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PRIVACY POLICY

The Business Birds Pty Ltd (ABN 40 692 246 601) (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our business, The Business Birds, our website, our proprietary platforms such as Chirpy and Torque, in person, or through other means.

For individuals located in the European Economic Area (EEA), United Kingdom or Switzerland: Additional rights and protections apply to you under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (UK GDPR). Please refer to Appendix 1 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with GDPR and UK GDPR requirements.

Quick overview

We collect information you provide to us and information we gather when we interact with you
We use this information to provide our services and improve your experience
We protect your information using secure systems and processes
You have rights regarding your personal information, including access and correction rights

Information we collect

Identity and contact details

Name, address, email address and phone number
Professional details

Service related information

Payment and transaction details for products and services you've purchased from us or enquiries about our products and services
Your preferences for our services and your marketing preferences
Feedback and survey responses

Digital information

IP address and general location information derived from your IP address
Search and browsing behaviour
Website usage patterns
Cookie preferences

Recordings

Call recordings
Records of meetings and decisions

Professional information (for job applicants and workers)

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Information about your right to work in the relevant jurisdiction

How we collect personal information

Directly from you when you: interact with us, contact us, fill out forms.
From our clients: we may handle on personal information on behalf of our clients as part of the marketing services we provide to our clients.
Automatically when you: visit our website, use our technologies, interact with our online services.
From third parties: service providers, business partners, public sources, government organisations, public databases, joint marketing partners, affiliate programs, data providers and organisations or people authorised by you.
From publicly available sources: such as ASIC and other regulatory bodies, social media and professional networking sites such as LinkedIn.
CRM Data Linking: Information you provide through website enquiries, forms, AI conversations, bookings or other interactions may be linked to an existing customer or contact record in our systems. We do this to manage our communications with you and provide a consistent experience across all of your interactions with us.

Why we collect, hold, use and disclose personal information

We collect and use your personal information to run our business and provide our services as set out below.

Business operations

To manage our relationship with you as a customer or supplier
To process and deliver our products and services
To handle your inquiries, support requests, and communications
To maintain accurate records for billing and administration

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle inquiries made through our website or platforms
To manage your participation in surveys, feedback sessions, or events

Service improvement

To conduct analytics and market research
To improve our business operations and services
To develop and enhance our applications and platforms
To understand how our services are used

Marketing and promotions

To send you promotional information about our services and events
To generate, score and qualify leads from website traffic using our CRM, marketing platforms and AI tools
To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions, and special offers
To provide additional benefits to our customers

Employment purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment records

Legal and compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business records
To fulfill regulatory requirements or reporting obligations
To protect our legal rights and interests or as authorised by law

Our disclosures of personal information to third parties

We may disclose personal information to:

Service providers

IT service providers, including our customer relationship management software
Data storage providers
AI-powered lead generation and analytics tools including Next Level AI
Web hosting and server providers
Payment processors
Marketing and advertising providers
Analytics providers
Identity verification and compliance screening service providers

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers

Business partners

Our existing or potential agents
Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

Your information may be disclosed to our advisers
Your information may be disclosed to the potential purchaser's advisers
Your information may be included in the transferred assets

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities including as required for reporting obligations
Law enforcement officers

Other parties

Third parties you have authorised
Emergency services when necessary
Any other parties as required or permitted by law

We do not sell, rent or commercially share your personal information with third parties such as insurance companies, data brokers or third-party marketplaces. If you wish us to share your information with a specific third party, you may instruct us to do so in writing.

Overseas disclosure

Storage and access

We store your personal information in Australia, the United States of America and the United

Kingdom. Your information may also be accessed from or transferred to locations outside Australia in these circumstances:

When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is

necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.

Your privacy rights and choices

Providing information

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don’t want to provide information and we will let you know when information is required versus optional.

Access to your information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or

misleading and we will take reasonable steps to correct your information promptly. If we cannot

make the correction, we will explain why and discuss alternatives. You can ask us to add a

statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing

communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

How to contact us about your rights or to make a complaint and what happens next

Step 1: Contact our privacy officer

Email: [email protected]
Phone: 0430069209
Post: Suite #1066, 6/50 Miller St North Sydney, NSW 2060

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant

dates or reference numbers.

Step 2: Our response

We will:

Verify your identity before processing your request
Investigate thoroughly (for complaints) or process your request (for rights)
Respond to you in writing within reasonable timeframes and as required by law
Explain what actions we will take and keep you updated on progress
Not charge you for making a request (except for reasonable access fees if applicable)
Help you understand and exercise your rights

Step 3: If you're not satisfied (complaints only)

If you're not satisfied with our response to your complaint, you can:

Ask for a review by our senior management, or
Contact external bodies:
Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363
992, Website: www.oaic.gov.au)

This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.

Protecting your information

We use multiple layers of security to protect your information.

Technical safeguards

Enterprise-grade encryption for data storage and transmission
Regular security testing and monitoring
Automated threat detection systems

Operational security

Staff training on security and privacy
Strict access controls based on job requirements
Regular security audits and incident response procedures testing

Physical security

Secure premises with controlled access
Secure disposal of physical documents
Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as

comments or reviews) can be accessed and used by others. We cannot control or protect

information that you make publicly available.

How long we keep your information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it.

Cookies and Analytics

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to

improve your experience and our services.

Cookies

Small text files stored on your device
Help remember your preferences
Enable certain website functions
Make your interactions with our website more efficient

Tracking Pixels

Tiny, invisible images in web pages and emails
Help us understand how you interact with our content
Allow us to measure email engagement
Enable more relevant content delivery

How we use these technologies

Essential Functions

Remember your login status
Maintain your session security
Store your preferences
Enable core website features

Analytics and Performance

Understand how our website is used
Measure page views and traffic
Analyse user navigation patterns
Identify areas for improvement

Personalisation

Remember your preferences
Tailor content to your interests
Improve your browsing experience
Provide relevant recommendations

Your control

You can manage these technologies by:

Adjusting your browser settings to block or delete cookies
Using privacy-focused browser extensions
Configuring your email client to block images
Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience.

Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that

collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta advertising tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to

show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and

services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

Conduct analysis and data processing
Generate and prioritise leads from website and marketing activity data
Generate and modify content and coding
Improve and optimise our services and operations
Automate routine tasks and communications
Personalise your experience with our services
Support quality assurance processes
Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in

accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal

information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

We'll inform you when AI is used to make decisions that may significantly affect you
We maintain human oversight and review of significant AI-generated decisions
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

Amendments

We may update this policy at any time by posting the revised version on our website. We

recommend that you review our website regularly to stay current with any policy changes.

APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (together, the European Data Protection Laws), individuals located in the EU and UK have additional rights which apply to their personal information. Personal information under these Data Protection Laws is often referred to as personal data and is defined as information relating to an identified or identifiable natural person. This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as the lawful basis on how we process the personal information of individuals located in the EU and UK.

Legal bases for processing personal information

European Data Protection Law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases.

Consent - You have clearly agreed to us using your personal data for a specific purpose.
Performance of a contract - We need to use your information to fulfil a contract with you, or
because you've asked us to do something before entering into a contract.
Legal duty - We must use your information to comply with the law.
Vital interests - We need to use your information to protect someone's life.
Public interest - We need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis.
Legitimate interests - We have a genuine business reason to use your information, or a third party does, but only if this doesn't unfairly override your rights and interests. Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. These assessments
consider:
o The nature of our legitimate interest
o The impact on you
o Any safeguards we can implement
o Your reasonable expectations
o The broader context of our relationship

Note that we may process your personal data for more than one legal basis depending on the

specific purpose for which we are using your data. We have listed the reasons we process your data and the legal basis below. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data.

The full purposes of processing are set out in the policy above under “Why we collect, hold, use and disclose personal information” and the legal basis for this processing is set out below

Purpose: Business operations