1) Introduction

This Privacy Policy explains how Growth Spark Digital LLC (“we”, “us”, “our”) collects, uses, stores and discloses personal information in connection with our services provided to Australian businesses.

We are a company registered in Wyoming, United States. We provide CRM systems, AI voice solutions, automation software and marketing services to business clients in Australia.

This policy is intended to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”). By using our website or services, you agree to this policy.

2) The Information We Collect

We collect personal information that is reasonably necessary for our business functions and activities.

2.1 Business & Contact Information

• Name, business name, position and contact details
• Email address, phone number and billing details
• Account login credentials

2.2 Technical & Usage Data

• IP address, browser type, device data and system logs
• Website usage, session data and analytics information

2.3 Client Data & AI Inputs

• Information you upload or input into our CRM or AI systems
• Messages, call data, workflow data and automation triggers
• AI-generated responses created at your direction

We do not intentionally collect sensitive information unless it is necessary for service delivery and provided by you.

3) How We Use Personal Information

We use personal information only for legitimate business purposes, including to:

• Provide and configure our services
• Operate AI voice and automation systems at your request
• Process payments and manage subscriptions
• Provide support and account management
• Improve system performance and reliability
• Comply with legal obligations

AI & Automation

Our services include AI-powered tools. AI outputs are generated based on system prompts and user inputs. Clients remain responsible for reviewing and approving automated communications before reliance where appropriate.

We do not make solely automated decisions that produce legal or similarly significant effects without appropriate human involvement.

4) Disclosure of Personal Information

We may disclose personal information where reasonably necessary to deliver our services, including to:

• Hosting providers and cloud infrastructure partners
• CRM and telephony platforms
• Payment processors (e.g. Stripe)
• Email delivery and analytics providers

We may also disclose information where required or authorised by law, including to regulators or law enforcement agencies.

5) Overseas Disclosure

As we are a United States registered company, and use international technology providers, personal information may be stored or processed outside Australia, including in the United States and other jurisdictions.

Where overseas disclosure occurs, we take reasonable steps to ensure recipients handle personal information in a manner consistent with the Australian Privacy Principles.

6) Data Security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

• Encrypted data transmission where available
• Role-based access controls
• Secure third-party infrastructure providers
• Regular monitoring and system review

No system is completely secure. You acknowledge that internet-based services carry inherent risks.

7) Data Retention

We retain personal information only for as long as required to provide our services, comply with legal obligations, resolve disputes and enforce agreements.

When information is no longer required, we take reasonable steps to securely delete or de-identify it.

8) Access & Correction

You may request access to personal information we hold about you, and request correction of inaccurate or incomplete information, subject to limited exceptions under Australian law.

Requests can be made by contacting us at [email protected]. We may require identity verification before processing requests.

9) Marketing Communications

We may send service-related communications and limited marketing updates. You may opt out of marketing emails at any time using the unsubscribe link or by contacting us directly.