Privacy Policy

1. What is personal information?

1.1 Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Sensitive information is a category of personal information that includes information such as health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record and some biometric information.

2. The kinds of personal information we collect and hold

2.1 Depending on how you interact with us, we may collect and hold:

• identity and contact information, such as name, business name, job title, email address, telephone number and business address;
• business relationship information, including enquiries, proposals, contracts, meeting notes, correspondence, preferences and service history;
• billing and transaction information, excluding full payment-card details where those are handled directly by a payment provider;
• website and technical information, such as IP address, device/browser information, referral source, pages viewed, cookies and analytics data;
• marketing and campaign information, including advertising account information, audience information, analytics, CRM or lead information and reporting data where that information can identify an individual;
• supplier, contractor, job applicant and team information relevant to engaging or working with us; and
• other information you choose to provide to us or that is reasonably necessary for our services.

2.2 We do not generally seek sensitive information. We may encounter sensitive information where a client provides it or gives us access to systems containing it. We will only handle sensitive information where it is reasonably necessary, lawful and subject to appropriate authority, consent or another applicable legal basis.

3. How we collect personal information

3.1 We may collect personal information:

• directly from you, including through our website, email, telephone, meetings, forms, proposals, contracts and service delivery;
• from our clients, agency partners and other organisations where they engage us to perform marketing, reporting, analytics, data or related services;
• from advertising, analytics, CRM, website, ecommerce, reporting and other platforms that we are authorised to access;
• from contractors, suppliers, business partners, referrals and professional advisers;
• from public sources, business websites and professional networking platforms where collection is lawful and reasonably necessary; and
• automatically through website hosting, security, cookies and analytics technologies.

4. Why we collect, hold, use and disclose personal information

4.1 We may collect, hold, use and disclose personal information to:

• respond to enquiries and communicate with clients, prospective clients, suppliers and business contacts;
• prepare proposals, contracts, media plans, reports and other business documents;
• provide and administer marketing, media, analytics, data, SEO, AI visibility, reporting, consulting and related services;
• set up, access, manage, troubleshoot and report on authorised advertising, analytics, website, CRM and technology accounts;
• manage billing, accounts, insurance, records, suppliers, contractors and internal administration;
• protect our systems, investigate incidents, prevent fraud and maintain security;
• send business updates or marketing communications where permitted by law, and manage opt-out requests;
• comply with legal and regulatory obligations and establish, exercise or defend legal rights; and
• improve our processes, templates, services and operations, including through de-identified or aggregated information where appropriate.

5. Client data and information we process for clients

5.1 In some engagements, we access or process personal information on behalf of a client or agency partner. In those circumstances, the client may remain primarily responsible for the collection and lawful use of that information, and we will generally handle it for the purpose of delivering the agreed services and in accordance with the client's lawful instructions.

5.2 If your personal information is held by us solely on behalf of one of our clients, we may refer an access, correction or privacy request to that client and assist them as appropriate.

6. Artificial intelligence and automated tools

6.1 We may use commercial artificial intelligence, machine-learning and automation tools to assist with tasks such as research, drafting, summarisation, analysis, reporting, quality assurance, ideation and operational work.

6.2 Where personal information is involved, we aim to minimise the information used, consider whether the use is reasonably necessary, use approved business-grade tools and settings where appropriate, restrict access and apply human review to material outputs.

6.3 As a standard practice, we do not enter passwords, authentication credentials, payment card data, government identifiers or sensitive personal information into publicly available consumer generative AI tools. Any exceptional use involving high-risk or sensitive information must be specifically assessed and authorised before use.

6.4 AI systems can generate inaccurate, incomplete or inferred personal information. Where AI-assisted output contains personal information and is used for a business purpose, we take reasonable steps appropriate to the context to review its accuracy and relevance before relying on or disclosing it.

7. Cookies, analytics and website information

7.1 Our website and service providers may use cookies and similar technologies for essential site functions, security, analytics and performance measurement. These technologies may collect technical information such as IP address, browser, device, referral source and pages viewed.

7.2 You can usually control cookies through your browser settings. Disabling cookies may affect some website functions. Where a third-party analytics or advertising technology applies its own privacy terms, you should review that provider's information as well.

8. Who we disclose personal information to

8.1 We may disclose personal information where reasonably necessary to:

• our employees, contractors, specialist partners and subcontractors;
• advertising platforms, publishers, analytics providers, CRM systems, reporting platforms and other technology providers used to deliver client services;
• cloud hosting, email, file storage, collaboration, security, support, accounting and business administration providers;
• approved AI and automation service providers;
• professional advisers, insurers, auditors, financiers and debt-recovery providers;
• a purchaser or adviser in connection with a genuine business sale, restructure or transaction, subject to appropriate confidentiality; and
• courts, regulators, law-enforcement bodies or other persons where disclosure is authorised or required by law.

8.2 We do not sell personal information.

9. Overseas processing and disclosure

9.1 Some service providers we use operate globally and may store or process personal information outside Australia. Depending on the provider, account configuration and service used, overseas recipients are likely to include recipients in the United States and may include other countries in which the relevant provider or its subprocessors operate.

9.2 Where practicable and required, we will take reasonable steps to assess overseas handling arrangements and to provide more specific information about likely countries. Because provider infrastructure and subprocessors can change, you may contact us for current information relevant to a particular service or engagement.

10. Direct marketing

10.1 We may use business contact information to send communications about our services where permitted by law. You can opt out of marketing emails at any time by using the unsubscribe function where available or contacting us. We may still send service, account, legal or administrative communications that are not marketing.

11. Security

11.1 We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include access controls, authentication, role-based permissions, device and account security, approved cloud providers, staff and contractor obligations, and procedures for handling security incidents.

11.2 No internet transmission or storage system can be guaranteed to be completely secure. If we become aware of an eligible data breach, we will assess and respond to it in accordance with applicable legal obligations, including the Notifiable Data Breaches scheme where it applies.

12. Retention and deletion

12.1 We retain personal information for as long as reasonably necessary for the purpose for which it was collected, to provide services, maintain appropriate business records, comply with law, resolve disputes and meet tax, accounting, insurance or contractual requirements.

12.2 When information is no longer required, we take reasonable steps to delete or de-identify it, subject to lawful backup and record-retention requirements.

13. Access and correction

13.1 You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details below. We may need to verify your identity before responding.

13.2 In some circumstances, the law permits or requires us to refuse access or correction. If that occurs, we will explain the reason where required and available to us.

14. Privacy complaints

14.1 If you have a privacy concern or complaint, please contact us at info@fractional-marketing.com.au and provide enough information for us to understand the issue. We will acknowledge and investigate the matter and aim to respond within a reasonable period.

14.2 If the Privacy Act applies and you are not satisfied with our response, you may be able to complain to the Office of the Australian Information Commissioner (OAIC). Information about privacy complaints is available at oaic.gov.au.

15. Automated decision-making

15.1 We do not currently arrange for a computer program to use personal information to make decisions that could reasonably be expected to significantly affect an individual's rights or interests as part of our ordinary business operations.

15.2 If our practices change, we will update this policy to describe relevant automated decision-making arrangements and the kinds of personal information and decisions involved, where required by law.

16. Changes to this policy

16.1 We may update this policy when our practices, service providers or legal obligations change. The current version will be published on our website with the date of the latest update.

17. Contact us

17.1 Fractional Marketing Australia Pty Limited, ACN 668 194 616

17.2 Website: https://fractional-marketing.com.au

17.3 Privacy enquiries and requests: info@fractional-marketing.com.au