Privacy Policy

Who this policy applies to

This policy applies to personal information we handle about:

• visitors to our website at pulpdigital.com.au and our social media channels;
• our clients, prospective clients, and the people who work for them;
• our clients' customers and audiences, where we handle their information to deliver services to our clients;
• creators, talent and other people who appear in, or submit, content we work on;
• job applicants, contractors, suppliers and referral partners; and
• people who subscribe to our emails, join our community or attend our events.

Where the employee records exemption in the Privacy Act applies, this policy does not cover records about our current and former employees. We handle those under our internal policies.

What personal information is

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. It does not matter whether the information is true, or whether it is recorded in a material form.

We treat online identifiers, such as IP addresses, device identifiers and cookie or pixel IDs, as personal information where they can reasonably be linked to you.

The personal information we collect

The information we collect depends on how you deal with us. It may include:

• Contact and identity details: your name, job title, business name, email address, phone number, business address and social media handles.
• Business and commercial details: information about your brand, goals, budgets, results, contracts, invoices and payment history. Card payments are handled by our payment providers, and we do not store full card numbers.
• Platform access: user access you give us to advertising accounts, analytics, eCommerce stores, email marketing platforms and similar tools so we can deliver our services.
• Communications: emails, messages, meeting notes, and recordings or transcripts of calls and video meetings.
• Website and device information: your IP address, browser and device type, pages you view, links you click, the site that referred you, your approximate location, and cookie and pixel identifiers.
• Content: photos, video, voice recordings and likenesses of people who appear in content we create, brief or review, along with related consents and release forms.
• Recruitment and engagement details: CVs, work history, portfolios, referee details, work rights, and the bank and tax details we need to pay contractors and suppliers.
• Preferences: your marketing preferences and feedback you give us.

Sensitive information

Sensitive information includes information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record, health and biometric information. We do not usually need it. We only collect sensitive information with your consent and where it is reasonably necessary for our functions, or where the law otherwise allows it. Some of our clients work in health and wellness, and their customer data may include sensitive information. We handle that information only on our client's instructions and with extra care.

How we collect personal information

We collect personal information:

• Directly from you, when you fill in a form on our website, email or call us, book or join a meeting, sign a proposal or agreement, apply for a role, subscribe to our emails, or message us on social media.
• Automatically, through cookies, pixels, tags and analytics tools when you use our website or interact with our ads. See Cookies, pixels and analytics below.
• From third parties, including our clients, advertising and social media platforms, referral partners, recruiters, and publicly available sources such as business websites and LinkedIn.

Where we collect information about you from someone else, we take reasonable steps to make sure you are aware of it.

We may record or transcribe calls and video meetings so we can keep accurate notes and act on what was discussed. We will let you know when this is happening, and you can ask us not to record.

If we receive personal information we did not ask for and could not have collected under the APPs, we will destroy or de-identify it where it is lawful and reasonable to do so.

Why we collect and use personal information

We collect, hold and use personal information to:

• respond to enquiries and prepare proposals and quotes;
• deliver our services, including strategy, ad campaigns, creative production, reporting and account management;
• manage our client relationships, contracts, invoicing and payments, and recover money owed to us;
• run, secure and improve our website, services and internal systems;
• send you marketing, content and updates you are likely to be interested in;
• measure the performance of our own advertising and show relevant ads to people who have visited our website;
• assess job applicants and engage contractors and suppliers;
• pay referral partners for introductions that become clients;
• meet our legal, tax and regulatory obligations; and
• handle complaints and resolve disputes.

We may also use personal information for a related secondary purpose you would reasonably expect, or where the law requires or allows it. If we cannot collect the information we need, we may not be able to respond to your enquiry, provide our services or consider your application.

Information we handle for our clients

To deliver our services, our clients may give us access to personal information about their own customers and audiences. This can include customer lists, email subscriber data, order data and advertising audience data.

We handle this information on our client's behalf, only to deliver the services they have engaged us for and in line with our agreement with them. When we upload customer lists to advertising platforms to build custom or lookalike audiences, we use the platforms' matching tools, which hash the data before it is matched.

We do not sell personal information, and we do not use one client's customer data for another client.

If you are a customer of one of our clients, that brand's privacy policy explains how they handle your information, and you can contact them directly. If you contact us, we will pass your request to the relevant client and help them respond.

Cookies, pixels and analytics

Our website uses cookies and similar technologies, including Google Tag Manager and analytics and advertising tools such as Google Analytics, the Meta Pixel, the TikTok Pixel and the LinkedIn Insight Tag. These tools help us understand how people use our site, measure our marketing, and show our ads to people who have visited the site.

These tools send information such as your IP address, device details, pages viewed and actions taken to the provider of the tool. Some of those providers may combine it with other information they hold about you, under their own privacy policies.

We configure these tools so they do not capture what you type into forms on our website, and we do not use them to send sensitive information to advertising platforms.

Our website, booking pages and forms also keep their own record of your visits in your browser, using local storage and a first-party cookie that lasts up to 13 months. It notes where each visit came from (such as an ad, a search engine or another website), the pages you viewed, how long you spent on each and how far you scrolled, the links you clicked, your device and browser type, and your approximate location based on your IP address. This record stays on your device unless you send us an enquiry, book a call or submit a form. If you do, it is sent with your enquiry and kept with it in our CRM, so we can understand how you found us and what you were interested in. We do not share it with advertising platforms. You can delete it at any time by clearing your browser's site data for pulpdigital.com.au.

You can manage cookies through your browser settings, and limit personalised ads through the ad settings in your Google, Meta, TikTok and LinkedIn accounts, or at youronlinechoices.com.au. Blocking some cookies may affect how our website works.

AI tools and automated decisions

We use artificial intelligence tools, including generative AI and meeting transcription tools, to help with research, drafting, creative development, data analysis and admin. When we do:

• we choose business-grade tools with appropriate privacy and security protections;
• where we can control it, we turn off settings that let providers use our clients' or your personal information to train their models;
• we only put personal information into these tools when it is needed for the task; and
• a person on our team reviews the work before it is used.

The advertising platforms we use, such as Meta, Google and TikTok, use their own automated systems to decide who sees ads. Those systems are run by the platforms, under their own policies.

We do not currently use computer programs to make decisions, or to do things substantially and directly related to making decisions, that could reasonably be expected to significantly affect your rights or interests. If that changes, we will update this policy to describe the kinds of personal information used and the kinds of decisions involved, as the APPs require.

Direct marketing

We may send you emails and other marketing about our services, content and events where you have agreed to receive it, or where the law otherwise allows it. Every marketing email includes an unsubscribe link. You can also opt out at any time by contacting us. We comply with the Spam Act 2003 (Cth), and we do not sell or rent our mailing lists.

Who we share personal information with

We may disclose personal information to:

• our team, including contractors who work on client accounts;
• service providers who help us run our business, such as cloud hosting, email, CRM, project management, communication, accounting, payment, proposal, meeting recording and AI providers;
• advertising, social media and eCommerce platforms, as needed to deliver our services or run our own marketing;
• our clients, for example when we share creative content or campaign results;
• referral partners, limited to confirming that a business they introduced has engaged us, so we can pay referral fees;
• our professional advisers, insurers and auditors;
• debt collectors and lawyers, where we need to recover money owed to us or enforce our agreements;
• a buyer or potential buyer of our business, under confidentiality obligations; and
• government agencies, regulators, courts and law enforcement, where the law requires or allows it.

We require our service providers to handle personal information only for the purpose we give it to them for, and to keep it secure.

Overseas disclosure

Many of the tools and platforms we use store or process data outside Australia. As a result, personal information may be disclosed to recipients in the United States, Ireland and other European Union countries, the United Kingdom and Singapore. Where we engage contractors based outside Australia, information may also be accessed from the country where they are located.

Before we disclose personal information overseas, we take reasonable steps to make sure the recipient handles it in line with the APPs, unless an exception in the Privacy Act applies.

How we keep personal information secure

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, change or disclosure. These include:

• using reputable cloud systems with encryption and multi-factor authentication;
• limiting access to the people who need it for their role;
• using user-level access to client platforms rather than shared passwords, and removing our access when an engagement ends; and
• training our team on privacy and data security.

No system is completely secure. If we have a data breach that is likely to result in serious harm, we will notify affected people and the Office of the Australian Information Commissioner (OAIC) in line with the Notifiable Data Breaches scheme.

How long we keep personal information

We keep personal information only for as long as we need it for the purposes in this policy, or as the law requires. We generally keep client, contract and financial records for seven years to meet our legal and tax obligations. When we no longer need personal information, we take reasonable steps to destroy it or de-identify it.

Dealing with us anonymously

You can deal with us anonymously or using a pseudonym where it is lawful and practicable, for example when you ask a general question. We cannot provide services, engage you or process payments without knowing who you are.

Accessing and correcting your information

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. Contact us using the details below.

We will need to confirm your identity before we act on a request. We aim to respond within 30 days. Making a request is free. If you ask for a copy of a large amount of information, we may charge a reasonable fee to cover our costs, and we will tell you before we do.

If we refuse your request, we will tell you why in writing and explain how you can complain.

Children

Our services are for businesses, and our website is not directed at children under 18. We do not knowingly collect personal information directly from children. If content we work on involves a person under 18, we make sure consent has been given by their parent or guardian.

If you are outside Australia

If you are located in the European Union, the United Kingdom or another country with its own privacy laws, you may have additional rights over your personal information under those laws. Contact us and we will help.

Complaints

If you have a concern about how we have handled your personal information, please contact us first using the details below. We will acknowledge your complaint, look into it, and aim to give you a response within 30 days.

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

Changes to this policy

We may update this policy from time to time, for example when the law changes or we start using new tools. The latest version will always be on our website, with the date it was last updated at the top.

Contact us

For privacy questions, requests or complaints, contact our Privacy Officer: