Effective Date: May 25, 2025
Governing Entity: Wimbo Au Pty Ltd (ACN: 687 084 984), trading as Wimbo™
Contact: legal@wimbo.au | help@wimbo.au
Registered Address: 470 St Kilda Road, Melbourne, Victoria 3004, Australia

ARTICLE I — PURPOSE AND STATEMENT OF INTENT

Wimbo Au Pty Ltd (ACN: 687 084 984), a private company duly incorporated under the Corporations Act 2001 (Cth) and trading as Wimbo™ (hereinafter, “Wimbo”, “we”, “us”, or “our”), acknowledges and affirms that digital accessibility is not merely a matter of best practice, but a legally enforceable obligation and a fundamental human right, enshrined in both domestic statutes and international legal instruments.

This Accessibility Statement is promulgated in accordance with applicable anti-discrimination, disability rights, and electronic communications laws, including but not limited to:

• Disability Discrimination Act 1992 (Cth) (Australia), §§ 5–24, read in conjunction with the Disability Standards for Accessible Public Transport 2002 and relevant Human Rights Commission Guidelines;

• United Nations Convention on the Rights of Persons with Disabilities, Article 9 (Accessibility), ratified by Australia and binding under international law;

• Equality Act 2010 (UK), Chapter 2, Part 2, and associated Codes of Practice issued by the UK Equality and Human Rights Commission;

• Americans with Disabilities Act of 1990, Title III, 42 U.S.C. § 12182, and implementing regulations at 28 C.F.R. Part 36;

• Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d), requiring federal-level digital accessibility in the United States;

• Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the Integrated Accessibility Standards Regulation (O. Reg. 191/11);

• General Data Protection Regulation (EU) 2016/679, specifically Recitals 39, 42, and Article 12(1), which emphasize transparency, intelligibility, and equal access in data-related communications.

Wimbo further embraces the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA, as the technical benchmark for accessibility compliance. These guidelines serve as a harmonized framework for digital design that is perceivable, operable, understandable, and robust (POUR), as recognized by the W3C (World Wide Web Consortium).

The purpose of this Statement is to codify Wimbo’s corporate intent to:

1. Ensure all digital content, features, tools, and services on the Platform are equally accessible to users with disabilities;

2. Prevent discriminatory barriers to participation on the basis of disability in accordance with public policy doctrines under equality law;

3. Facilitate the implementation of reasonable adjustments and auxiliary aids as required under law;

4. Establish institutional accountability for accessibility compliance through internal monitoring, legal review, and third-party testing.

This Statement shall be interpreted in harmony with applicable statutory duties, case law, and the principle of substantive equality in access to digital goods and services. It shall form an integral component of Wimbo’s broader governance and legal risk management framework, and is binding upon all departments, subcontractors, and third-party service providers engaged in Platform development or delivery.

ARTICLE II — GOVERNING LEGAL FRAMEWORKS

Wimbo Au Pty Ltd (ACN: 687 084 984), trading as Wimbo™ (“Wimbo”, “we”, “us”, or “our”), affirms its binding legal obligations to implement and maintain digital accessibility standards in accordance with a multilayered framework of statutory instruments, regulatory mandates, constitutional principles, and public international law. These instruments impose affirmative duties to ensure that digital services, interfaces, and content are made accessible to persons with disabilities on an equal basis with others, and include, inter alia:

(a) Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, developed by the World Wide Web Consortium (W3C), which constitute the globally recognized benchmark for technical and functional digital accessibility, and are incorporated by reference into numerous national legal frameworks.

(b) Americans with Disabilities Act of 1990 (ADA), Title III, codified at 42 U.S.C. § 12182 and implemented under 28 C.F.R. § 36.303, which obligates private entities that own, lease, or operate places of public accommodation—including digital platforms—to provide full and equal access to individuals with disabilities, and to furnish auxiliary aids and services as necessary to ensure effective communication.

(c) Section 508 of the Rehabilitation Act of 1973, 29 U.S.C. § 794d, which requires that federal agencies and their contractors ensure that all electronic and information technologies (EIT), including websites and mobile applications, are accessible to persons with disabilities in compliance with federal procurement standards.

(d) Equality Act 2010 (United Kingdom), particularly Sections 20–22 and Schedule 2, which impose a continuing duty on service providers to anticipate and implement reasonable adjustments for disabled individuals, including through the design and operation of websites and mobile applications, under the oversight of the Equality and Human Rights Commission.

(e) Disability Discrimination Act 1992 (Cth) (Australia), specifically Sections 5, 6, 24, and 29, interpreted in light of the Australian Human Rights Commission’s Advisory Notes, which prohibit the refusal or failure to provide goods or services in an accessible format, including those offered through digital means, unless such adjustment would impose unjustifiable hardship.

(f) Accessibility for Ontarians with Disabilities Act (AODA), S.O. 2005, c. 11, and the Integrated Accessibility Standards Regulation (O. Reg. 191/11), which require that private-sector digital content conform to WCAG 2.0/2.1 AA and be updated continuously to remain accessible to individuals with disabilities in Ontario and other applicable Canadian jurisdictions.

(g) Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR), specifically Article 12(1) and Recitals 39, 58, and 60, which mandate that information provided to data subjects, including privacy notices and rights-related communications, must be intelligible, accessible, and presented in a clear and plain format to ensure data transparency and equity in digital interaction.

(h) United Nations Convention on the Rights of Persons with Disabilities (CRPD), ratified by Australia and many other nations, particularly Article 9, which imposes obligations on State Parties and private entities acting under State authority to promote access to ICT, digital content, and services for all persons with disabilities without discrimination and on an equal basis.

These instruments, taken together, impose both substantive obligations (i.e., to make services accessible) and procedural guarantees (i.e., to provide notice, remedies, and opportunities for redress), and must be interpreted purposively in light of prevailing jurisprudence, including but not limited to:

• Robles v. Domino’s Pizza LLC, 913 F.3d 898 (9th Cir. 2019);

• Maguire v. SOCOG (1999) HREOC 21 (Australia);

• National Federation of the Blind v. Scribd Inc., 97 F. Supp. 3d 565 (D. Vt. 2015);

• R (on the application of B) v. The Secretary of State for Work and Pensions [2005] EWCA Civ 929.

Failure to comply with the above legal mandates may result in civil liability, regulatory enforcement, reputational harm, and other sanctions. Wimbo therefore affirms its continuing legal duty to align all aspects of its Platform with such frameworks, and to adopt an internal compliance model that reflects both proactive design and responsive remediation.

ARTICLE III — SCOPE OF APPLICATION

This Accessibility Statement applies in its entirety to all digital properties, services, and technical interfaces created, managed, or made available by Wimbo or its authorized affiliates, including without limitation:

(a) The WimboTM mobile application, available through Apple App Store (iOS) and Google Play Store (Android), including its embedded features, push notifications, location services, and interactive menus;

(b) The web-based Platform, including user dashboards, registration and onboarding flows, content management systems (CMS), and public or private event-hosting portals;

(c) All digital communication tools, including direct messaging systems, marketing emails, transactional notices, privacy notices, pop-up modals, and cookie banners;

(d) All interactive user-facing functionality, including search and filtering tools, RSVP processes, AI-generated content features (e.g., Wimbot), and consent management panels;

(e) Any and all application programming interfaces (APIs), software development kits (SDKs), embedded widgets, or third-party tools integrated into the Platform under contract or license;

(f) Any white-labeled, franchised, or rebranded Platform variants, whether operated directly or via local partners, resellers, or subsidiaries under Wimbo’s intellectual property.

This Statement binds Wimbo, its officers, employees, agents, subcontractors, and any third parties who participate in the development, deployment, maintenance, or content provision of the Platform. It shall be interpreted as having extraterritorial effect to the fullest extent permissible by law, and shall supplement but not supersede any statutory duty under applicable accessibility legislation in the user’s jurisdiction of residence.

ARTICLE IV — DIGITAL ACCESSIBILITY FEATURES

Wimbo affirms that all core functionalities of its digital Platform shall be designed and implemented in accordance with the WCAG 2.1 Level AA criteria, the principles of universal design, and the technical requirements imposed by applicable laws and regulatory guidelines. The following accessibility-enhancing features are incorporated by design and form part of Wimbo’s standard development protocol:

(a) Screen-reader compatibility with semantic HTML, ARIA landmarks, roles, and labels to support assistive technologies such as JAWS, NVDA, and VoiceOver;

(b) Alternative text (alt-text) and descriptive captions for all images, icons, and non-text content, ensuring compliance with WCAG Success Criterion 1.1.1;

(c) Logical tab sequencing, focus indicators, and full keyboard operability to ensure non-reliance on pointer devices, as required under 28 C.F.R. § 35.160 and comparable frameworks;

(d) Adjustable typography and high-contrast modes, allowing users to scale fonts and select interface color schemes to accommodate visual impairments and low vision conditions;

(e) Captioning and/or synchronized transcripts for all pre-recorded multimedia, consistent with WCAG 2.1 Success Criteria 1.2.2 and 1.2.3, and as required under Section 508 and ADA Title III;

(f) Minimization of time-limited content, with adjustable or extended timeouts, pause/resume features, and clear error recovery options to comply with cognitive accessibility mandates;

(g) Consistent page hierarchy, language tags, skip-navigation functionality, and meaningful link text to facilitate orientation and reduce cognitive load.

ARTICLE V — ACCESSIBILITY DESIGN PRINCIPLES

Wimbo’s inclusive development approach is guided by the internationally recognized POUR Framework, as established under WCAG, and integrated into every phase of the product lifecycle:

• Perceivable: Information and interface components must be presented in ways that users can perceive through at least one sense (e.g., sight, sound, touch);

• Operable: User interface components and navigation must be fully operable via keyboard, speech, or alternative devices;

• Understandable: Content and operation of the Platform must be predictable, consistent, and linguistically clear, allowing for simplified reading levels and multilingual support;

• Robust: Content must be interpretable by a wide range of user agents, including assistive technologies and emerging tools.

Each Platform update or new feature shall undergo an Accessibility Impact Assessment (AIA) and Design Review Memorandum, consistent with Wimbo’s internal Accessibility Compliance Protocol and in light of Section 5 of the Australian Human Rights Commission's Disability Discrimination Guidelines.

ARTICLE VI — TRAINING AND AWARENESS

Wimbo mandates periodic and role-specific training for all personnel engaged in the design, development, content curation, legal review, and customer support functions of the Platform. This includes:

(a) Mandatory onboarding training on WCAG guidelines, platform obligations under applicable laws (e.g., ADA, DDA, AODA), and ethical accessibility;

(b) Ongoing workshops, compliance refreshers, and access to a digital Accessibility Compliance Manual curated by legal and technical advisors;

(c) Inclusion of accessibility awareness modules in contractor agreements and statements of work (SOWs) with design and engineering vendors.

Training records shall be maintained by the Human Resources and Compliance Departments and reviewed biannually to ensure knowledge retention and procedural conformance.

ARTICLE VII — THIRD-PARTY CONTENT AND EMBEDDED SERVICES

Where the Wimbo Platform integrates third-party content or relies upon embedded services—including but not limited to payment processors (e.g., Stripe), location services (e.g., Google Maps), social media APIs (e.g., Meta/Facebook), or advertising SDKs—Wimbo shall:

(a) Exercise due diligence in selecting vendors with demonstrable adherence to accessibility standards and inclusive design principles;

(b) Provide contextual warnings or disclaimers where Wimbo lacks technical or legal control over the accessibility of third-party content;

(c) Contractually require third-party service providers to meet accessibility performance benchmarks where feasible, consistent with procurement best practices under Section 508 and equivalent laws.

Wimbo expressly disclaims liability for third-party accessibility failures beyond its operational control but commits to providing meaningful alternatives or remedial options upon user request.

ARTICLE VIII — ACCESSIBILITY TESTING AND AUDITS

Wimbo implements a robust compliance verification protocol to ensure that all accessibility measures are both effective and legally defensible. Testing and auditing procedures include:

(a) Automated testing using reputable tools such as Axe, WAVE, and Lighthouse to detect code-level nonconformities against WCAG standards;

(b) Manual usability testing with assistive technology users, including blind, low vision, and mobility-impaired individuals, to verify real-world operability;

(c) User-submitted feedback evaluations, captured through designated accessibility reporting channels, and logged in the internal Accessibility Issue Tracker;

(d) Scheduled audits, performed:

• Upon substantial codebase changes or feature rollouts;

• Following verified user complaints;

• At least once annually, as part of Wimbo’s formal Accessibility Compliance Audit under the direction of its Data Protection Officer and General Counsel.

Each audit shall result in a Compliance Report, detailing conformance levels, deviations, remediation timelines, and risk mitigation strategies.

ARTICLE IX — REPORTING ACCESSIBILITY BARRIERS AND REQUESTING REASONABLE ACCOMMODATIONS

Any individual who encounters a digital accessibility barrier while interacting with the WimboTM Platform, or who seeks a reasonable accommodation consistent with applicable anti-discrimination laws, shall be entitled to submit a formal request or complaint via one of the following channels:

• Email: help@wimbo.au or legal@wimbo.au

• Subject Line: “Accessibility Assistance Request”

• Postal Mail:
  Accessibility Compliance Office
  Wimbo Au Pty Ltd
  470 St Kilda Road, Melbourne VIC 3004, Australia

All such inquiries will be acknowledged within five (5) business days of receipt. Wimbo commits to investigating the reported barrier or requested adjustment in a prompt, confidential, and non-retaliatory manner and, where feasible, shall provide a reasonable accommodation or alternative access mechanism within a commercially reasonable time frame, consistent with:

• Section 20 of the Equality Act 2010 (UK);

• Sections 5, 6, and 24 of the Disability Discrimination Act 1992 (Cth) (Australia);

• Title III of the ADA (42 U.S.C. § 12182) and its effective communication obligations under 28 C.F.R. § 36.303;

• CRPD, Article 9(2)(d), concerning the elimination of access obstacles and barriers.

ARTICLE X — INTERPRETATION AND LIMITATION OF LIABILITY

This Accessibility Statement is issued for the purpose of transparency, legal alignment, and policy articulation, and shall not be construed as creating or conferring any legally enforceable contractual rights, causes of action, or private remedies beyond those mandated under applicable law.
Nothing in this Statement shall be interpreted to derogate from, enlarge, or otherwise modify any limitation of liability, warranty disclaimer, or force majeure clause contained within Wimbo’s general Terms of Use, Privacy Policy, or any other legally binding platform documentation.
This Statement is intended to be declaratory in nature, reflecting Wimbo’s good-faith efforts to voluntarily comply with prevailing digital accessibility obligations under domestic and international law.

ARTICLE XI — USER RIGHTS UNDER APPLICABLE LAW

Notwithstanding the foregoing, users of the Wimbo Platform retain all rights and remedies provided under relevant accessibility and anti-discrimination legislation, including but not limited to the right to:

• Lodge a formal complaint with the Australian Human Rights Commission, the UK Equality and Human Rights Commission, the U.S. Department of Justice, or other competent supervisory or enforcement authority;

• Request information in accessible alternative formats, including but not limited to screen-reader-compatible text, audio transcriptions, or large-print communications;

• Seek equitable or injunctive relief, or initiate administrative or judicial proceedings, where digital accessibility barriers result in unlawful exclusion or discrimination.

These rights shall be construed in accordance with applicable legal doctrines, including substantive equality, reasonable adjustment/accommodation, and effective communication as recognized under international human rights law and local implementation statutes.

ARTICLE XII — ENFORCEMENT, MONITORING, AND INTERNAL REVIEW

The Wimbo Accessibility Statement shall be administered and enforced under the supervision of the designated Accessibility Compliance Officer, who shall report directly to Wimbo’s General Counsel and Chief Compliance Officer.

Responsibilities of the Accessibility Compliance Officer shall include:

• Oversight of ongoing compliance monitoring activities;

• Maintenance of a centralized Accessibility Incident Log, recording all reported accessibility issues, accommodation requests, corrective actions taken, and timelines of resolution;

• Coordination of annual accessibility audits in accordance with Article VIII;

• Preparation of an annual Accessibility Compliance Report, to be retained for a minimum of five (5) years in compliance with legal recordkeeping obligations.

ARTICLE XIII — VERSION CONTROL, AMENDMENT, AND PUBLICATION

This Accessibility Statement may be amended, revised, or supplemented by Wimbo at any time to reflect:

• Legislative or regulatory changes impacting accessibility standards;

• Technological developments that affect the operability or usability of the Platform;

• Internal compliance reviews or audit findings; or

• Judicial or administrative rulings with applicability to Wimbo’s services or jurisdictions of operation.

All material amendments shall be published with a revised “Effective Date” and will be made available to users via the Platform’s designated policy repository. Continued use of the Platform following publication of such revisions shall constitute conclusive acceptance of the amended Statement, unless otherwise required by law.