1) Introduction
Growth Spark Digital LLC (“we”, “us”, “our”) is committed to protecting your privacy and managing your personal information in an open and transparent way in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).
This policy explains what personal information we collect, how we use and disclose it (including where our Service uses AI and automation), how we store and secure it, and the choices and rights you have.
By using our websites, tools and services in Australia (the “Service”), you agree to this policy.
For terms governing your use of our Service, see our Terms & Conditions.
2) Personal Information We Collect
“Personal information” has the meaning given in the Privacy Act 1988 (Cth) and broadly includes information or an opinion about an identified individual, or an individual who is reasonably identifiable.
2.1 Identity & Contact Details
- Name, email address, phone number, postal or street address
- Business or company details and your role/position
- Billing details (processed via third‑party payment providers)
- Login credentials and account identifiers
2.2 Usage, Technical & Metadata
- IP address, device information, operating system, browser type
- Pages visited, timestamps, referrer URLs, error logs
- Cookies, pixels, beacons and session identifiers
2.3 Content & Input Data
- Messages, files, form entries and uploads you submit to the Service
- AI‑generated outputs created while you use our AI features
- Feedback on AI outputs and your usage history of AI features
2.4 Third‑Party / Integration Data
- Information received when you connect third‑party tools (for example, CRM, calendars, messaging apps), in line with the permissions you grant
2.5 Aggregated / De‑identified Information
- Analytics and insights that do not reasonably identify you
3) How We Use Your Information (incl. AI)
We only collect, use and disclose personal information that is reasonably necessary for our functions and activities, or as otherwise permitted or required by law.
- Provide, maintain and secure the Service
- Authenticate accounts and deliver customer support
- Generate AI‑assisted content and responses at your request
- Monitor performance, detect and prevent abuse, spam and fraud
- Analytics, reporting and improving our Service and AI models
- Communications: emails, notifications and service updates
- Legal compliance, record keeping and enforcement of our terms
3.1 Automated / AI‑Supported Decision‑Making
Where AI assists with responses, recommendations or automation, you remain in control and can review, correct or override outputs at any time.
We do not rely on solely automated decisions that are likely to have legal or similarly significant effects on individuals without appropriate human review.
3.2 Training & Improvement
We may use de‑identified or aggregated data to improve our AI models, automation workflows and overall Service performance.
We avoid using identifiable content for model training without your explicit consent, and you can opt out of training use of your data (see section 6).
5) Retention & Deletion
We keep personal information only for as long as it is needed for the purposes for which it was collected, or as required or permitted by Australian law (for example, for tax or record‑keeping obligations). [web:11]
When information is no longer required, we take reasonable steps to destroy or de‑identify it. Model artefacts or aggregated statistics used for analytics or AI improvement may be retained without underlying raw personal information.
6) Your Rights in Australia
Subject to certain exceptions under the Privacy Act, you have rights in relation to your personal information.
- Access – request access to personal information we hold about you
- Correction – request that we correct inaccurate, out‑of‑date or incomplete information
- Opt‑out of marketing – opt out of receiving direct marketing communications from us
- Manage cookies and tracking – control cookies via your browser or device settings (see section 9)
- Opt‑out of AI training – request that your identifiable data is not used to train our AI models
- Complain – lodge a privacy complaint with us and, if unresolved, with the Office of the Australian Information Commissioner (OAIC)
To exercise these rights, email [email protected]. We may need to verify your identity before we can respond to your request.
7) Overseas Disclosure
Our service providers and partners may be located in, or may store personal information in, countries outside Australia, including (but not limited to) the United States, the United Kingdom and member states of the European Union. [web:5][web:11]
Where we disclose personal information overseas, we take reasonable steps to ensure that the recipient handles your information in a way that is consistent with the Australian Privacy Principles.
8) Security
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, as required by the Privacy Act and APP 11.
- Encryption in transit and at rest where feasible
- Access controls, authentication and role‑based permissions
- Monitoring, logging and periodic security reviews
- Secure deletion and disposal practices for systems and media
No method of transmission or storage is completely secure, but we act promptly to investigate and mitigate any suspected privacy or security incidents.
10) Changes to this Policy
We may update this Privacy Policy from time to time, for example to reflect changes to our Service, our use of AI, or Australian privacy laws.
We will publish the updated policy on this page and update the “Last updated” date above. Your continued use of the Service after any change takes effect will constitute your acceptance of the updated policy.
11) Children
Our Service is designed for business users and is not directed to children. We do not knowingly collect personal information from children under the age required by applicable law in Australia or in the relevant jurisdiction. [web:9]
If you believe we have collected personal information about a child, please contact us so we can take appropriate steps to delete it.
12) Contact & Complaints
If you have any questions about this Privacy Policy, or if you wish to make a privacy complaint or exercise your rights, please contact us:
Growth Spark Digital LLC
Email: [email protected]
We will respond to your enquiry or complaint within a reasonable period. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
This Privacy Policy is intended to meet the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles for our handling of personal information in Australia.
