Privacy Policy

Purpose

This Privacy Policy applies to Omnipulse Pty Ltd (Omnipulse, we, us or our). It explains how we handle the personal information of the people we deal with, including visitors to our website, people who contact us, and representatives of the businesses we advise.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (the APPs). Where we deal with individuals in New Zealand, we also have regard to the New Zealand Privacy Act 2020.

There may be times when we handle personal information differently from the way described here. Where that happens, we will give you a separate privacy notice at the time that applies in place of, or in addition to, this Policy.

If you have any questions about how we handle personal information, please contact us using the details at the end of this Policy.

Collection of personal information

The main kinds of personal information we collect and hold are:

• the contact details and roles of our actual and prospective clients, suppliers and business contacts, typically names, business email addresses, phone numbers, job titles and the name and size of the business you work for;
• information you give us when you complete a form on our website, book a call, or contact us by email, phone or other means, including anything you choose to tell us in a message;
• information we collect to provide our advisory services to a client, which can include information about the client's business, its people and how it operates; and
• technical information collected automatically when you use our website (see "Our website" below).

We collect most personal information directly from you, for example when you fill in a form, book a call, email us, or speak with us. We may also collect it from publicly available sources (such as your business's website or your professional profile) and from people who refer you to us.

We do not generally collect sensitive information (as defined in the Privacy Act). If we ever need to, we will ask for your consent first.

You can deal with us anonymously or using a pseudonym where it is lawful and practicable, for example when asking a general question. For most of what we do, though, we need your contact details to help you.

If you choose not to give us the information we ask for, we may not be able to respond to your enquiry or provide our services.

Why we collect, use and disclose personal information

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

• respond to your enquiry and tell you about our services;
• provide our advisory services and meet the terms of our client agreements;
• communicate with you and manage our relationship with you;
• issue invoices and manage payments and our accounts;
• run, maintain, secure and improve our website and our business;
• send you marketing communications, where this is permitted (see "Marketing communications" below);
• meet our legal, regulatory and professional obligations; and
• protect our rights, our people, and the people we deal with.

We use a range of third-party providers to run our business and deliver our services. This means some organisations outside Omnipulse will, at times, store or have access to personal information we hold. These providers include cloud hosting and website providers, contact and customer-relationship management providers, email and scheduling providers, artificial intelligence tools, and our professional advisers (such as accountants and lawyers). We only share what is necessary, and we require these providers to protect personal information and use it only for the purpose we engaged them for.

We may also disclose personal information where required or permitted by law, and to a buyer (and its advisers) if we sell or restructure our business, subject to confidentiality protections.

We do not sell personal information.

Artificial intelligence

We use artificial intelligence tools in our internal operations and as part of our advisory work. Where personal information is involved, we provide only what is necessary for the task, we choose providers that offer enterprise-grade privacy and security commitments, and we do not permit those providers to use the information to train their general models where that choice is available to us. We treat information handled through AI tools with the same confidentiality as the rest of our business.

Marketing communications

We may send you marketing communications by email or other electronic means, for example updates about our work and services, where we are permitted to do so under the Privacy Act 1988 (Cth) and the Spam Act 2003 (Cth) (and, in New Zealand, the Unsolicited Electronic Messages Act 2007).

Every marketing message we send includes a way to unsubscribe. You can also opt out at any time by contacting us using the details at the end of this Policy. If you opt out, we may still contact you about other things, such as a service we are providing to you.

Disclosure of information outside Australia

Some of the providers we use, or their parent companies, are located overseas or may access information from overseas. In particular, personal information may be disclosed to, processed in, or accessed from the United States, for example through our website analytics and the AI tools we use, and because some of our providers are United States companies.

Where we disclose personal information overseas, we take reasonable steps to ensure it is handled consistently with the APPs. Because of differences in overseas laws, those protections may not be the same as under Australian law, and the Privacy Act may not apply to the overseas recipient.

Our website

Our website is hosted on infrastructure located in Sydney, Australia. To run and secure the site, our hosting provider records standard server logs (such as IP address, browser type, the pages requested, the referring website, and the date and time). This information is used to operate and protect the site and is not used to identify you, except where necessary for security.

We use a privacy-focused, cookieless analytics tool to understand how the site is used, for example which pages are viewed, and general information such as country (country level only), device type and browser. It does not set cookies, does not place a persistent identifier in your browser, and is not used to build a profile of you, to advertise to you, or to track you across other websites. This analytics data is processed overseas, in the United States (see "Disclosure of information outside Australia").

Our website does not set tracking or advertising cookies. We store one setting in your browser to remember your light or dark theme preference; it holds no personal information and is never sent to us.

If you book a call, you are taken to a third-party scheduling page, which operates under its own provider's privacy terms and may set its own cookies.

We provide links to other websites for your convenience. We are not responsible for the privacy practices of those sites, and we encourage you to read their privacy policies.

Security of personal information

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include limiting access to people who need it, using reputable providers with appropriate security commitments, requiring strong authentication, and keeping confidentiality and information-handling practices for our team.

No system can be guaranteed to be completely secure. If an eligible data breach occurs, we will respond in line with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

How long we keep personal information

We keep personal information only for as long as we reasonably need it for the purposes described in this Policy, or as required by law. When we no longer need it, we take reasonable steps to securely destroy or de-identify it. As a guide:

• enquiry information is generally kept for up to 24 months where no engagement proceeds;
• client engagement records are generally kept for 7 years after the engagement ends; and
• marketing-subscriber information is kept until you unsubscribe.

Access to and correction of your information

You can ask us for access to the personal information we hold about you, and ask us to correct it if it is wrong, out of date or incomplete. We will respond within a reasonable time (ordinarily within 30 days). We may need to verify your identity first. In limited cases the law allows us to decline access, and if that happens we will explain why.

Concerns and complaints

If you have a concern or complaint about how we have handled your personal information, please contact us using the details below and we will work to resolve it. If you are not satisfied with our response, you can contact:

• in Australia, the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992; or
• in New Zealand, the Office of the Privacy Commissioner at www.privacy.org.nz or on 0800 803 909.

Changes to this Policy

We may update this Policy from time to time by publishing a new version on our website. The "Last updated" date shows when it last changed. Where a change is significant, we will take reasonable steps to bring it to your attention.

Contact us

For any questions about this Policy or our handling of personal information, please contact our Privacy Officer: