.

6. Targeted Advertising and Analytics

6.1. Analytics Technologies.

Fractionus may use third-party analytics technologies to understand how users interact with the Services, improve performance, measure engagement, and develop or improve features and functionality.

6.2. Targeted Advertising Technologies.

Fractionus may use third-party advertising technologies, including cookies, pixels, and similar technologies, to support targeted advertising, remarketing, audience measurement, and related marketing activities. These technologies may collect information about your interactions with the Services and other online services over time.

6.3. Sale, Sharing, and Targeted Advertising Disclosures.

Fractionus does not sell Personal Information for money. Fractionus may, however, use third-party advertising cookies, pixels, and similar technologies in ways that may constitute “sharing” of Personal Information or processing for targeted advertising under applicable privacy laws. Where required by applicable law, Fractionus will provide appropriate notice and a method to exercise applicable opt-out rights with respect to such processing.

7. User Rights and Privacy Choices

7.1. Your Privacy Choices.

Depending on how you use the Services and where you are located, you may have the following choices regarding your Personal Information:

(a) Account Information. Where account functionality is available, you may review and update certain account or profile information by logging into your account and editing your settings. You may also contact Fractionus using the contact information below to request correction of certain information.

(b) Email Preferences. You may opt out of marketing emails by using the unsubscribe link in those emails. Fractionus may still send transactional, relationship, legal, security, or service-related communications.

(c) Communications Preferences. If you prefer not to receive non-essential outreach about matches or marketing, you may contact Fractionus using the details below, although Fractionus may continue to send communications necessary to administer an account or engagement.

(d) Cookies and Similar Technologies. You can control certain cookies through your browser settings and, where offered, a cookie preference tool on the Services. Blocking certain cookies may affect platform functionality. Where required by applicable law, Fractionus will also provide a method to exercise applicable opt-out rights with respect to targeted advertising or similar processing based on cookies, pixels, and related technologies.

(e) Text Messaging. If you elect to receive text messages from Fractionus, you consent to receive autodialed or prerecorded marketing messages at the mobile number you provide. Consent is not a condition of using the Services or making a purchase. Message and data rates may apply. You may opt out at any time by replying STOP. Fractionus will not sell, share, or disclose your phone number, SMS consent status, or opt-out choices to any third party for purposes unrelated to delivering the requested messaging services, except to service providers contractually bound to use such information solely on Fractionus’s behalf.

8. Security Measures

8.1. Security.

Fractionus uses reasonable administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, use, alteration, and disclosure. However, no method of transmission over the Internet or method of electronic storage is completely secure, and Fractionus cannot guarantee absolute security.

8.2. Account Responsibility.

If the Services support accounts, you are responsible for maintaining the confidentiality of your account credentials and for activity under your account. If you suspect unauthorized access to or misuse of your information, please contact Fractionus promptly.

8.3. Data Breach Notification. If Fractionus becomes aware of a security breach involving unauthorized access to, or acquisition of, your Personal Information, Fractionus will notify affected individuals and applicable regulatory authorities as required by law. If you believe the security of your information with Fractionus has been compromised, please contact us immediately at privacy@fractionus.com.

9. Children’s Privacy

9.1. Age Restriction.

The Services are intended for businesses and adult professionals. Fractionus does not knowingly permit anyone under eighteen (18) to use the Services, and the Services are not directed to children.

9.2. Children’s Information.

If Fractionus becomes aware that it has collected Personal Information from a child under thirteen (13) without appropriate authorization, Fractionus will take commercially reasonable steps to delete that information.

10. Links to Other Sites

The Services may contain links to third-party websites, applications, or services. Fractionus does not control and is not responsible for the privacy practices, content, or security of those third parties. We encourage you to review the privacy policies of any third-party sites or services you choose to access.

11. Cookies and Tracking Technologies

Fractionus may use cookies, web beacons, pixels, local storage, and similar technologies to operate the Services, maintain sessions, remember preferences, understand usage, improve performance, support analytics, and help deliver and measure advertising and marketing activities. You can control certain cookies through your browser settings and, where offered, a cookie preference tool on the Services. Blocking or disabling certain cookies may affect the functionality of the Services. For more detailed information about the cookies and similar technologies Fractionus uses, the categories of data collected, and how to manage your preferences, please refer to our Cookie Policy [link] and any cookie consent banner or preference tool presented on the Services.

12. Do Not Track Signals

12.1. Do Not Track Signals.

Some web browsers transmit “Do Not Track” signals. Because there is not yet a universally accepted standard for responding to those signals, Fractionus does not respond to browser-based “Do Not Track” signals in a uniform way.

12.2. Recognized Opt-Out Preference Signals.

Fractionus does respond to recognized opt-out preference signals, such as Global Privacy Control, to the extent required by applicable law and to the extent such signals relate to targeted advertising, sale, or sharing activity that Fractionus engages in.

13. California Privacy Rights and Other U.S. State Privacy Rights

13.1. California Privacy Rights and Disclosures.

This Section applies to individuals who are California residents to the extent the California Consumer Privacy Act, as amended, including by the California Privacy Rights Act (collectively, the “CCPA”), applies to Fractionus’s processing of Personal Information. This Section supplements the other disclosures in this Privacy Policy.

13.2. California Residents.

Subject to applicable exceptions and verification requirements, eligible California residents may have the following rights:

(a) Right to Know and Access. You may have the right to request access to the specific pieces of Personal Information Fractionus has collected about you and information about Fractionus’s collection, use, and disclosure practices.

(b) Right to Delete. You may have the right to request deletion of Personal Information, subject to applicable exceptions.

(c) Right to Correct. You may have the right to request correction of inaccurate Personal Information.

(d) Right to Portability. You may have the right to request a portable copy of certain Personal Information in a usable format.

(e) Right to Opt Out of Sale or Sharing. You may have the right to opt out of the sale or sharing of Personal Information, including sharing for cross-context behavioral advertising, to the extent applicable.

(f) Right to Limit Use and Disclosure of Sensitive Personal Information. Where applicable, you may have the right to request that Fractionus limit the use and disclosure of Sensitive Personal Information to uses authorized by California law.

(g) Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising your privacy rights.

13.3. California Privacy Disclosures.

Fractionus collects, uses, and discloses the categories of Personal Information described in Section 1 for the purposes described in Section 2 and may disclose such information to the categories of recipients described in Sections 4, 5, and 6. Where required by applicable law, these disclosures describe Fractionus’s practices during the preceding twelve (12) months.

13.4. Sensitive Personal Information.

Fractionus does not seek to use Sensitive Personal Information to infer characteristics about California residents. If Fractionus processes Sensitive Personal Information, it will do so only as permitted by applicable law and as disclosed at collection.

13.5. Sale, Sharing, and Opt-Out Preference Signals.

Fractionus does not sell Personal Information for money. Fractionus may, however, use third-party advertising cookies, pixels, and similar technologies in ways that may constitute “sharing” of Personal Information or use of Personal Information for cross-context behavioral advertising under the CCPA. Where required by applicable law, Fractionus will provide a clear method to exercise applicable opt-out rights and will honor user-enabled opt-out preference signals, such as Global Privacy Control, to the extent required by law.

13.6. Submitting Requests.

California privacy requests may be submitted by emailing privacy@Fractionus.com and stating the nature of the request. Fractionus will take reasonable steps to verify the requester’s identity before processing certain requests, which may include confirming information associated with the requester’s account or requesting additional information where permitted by law. Fractionus will respond to verifiable consumer requests within the timeframes required by applicable law, which is generally forty-five (45) days from receipt of the request. Fractionus may extend that period by an additional forty-five (45) days where reasonably necessary, in which case Fractionus will notify you of the extension and the reason for it.

13.7. Authorized Agents.

California residents may designate an authorized agent to submit certain requests on their behalf, subject to applicable verification and authorization requirements.

13.8. California Shine the Light.

California residents may also request information regarding any disclosure of Personal Information to third parties for those third parties’ direct marketing purposes, if applicable, during the preceding calendar year, by contacting Fractionus as described below.

13.9. Other U.S. State Privacy Rights.

Depending on your state of residence and subject to applicable law, you may have privacy rights in addition to those described above. Subject to applicable exceptions, residents of certain states may have the following rights:

(a) Right to Confirm Processing. You may have the right to confirm whether Fractionus processes your Personal Information.

(b) Right to Access. You may have the right to access or obtain a copy of certain Personal Information.

(c) Right to Correct. You may have the right to correct inaccuracies in your Personal Information.

(d) Right to Delete. You may have the right to request deletion of Personal Information.

(e) Right to Portability. You may have the right to obtain a portable copy of certain Personal Information.

(f) Right to Opt Out. You may have the right to opt out of targeted advertising, sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects.

(g) Right to Revoke Consent. Where processing is based on consent, you may have the right to revoke that consent.

(h) Right to Obtain List of Third Parties. Where required by applicable state law, you may have the right to obtain a list of specific third parties to whom Fractionus has disclosed your Personal Information.

(i) (h) Non-Discrimination. You will not receive discriminatory treatment from Fractionus for exercising any of your privacy rights under applicable law.

13.10. Appeals.

Where required by applicable state law, if Fractionus declines to take action on a privacy request, Fractionus will provide instructions for appealing that decision. Where required by applicable state law, if Fractionus declines to take action on a privacy request, Fractionus will inform you of the reason and provide instructions for appealing the decision. You may appeal by emailing privacy@fractionus.com with the subject line “Privacy Appeal” and a description of your request and Fractionus’s response. Fractionus will respond to appeals within the timeframe required by applicable law, generally within sixty (60) days. If your appeal is denied, you may contact your state attorney general or applicable regulatory authority to file a complaint.

13.11. Opt-Out Preference Signals.

To the extent required by applicable law, including the Delaware Personal Data Privacy Act where applicable, Fractionus will recognize and process opt-out preference signals relating to targeted advertising or sale of Personal Information if Fractionus engages in the underlying processing activity and the signal is sent through a mechanism recognized by applicable law.

13.12. Data Protection Assessments.

Where required by applicable law, Fractionus conducts data protection assessments before engaging in processing activities that present a heightened risk to consumers, such as targeted advertising, the sale or sharing of Personal Information, profiling, and certain processing of Sensitive Personal Information. Fractionus documents these assessments and makes them available to applicable regulators upon request as required by law.

14. International Data Transfers

Fractionus is based in the United States and may use service providers in the United States and other countries. If you access the Services from outside the United States, your Personal Information may be transferred to, stored in, and processed in the United States and other countries that may not provide the same level of protection as your home jurisdiction. Where required by applicable law, Fractionus will implement appropriate safeguards for cross-border transfers of Personal Information.

15. Changes to This Privacy Policy

Fractionus may update this Privacy Policy from time to time. If we make material changes, Fractionus will post the updated version on the Services, update the “Last Updated” date, and provide any additional notice required by law. Your continued use of the Services after the effective date of an updated Privacy Policy means the updated Privacy Policy will apply to your use of the Services to the extent permitted by law.

16. Contacting Fractionus

If you have questions, concerns, or requests regarding this Privacy Policy or Fractionus’s privacy practices, you may contact Fractionus at privacy@Fractionus.com.

17. Complaints and Disputes.

If you have a complaint about Fractionus’s handling of your Personal Information, please contact Fractionus in writing at privacy@fractionus.com. Fractionus will acknowledge receipt of your complaint and will endeavor to resolve it directly with you. If you are not satisfied with Fractionus’s response, you may have the right to file a complaint with your state attorney general or applicable regulatory authority.