Privacy Policy

This Privacy Policy explains how Action Digital (a trading name of Justin Peter Bryce, ABN 19 329 127 766) ("we", "us" or "our") collects, holds, uses and discloses personal information.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This policy applies to personal information collected through our website, our booking calendar, our lead forms (including Meta lead forms), our SMS and email communications, and our client platform.

Action Digital is based in New South Wales, Australia.

For privacy requests, questions or complaints, contact us at [email protected].

We collect the following personal information:

• (a)your name, email address and phone number;
• (b)the details you give us when you make an enquiry or book a call, including anything you tell us about your business and your needs;
• (c)records of our communications with you, including SMS messages, emails, call bookings and notes;
• (d)if you become a client, your login account details and the information you and your team add to or generate through our client platform; and
• (e)technical and usage information collected through cookies and similar technologies, such as device type, browser type, IP address and how you use our website.

We do not collect payment card details on our website.

We do not ask you to provide sensitive information (such as health information) and ask that you do not include it in your enquiry or booking details.

We collect personal information:

• (a)directly from you when you complete a form on our website;
• (b)directly from you when you book a call through our booking calendar;
• (c)from you when you submit a Meta (Facebook or Instagram) lead form, with the information passed to us through Meta's lead advertising tools;
• (d)when you communicate with us by phone, SMS, email or video call; and
• (e)automatically through cookies, pixels and analytics tools when you visit our website.

If you provide us with personal information about another person, please make sure you are authorised to do so and have told them about this policy.

We collect, use and disclose personal information to:

• (a)respond to your enquiry and arrange, hold and run your booked call;
• (b)send you automated replies, reminders and follow-ups about your enquiry and booking;
• (c)provide our services to you and manage our relationship with you if you become a client;
• (d)set up and administer your login account on our client platform;
• (e)measure and improve our website, advertising and services;
• (f)show and measure our advertising on Meta and Google platforms;
• (g)comply with our legal obligations and resolve disputes; and
• (h)keep our systems secure and prevent misuse.

We will not use or disclose your personal information for a purpose unrelated to those above unless you consent, the use is related to those purposes and you would reasonably expect it, or the law permits or requires it.

We contact people by SMS and email about their enquiry and booking, including automated replies, reminders and follow-ups.

Every commercial electronic message we send includes a functional unsubscribe option. For SMS, you can reply with the opt-out instruction in the message. For email, you can use the unsubscribe link in the email.

You can also ask us to stop contacting you at any time by emailing [email protected]. We will action your request within a reasonable time and in any event within the time required by law.

We handle commercial electronic messages in accordance with the Spam Act 2003 (Cth) and the Australian Privacy Principles.

We use the following third-party tools and service providers that handle personal information:

• (a)HighLevel, which we use for our customer relationship management system, text messages, email and calendar, and which stores data overseas (see clause 8);
• (b)Meta (Facebook and Instagram), including the Meta pixel and Meta lead ads, which collect information through our website and lead forms;
• (c)Google Analytics and Google Ads, which use cookies and usage data only, such as device, browser and IP address. We do not send names, email addresses or phone numbers to Google;
• (d)Loom, which we use to create and share video messages; and
• (e)Google Meet and HighLevel meeting rooms, which we use to hold video calls.

We require our service providers to handle personal information only as needed to provide their services to us. These providers also have their own privacy policies, and we encourage you to read them.

We do not sell personal information.

We may also disclose personal information to our professional advisers, to a person who acquires or merges with our business, or where the law requires or authorises disclosure.

Some of the tools we use store or process personal information outside Australia. In particular, HighLevel stores data overseas. Meta and Google may also process information in countries outside Australia.

The countries where this may occur include the United States, where HighLevel stores data, and other countries where Meta and Google operate their data centres, and the countries where our AI providers operate.

Before disclosing personal information overseas, we take reasonable steps to ensure the overseas recipient handles it in a way that is consistent with the Australian Privacy Principles, unless an exception under the Privacy Act applies.

Our website uses cookies, the Meta pixel, Google Analytics and Google Ads tracking. These collect information such as device type, browser type, IP address, pages visited and how you interact with our website.

This information helps us understand how our website is used, measure our advertising and show our advertising to people who may be interested in our services.

You can control cookies through your browser settings. You can opt out of Google Analytics using Google's browser add-on, and manage your Meta advertising preferences through your Meta account settings. Blocking some cookies may affect how our website works.

We use automation and AI tools in our business. This includes AI assistants that talk with people by text, email or chat to answer questions and help book appointments. We also use AI tools to help us write and prepare content. If you ask whether you are talking with an AI assistant, we will answer honestly. AI tools may process the information you give us, such as your messages and contact details, and some AI providers process information outside Australia (see clause 8). We also build and run AI tools for our clients. When we do, we handle personal information on the client's behalf under our agreement with them.

Automated replies, reminders and follow-ups are sent through HighLevel. These use the personal information you give us, such as your name, contact details and booking details, to send messages to you at the right time.

We do not use automated tools or AI to make decisions that significantly affect a person's rights or interests, such as refusing a service or setting a price. A person is involved in those decisions.

The kinds of personal information used by our automation tools are your name, email address, phone number and booking details. If this changes, we will update this policy.

You do not need an account to make an enquiry or book a call.

When you become a client, we give you a login account to our white-labelled HighLevel platform at app.actiondigital.com.au.

We hold your account information, including your name, email address, phone number, login credentials and the information you and your team add to or generate through the platform, for as long as your account is open and as needed to provide our services.

We take reasonable steps to keep account information secure, including by limiting access to people who need it for their role.

You can ask us to close your account at any time by emailing [email protected]. When we close your account, we will remove your access to the platform. We will then delete or de-identify your personal information when we no longer need it, unless we are required or authorised by law to keep it or need it to resolve a dispute.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These steps include password-protected systems and restricting access to personal information to people who need it.

We keep personal information only for as long as we need it for the purposes in this policy or as the law requires. When we no longer need it, we take reasonable steps to destroy or de-identify it.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

If a data breach occurs that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Privacy Act.

You can ask to access the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, email [email protected]. We may need to verify your identity first.

We will respond to your request within a reasonable period, and in any event within 30 days. If we refuse your request, we will give you written reasons and explain how you can complain.

We do not charge for making a request. We may charge a reasonable fee for giving you access, and we will tell you about any fee before we proceed.

If you think we have breached the Australian Privacy Principles or mishandled your personal information, please send your complaint to [email protected] with details of your concern.

We will acknowledge your complaint promptly, investigate it and respond within a reasonable period.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

We may update this policy from time to time. The current version is published on our website with the date it was last updated.

We update this policy when our practices, tools or legal requirements change, including to address the automated decision-making transparency requirements that commence on 10 December 2026.