Dispute Resolution

Dispute Resolution Policy- Version 3.1 (as at January 2026)

1.       Introduction

1.1 Terms and Definitions

“we”, "us" and “our” refer to Data Zoo; “staff” and “users” means all of those who work under our control, including employees, contractors, interns etc. “IDR” refers to the internal dispute resolution. “EDR” refers to the external dispute resolution. “AFCA” refers to the Australian Financial Complaints Authority. “Complaint” refers “an expression of dissatisfaction made to or about an organisation related to its products, services, staff or the handling of a complaint where a response or resolution is explicitly or implicitly expected or legally required”. (This is the definition given in AS/NZS 10002:2014).

1.2 Scope

This document outlines Data Zoo’s arrangements for dealing with client complaints or disputes in a genuine, prompt, fair and consistent manner. IDR will offer -

• The opportunity to resolve complaints or disputes quickly and directly.

• The ability to identify and address recurring or systemic problems (which can then lead to product or service improvements).

• The capacity to provide solutions to problems rather than have remedies imposed by an external body.

• The chance to improve levels of customer and investor confidence and satisfaction.

• The ability to solve complaints or disputes directly with clients, so that a complaint or dispute is dealt with at the earliest possible stage following dispute resolution procedures.

• Informing complainants about the availability and accessibility of the relevant external dispute resolution scheme.

1.3 Responsibilities

Managers and supervisors are responsible for the implementation of these arrangements within the scope of their responsibilities and must ensure that all staff under their control understand and undertake their responsibilities accordingly.

2.  Dispute Resolution Principles

2.1 Visibility

We will take necessary steps to ensure our Clients/ Customers know about the existence of our dispute resolution procedure and how to make a complaint. This visibility can be demonstrated by:

• Ensuring this dispute resolution process is published on our websites (www.datazoo.com)

• What a customer needs to do to lodge a complaint.

• What process we follow to deal with the complaint.

• Our EDR scheme.

2.2 Commitment

Data Zoo is actively committed to effective and efficient complaint and dispute handling. This commitment can be demonstrated by:

• Ensuring all relevant staff are aware of and educated about Dispute Resolution procedures.

• Ensuring that adequate resources are allocated to Dispute Resolution.

• Implementing management systems and reporting procedures to ensure timely and effective complaint or dispute handling and monitoring.

2.3 Resources

The adequacy of resources relates to documentation, specialist support, materials and equipment, computer hardware and software, and finances. When implementing Dispute Resolution procedures, Data Zoo makes sure to:

• Establish a contact point for complainants or disputants.

• Nominate staff to handle complaints or disputes who have sufficient training and competence to deal with those complaints or disputes, including the authority to settle complaints or disputes or ready access to someone who has the necessary authority.

• Ensure adequate systems are in place to handle complaints or disputes promptly, fairly, and consistently.

2.4 Accessibility

Data Zoo ensures the arrangements for making complaints or disputes are simple and accessible. Information about making and resolving complaints or disputes is easy to understand and is in plain English. Data Zoo provides the following medium to submit complaints or disputes.

Email: info@datazoo.com

Postal address: Suite 1803, 99 Mount St, North Sydney, NSW, 2060

Website: www.datazoo.com

2.5 Responsiveness

Data Zoo ensures to respond to complaints or disputes promptly in accordance with the urgency of the complaint or dispute. Where immediate acknowledgement of a complaint or dispute is not possible, the acknowledgement will be made as soon as practicable.[1]

[1] RG271.51 (RG165 pg. 41 Guiding Principle 4.4)

2.6 Objectivity

Data Zoo addresses complaints and disputes in an equitable, objective, and unbiased manner. The complaint/dispute handling process ensures:

• Adequate opportunity for each party to make their case (and where a credit dispute involves a credit representative, for the credit representative to provide relevant information to its credit licensee).

• Allow other persons who may request an information return (e.g. beneficiaries), and who may reasonably have an interest in the outcome of a traditional services complaint, to be identified, notified and their views considered, where relevant to the efficient and fair handling of the complaint

• Investigate a complaint/dispute by staff not involved in the subject matter of the complaint or dispute.

• Provide reasons for reaching a decision on the complaint or dispute and adequately address the issues that were raised in the initial complaint or dispute. Where practicable, reasons for a decision should be in writing and should refer to applicable provisions in legislation, codes, standards, or procedures.

2.7 Collection of Information

Data Zoo has established a recording system for managing complaints/disputes while protecting personal information and ensuring complainant or disputant confidentiality. The system specifies the steps for identifying, gathering, maintaining, storing, and disposing of records. It records information on complaints or disputes handling and takes the utmost care in maintaining and preserving such items as electronic files and magnetic recording media.

2.8 Analysis and Evaluation of Complaints

All complaints/disputes are classified and then analysed to identify systematic, recurring, and single incident problems and trends. This helps in eliminating the underlying causes of complaints/disputes. To do this, it will be important to be able to analyse complaints or disputes according to categories, such as type of complainant, subject of the complaint, outcome of a complaint, and timeliness of response. Data Zoo handled complaints by following below categories:

2.9 Timeframes

The responsible manager will:

record details of all complaints and responses in the Complaints Register (Appendix 2) including the date they are received and the date of the response.

provide a final written response to standard complaints within 30 days[2] (21 days for disputes involving default notices[3]) after receiving the complaint.

In our pursuit of best practice, we will always endeavour to outperform the established timeframes whenever possible. Where we conclude complaints within five business days,[4] no IDR response will be provided unless requested by the complainant (or where other exceptions[5] apply). Despite our best endeavours, there are many variables that can affect complaint response times, which include the complexity [6] of the issues raised, the availability of information (including from third parties) and other circumstances beyond our control.[7]

Where such circumstances give rise to complaint management delays, we will provide the complainant with a ‘delay notification’[8] prior to the expiration of the relevant dispute resolution timeframe. This will inform the complainant about the reasons for the delay; their right to complain to the regulator if they are dissatisfied; and the contact details for AFCA as outlined below (under External Dispute Resolution).[9]

[2] RG 271.56

[3] RG271.86 and RG 271.91

[4] RG 271.71

[5] See RG 271.75 for exceptions including those related to hardship, declined insurance claim or value of an insurance claim

[6] RG 271.67

[7] RG 271.63-68

[8] Previously referred to as RG 165.92 ‘delay letters’

[9] RG271.66

2.10 Documenting

We maintain proper documentation to:

Enable the relevant staff to understand and follow the procedures.

Promote accountability and transparency of the procedures.

Facilitate the ease of understanding and accessibility of the procedures for consumers (i.e. via the production of user-friendly guides).

2.11 Charges

We ensure:

• Material explaining dispute resolution procedures is provided free of charge to complainants or disputants.

• Complainants or disputants should not have to pay to access the complaints or disputes handling process.

2.12 Confidentiality

We ensure the confidentiality of the information. The data handling policy of Data Zoo is transparent with minimal Personal Identifiable Information (PII) stored in the system.

2.13 Continual Improvement

The continual improvement of the complaints or disputes handling process and the quality of products and services is an ongoing objective of Data Zoo. This involves conducting regular reviews of dispute resolution procedures to identify areas for improvement. We consider that reviews should be conducted at least every two years to ensure that the complaints or disputes system is operating effectively.

2.14 Customer-focused approach

Data Zoo adopted a customer-focused approach which involves being open to customer feedback, offering customer helpful and user-friendly response in plain English. Data Zoo will show commitment to resolve complaints or disputes by its actions.

3.   External Dispute Resolution

A.      The Office of the Australian Information Commissioner (OAIC)

Complaints involving your Privacy/ Consumer Data Right (CDR), and how we have handled your personal information, are handled by the OAIC. Privacy complaints can be lodged online or by contacting the OAIC using the details below:

Website: www.oaic.gov.au

Phone: 1300 363 992

Postal Address: GPO Box, 5218, Sydney NSW 2001

Where the complaint or dispute involves a foreign jurisdiction, please contact us or the relevant privacy regulator/ commissioner directly.

B. Australian Court of International Commercial Arbitration (ACICA)

Where IDR has been exhausted as per this policy and/or the relevant contract procedures, disputes may be referred to arbitration for resolution. Our contracting arrangements include recourse to ACICA for Arbitration or other suitably agreed centre for Arbitration. Arbitration will be conducted in accordance with the specific agreement, which will always be consulted and confirmed before commencing any arbitration action.

4. Breach of Policy

Data Zoo will take all necessary measures to remedy any breach of this policy including the use of our disciplinary or contractual processes where appropriate.

Appendix 1

Data Zoo/IDU-X Complaint Handling and Dispute Resolution Steps

We handle complaints or disputes following nine steps:

Figure 1: Complaint handling and Dispute Resolution steps

1. Receiving Complaints: The initial record of the complaint identifies:

• The contact details of the complainant,

• The issues raised,

• Any other information required to appropriately respond to the matter.

2. Acknowledging Complaints: The receipt of each complaint is acknowledged promptly. Copies of any correspondence acknowledging a complaint are kept on file.

3. Assessing Complaints: After acknowledging a complaint, each issue is addressed separately by their priority. Evaluating a complaint involves determining what action is required based on importance.

4. Planning and Investigating: When conducting a formal investigation, we prepare a written investigation plan. This outlines the scope and sequence of investigative activities and highlights any risks that may need to be managed. The length and complexity of the plan will depend on the nature and seriousness of the complaint being investigated. However, it is not too rigid or detailed. It is flexible and able to be revised or entirely replaced if new evidence or inquiry lines emerge. Evidence and documentation provided by the customer is analysed and assessed by the relevant department and the outcomes are communicated to company management to decide action.

5. Obtaining, Storing & Reviewing Evidence: During the investigation, sufficient important reliable information is gathered, so that findings and recommendations can be made.

6. Making Findings: Once all the relevant evidence has been gathered and reviewed, an investigation report is prepared. This is an official record and will be used to help decide what action will be taken in response to the complaint.

7. Resolving Complaints: Based on the finding’s, resolution of complaints or disputes are determined, including details of any appropriate remedies.

8. Informing the Complainant about the Decision: The final written response to the complainant provided by the responsible officer will be made subject to and within the timeframes established. The decision will address all issues, provide reasons for the decisions and findings, outline details of the remedies available, and options for further review/ appeal including the consumers right to take the complaint to EDR through AFCA.[10]

9. Keep document for future use:

After a complaint has been closed, a comprehensive record is kept about:

• How the complaint was managed.

• The outcome of the complaint – including any aspects that were substantiated, adequacy of remedies available, any recommendations provided to address problems identified, and any decisions made on those recommendations.

• Any outstanding issues that need to be followed up.

[10] RG 165.87

Appendix 2: Form of Complaints Register

[11] See Appendix 3: Complaint Outcome Table

Appendix 3: Complaint Outcome Table

Adapted from thethe ASIC Internal Dispute resolution: Data dictionary and glossary published 1 December 2025; RG 271.161

REFERENCES