JADESTART®

Privacy Policy

Last amended 26 June 2026

1.1 Background

We recognise and value:

a)the protection of your personal information; and

b)that you have an interest in our collection and use of your personal information.

We have implemented this Privacy Policy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APP) and other data protection rules, in order to be open and transparent about how we collect, hold and use your personal information, and under what circumstances we may disclose or transfer it.

Please note that this Privacy Policy forms part of the JadeStart ABN 13 605 681 838 (we, our, us and other similar terms) terms and conditions of our various agreements with you (if any).

1.2 Disclaimer

While your privacy is very important to us, nothing in this Privacy Policy constitutes a voluntary opt in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with.

1.3 What is personal information?

Personal information held by us may include your:

a)name and date of birth;

b)any information that you otherwise share with us;

c)your computer and connection information;

d)preferences and password for using our software and services;

e)any information that you provided to us during an account creation process or added to your user profile;

f)bank account or credit card details for agreed billing purposes; and

g)residential and business postal addresses, telephone, mobile and fax numbers, and email addresses.

Some personal information is sensitive information under the Privacy Act, such as health information. We do not generally seek sensitive information, and we will only collect it where it is reasonably necessary for our services and with your consent, or where we are otherwise permitted or required by law.

1.4 Collection

We collect personal information:

a)when you use the website and any associated services or software, including (without limitation) when you:

(i)engage with our content or any platforms we choose to host that content on;

(ii)use our software or services, or the software and services of any associated third parties under an agreement with us;

(iii)create an account;

(iv)enter information on software or services which we provide to you;

(v)add information to your user profile;

(vi)purchase any services, hardware or software through us or our site;

(vii)engage with our chat functionality, including by chatting directly with our representatives;

(viii)complete an online contact form to contact us or any third party supplier;

(ix)provide information to us by telephone or through marketing forms; or

(x)send us an email or other communication;

b)in order to assist you with the supply of products, the provision of services and any related assistance or other purposes requested through such communication.

Information will be collected directly from you unless you authorise another person to provide the information. We may also collect information about you from third party sources such as business partners or mailing lists, subject to their respective policies.

IP addresses

We may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. We collect and manage IP addresses as part of our services and website and for security purposes. We may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activity involving, the website and any products or services.

1.5 Personal information we handle on behalf of our clients

In providing consulting, marketing and HR services, we may handle personal information about other people on behalf of our clients, for example a client’s staff, contractors or customers. Where we do this, our client decides the purpose for which that information is handled and is responsible for it as the controller of that information. We handle it on the client’s instructions and only to provide the agreed services. [updated]

Our client is responsible for ensuring it has collected that information lawfully and has provided any required collection notices and obtained any required consents before disclosing it to us. If you are an individual whose information has been provided to us by one of our clients and you have a question about how your information is handled, please contact that organisation in the first instance, and you may also contact our Privacy Officer using the details below.

1.6 Use

The personal information you provide is used for purposes related to our primary business operations. Examples of when your information may be used include:

a)providing you with the products and services you have requested;

b)administration needs in relation to providing you with products and services, including your account;

c)dealing with requests, enquiries or complaints and other customer care related activities;

d)verifying your identity;

e)informing you about our products and services;

f)assisting you to use functionality on the website or services;

g)processing any purchases of services that you may make through us or this site, including charging, billing and collecting debts;

h)making changes to your account;

i)responding to any queries or feedback that you may have;

j)conducting appropriate checks for credit-worthiness and for fraud;

k)preventing and detecting any misuse of, or fraudulent activity involving, this site, the services or software;

l)conducting research and development in respect of our services;

m)gaining an understanding of your information and communication needs, or obtaining your feedback or views about our services in order for us to improve them;

n)maintaining and developing our systems and infrastructure, including testing and upgrading of these systems;

o)marketing our products and services generally; and

p)carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on us, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;

and for any other purpose reasonably considered necessary or desirable by us in relation to the operation of our organisation.

We may also use personal information for purposes (as would be reasonably expected by you) in connection with those activities described above. We will not use your information for purposes other than as described in this Privacy Policy unless we have your consent, or there are specific law enforcement, public health or safety reasons.

1.7 Our use of artificial intelligence tools

We use artificial intelligence tools (AI Tools) to support the delivery of our services, including drafting, research, analysis and reporting, website design and build, the setup and management of advertising across Google and Meta, social media and email content, and administrative tasks. AI Tools support our work and do not replace our professional judgement, and AI-assisted work is reviewed by a member of our team before it is provided to you. [updated]

AI Tools are provided by third parties under their own terms and privacy policies. We take the security of your information seriously and we do not input personal information that identifies you or any individual, such as full names, contact details, financial details or account access information, into any AI Tool unless that tool operates under a confirmed zero data-retention policy or an equivalent contractual data-protection standard. We take reasonable steps to limit the information used with AI Tools to what is reasonably necessary for the relevant task.

1.8 Automated decision-making

We use AI Tools to assist our work, but we apply human oversight, and we do not use computer programs to make decisions, solely or substantially by automated means and without meaningful human involvement, that could reasonably be expected to significantly affect your rights or interests. If we introduce any such automated decision-making in the future, we will update this Privacy Policy to describe the kinds of personal information used and the kinds of decisions made. This reflects the new automated decision-making transparency requirements added to the Privacy Act by the Privacy and Other Legislation Amendment Act 2024 (Cth), which apply from 10 December 2026. [updated]

1.9 Our use of cookies, pixels and web beacons

This site and our products and services may use cookies to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used by us: a persistent cookie and a session cookie.

A persistent cookie is entered by your web browser into the cookies folder on your computer and remains there after you close your browser, and may be used on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer.

Cookies cannot be used to run programs. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

1.10 Why we use cookies

This site and our other services may use cookies in order to:

a)remember your preferences;

b)recognise you as logged in while you remain so, which avoids you having to log in again every time you visit a new page;

c)show relevant notifications to you (for example, notifications relevant only to users who have, or have not, created an account or subscribed to newsletters or other subscription services); and

d)remember details of data that you choose to submit to us (for example, through online contact forms or by way of comments, forum posts, chat messages, reviews or ratings).

Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through this site. For example:

a)Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies to collect de-identified data about how long users spend on this site and the pages that they visit;

b)Google Ads (formerly Google AdWords), one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times a particular advertisement is shown to you; [updated]

c)the Meta Pixel (formerly the Facebook Pixel), a re-marketing cookie and service which allows us to advertise to previous visitors to this site based on their activity. The pixel triggers based on actions you take on our website and means we can reach you again using Meta’s re-marketing tools across Facebook, Instagram and partner platforms. We can also use it to tailor our marketing to better suit your needs. None of your personal Meta account information is reported to us by our use of the pixel, and Meta implements its pixel service in accordance with its terms and privacy policy. Meta provides privacy functionality that lets you opt out of targeted advertising, and we recommend you use it if you have any concerns; and [updated]

d)third party social media applications (for example Facebook, Instagram, LinkedIn, Pinterest, YouTube and X) may use cookies in order to facilitate various social media buttons or plugins on this site. Log files track actions occurring on the websites and collect data including your IP address, browser type, internet service provider, referring and exit pages, and date and time stamps.

1.11 Our use of Google Analytics

In the case of Google Analytics, information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

1.12 Interacting with us

If you contact us with a general question, we may interact with you anonymously or through the use of pseudonyms. However, you are required to provide true and accurate details when requesting the supply of products or the provision of support services. You agree that you will provide accurate information if so required.

1.13 Direct marketing

From time to time we may send you marketing or promotional material. Marketing and promotional material will only be sent to you if you have opted into receiving marketing material.

We, or an appointed third party, may also conduct surveys or market research and may seek other information from you on a periodic basis. These surveys provide us with information that allows us to improve the type, quality and manner in which our products and services are offered to you. To opt out of receiving marketing material, you may contact us or select the unsubscribe link provided in the email.

1.14 Children’s privacy

Our website and services are intended for use by adults aged 18 years or over and are not directed at children. We do not knowingly collect personal information from children. If you believe we have collected personal information from a child, please contact our Privacy Officer and we will take reasonable steps to delete it. [updated]

1.15 Sharing your personal information

We may disclose your personal information to:

a)employees, a related company and professional advisers such as our lawyers;

b)law enforcement agencies to assist in the investigation and prevention of criminal activities;

c)credit-reporting and fraud-checking agencies;

d)credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);

e)government and regulatory authorities and other organisations, as required or authorised by law;

f)organisations who manage our business strategies, including those involved in a transfer or sale of all or part of our assets or business, and those involved in managing our business risk and funding functions; and

g)third party contractors or service providers with whom we have a business association, including:

(i)integration providers;

(ii)marketing and advertising service providers, including Google and Meta advertising platforms;

(iii)email, CRM and scheduling providers;

(iv)accounting service providers;

(v)artificial intelligence tool providers, subject to the safeguards described in this Privacy Policy; and

(vi)information technology service providers, including cloud application providers.

We will not disclose your personal information other than in accordance with this Privacy Policy without your consent. Unless necessary for our business purposes, we will de-identify your information where it is shared with third parties under the paragraph above.

1.16 Overseas disclosure

We may disclose your personal information to third party contractors, service providers or customers with whom we have a business association. While we do not otherwise actively disclose your personal information to overseas entities (unless provided for in a separate agreement with you), we do engage service providers (such as cloud data services, communications providers and artificial intelligence tool providers) who may be based overseas or have international data centres, hardware and disaster recovery sites. Consequently, these providers may have access to your information. We rely solely on reputable organisations for such services.

1.17 Security of your personal information

We store your personal information using servers which have built-in measures to combat unauthorised access, modification or disclosure, and we take reasonable steps to protect personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. While we endeavour to only hold personal information that is accurate, complete and up to date, if you become aware that your information is no longer accurate, complete or up to date, please contact us.

1.18 Data breach notification

We maintain procedures to respond to actual or suspected data breaches. If a breach involving personal information we hold is likely to result in serious harm to any affected individual, we will assess and respond to it, and we will notify affected individuals and the Office of the Australian Information Commissioner as required under the Notifiable Data Breaches scheme in the Privacy Act. Where a breach involves personal information that we handle on behalf of a client, we will notify and cooperate with that client so that any notification obligations can be met. [updated]

1.19 Disposal of personal information

If we hold personal information about you and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the APP and the European Union General Data Protection Regulation (GDPR), unless we are prevented from doing so by law.

You may make a request to us in writing to remove your personal information and, where permitted, we will do so in accordance with the APP and the GDPR. Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions contemplated by those records are completed.

1.20 How to access your personal information

Upon your request, and after satisfying ourselves of your identity, we will provide access to the personal information we hold about you, except in certain prescribed circumstances which include where:

a)we believe giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;

b)giving you access would be unlawful;

c)granting that access would have an unreasonable impact on the privacy of other individuals;

d)we would be in breach of our obligations under a Technical Assistance Notice, Technical Capability Notice or Computer Access Warrant from an Australian Government agency;

e)the request for access is frivolous or vexatious; or

f)there are anticipated legal proceedings.

We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

1.21 Third party websites

You may click through to third party websites from this site, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only, and we assume no responsibility for the content of any third party websites. We may also use third party websites to deliver content to you. Any information we receive from you through these websites will be treated in accordance with this Privacy Policy; however, you acknowledge that we have no control over how those third party websites use your data and that they have privacy policies of their own.

1.22 GDPR

We welcome the General Data Protection Regulation (GDPR) of the European Union (EU) as an important step forward in streamlining data protection globally. We intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.

GDPR rights

The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:

a)you are entitled to request details of the information that we hold about you and how we process it. For EU residents, we will provide this information for no fee;

b)you may also have a right to:

(i)have that information rectified or deleted;

(ii)restrict our processing of that information;

(iii)stop unauthorised transfers of your personal information to a third party;

(iv)in some circumstances, have that information transferred to another organisation; and

(v)lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and

c)where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. However, please be aware that:

d)such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could prevent us from legitimately providing our services to other clients subject to appropriate confidentiality protections; and

e)even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:

(i)to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and

(ii)in exercising and defending our legal rights and meeting our legal and regulatory obligations.

1.23 Compliance with Australian Assistance and Access legislation

The laws in Australia compel companies to share data with Australian intelligence agencies and law enforcement, or to build in data sharing mechanisms which may report directly to these agencies. While we endeavour to protect your data and our technology from vulnerabilities wherever possible, we cannot break the law, nor can we inform you when we have been issued with a notice under this legislation.

By using our platform or website, you expressly release and indemnify us from any liability to you which arises from sharing data or building data sharing mechanisms (including back-doors and vulnerabilities) into our technology at the direction of the Australian Government and its agencies, including where those mechanisms are later exploited by a third party.

1.24 User security

New digital threats are emerging all the time, and the online environment is more hostile than ever. To protect your data online, including any data or material transmitted by you to us, we recommend reading, implementing and observing the procedures and safety tips recommended by business.gov.au and the Australian Cyber Security Centre (cyber.gov.au) from time to time.

1.25 Complaints procedure

Your privacy is important to us. If you have a complaint or concerns about our information handling processes as they relate to your personal information, we ask that you first contact our Privacy Officer whose contact details are listed below. If, after we have conducted our investigations, you are still not satisfied, then we ask that you consult with:

The Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001. Telephone: 1300 363 992. Email: enquiries@oaic.gov.au

1.26 How to contact us

If you have any queries, questions, concerns or wish to make a complaint regarding how we deal with your personal information, please contact us:

Privacy Officer, JadeStart, PO Box 1223, Tewantin, QLD 4565. Email: admin@jadestart.com

1.27 Amendments to this Privacy Policy

We are obligated to regularly review and update this policy. We therefore reserve the right to amend this Privacy Policy at any time. Should any significant amendment occur, notification will be provided on the website after the changes have been made. Your continued use after you receive the notification indicates your consent to be bound by the amended Privacy Policy.

For further information about privacy in general, please refer to the Office of the Australian Information Commissioner’s website at oaic.gov.au. Alternatively, please contact our Privacy Officer using the details provided above.

GDPR Specific Addendum

Where you are a European Union citizen for the purposes of the GDPR, the following applies in relation to any data we collect from you.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

i)The right to access: you have the right to request that we provide you with copies of your personal data. We may charge you a small fee for this service.

ii)The right to rectification: you have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.

iii)The right to erasure: you have the right to request that we erase your personal data, under certain conditions. You can request this using our right to erasure form at jadestart.com/erasure.

iv)The right to restrict processing: you have the right to request that we restrict the processing of your personal data, under certain conditions.

v)The right to object to processing: you have the right to object to our processing of your personal data, under certain conditions.

vi)The right to data portability: you have the right to request that we transfer the data we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at admin@jadestart.com, or write to us at PO Box 1223, Tewantin, QLD 4565.