Privacy Policy & Data Governance

Effective Date: July 26, 2026 | Version 2.4

This Privacy Policy outlines how Cumulo Group Pty Ltd (ABN 13 607 947 419) and Returnr Creative Pty Ltd (ABN 98 693 534 879), collectively operating as Returnr Enterprise ("Returnr", "we", "us", or "our"), collect, use, and govern data across our global B2B infrastructure, hardware deployments, and web platforms.

1. B2B Enterprise Data Collection

As a global provider of circular packaging infrastructure, our primary data collection is strictly limited to facilitating B2B commerce, OEM manufacturing contracts, and enterprise deployments. We may collect:

Corporate Identity: Company names, contact personnel, billing addresses, and facility locations for DDP logistics.
Technical Specifications: Uploaded CAD files, DFM blueprints, and proprietary tooling requirements submitted for custom quoting.
Financial Data: Corporate procurement details necessary for processing high-volume manufacturing orders.

2. Smart Return Stations & Hardware Tracking

Returnr provisions advanced Deposit Return Systems (DRS) utilizing smart optical intake kiosks and modular bins. It is critical to note our privacy-first engineering approach to hardware:

Asset Tracking, Not User Tracking: The Laser Etched Serialized QR codes and embedded NFC tags on our SUS304 and Tritan Renew™ vessels are designed exclusively to track the physical lifecycle and wash cycle counts (up to 1,000+ cycles) of the inventory, not the end-consumer.
API Anonymization: When our hardware syncs with enterprise Point of Sale (POS) systems, Returnr’s API strictly processes transactional and deposit reconciliation states. We do not ingest, store, or process Personally Identifiable Information (PII) of your retail customers.

3. Global Regulatory Compliance

We mandate strict adherence to international data privacy frameworks to support our multinational corporate clients:

Australia: Full compliance with the APP under the Privacy Act 1988 (Cth).
European Union: Alignment with the GDPR requirements for data minimization, consent, and the right to erasure regarding B2B contact records.
California, USA: Compliance with the CCPA as it applies to enterprise procurement communications.

4. Data Security & Storage

Returnr applies enterprise-grade security protocols to safeguard your commercial data and proprietary ODM designs. Our internal quality management systems and operational governance are informed by ISO 9001:2015 and amfori BSCI protocols. Digital assets, including design schematics and LCA (Life Cycle Assessment) models, are encrypted in transit and at rest using industry-standard AES-256 encryption.

5. Contact the Privacy Officer

If you require clarification on how our API handles deposit logic, or wish to request the deletion or modification of your B2B corporate data, please direct your inquiries to our Melbourne headquarters:

Email: hello@returnr.org
Address: 271/15 Cochranes Road, Moorabbin, VIC 3189, Melbourne, Australia