PRIVACY POLICY

Creative Folks Pty Ltd (ACN 004 252 466) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our system integration and content management services (Services) or when otherwise interacting with you.

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

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

• Identity Data including full name, title, date of birth, gender, company and job title.
• Contact Data including billing address, delivery address, email address and telephone numbers.
• Financial Data including payment details (through our third party payment processor, Stripe).
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data including internet protocol (IP) address, general location information derived from your IP address, your browser session data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, your engagement with our emails, including through the use of Internet cookies, tracking pixels and similar technologies and your communications with our website.
• Profile Data including purchases or orders you have made with us, support requests you have made, content you post, send receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.
• Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly: We collect personal information which you directly provide to us, including through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal data from publicly available resources such as professional networking sites such as LinkedIn.

Why we collect, hold, use and disclose personal information

We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Purpose of use / disclosure	Type of Personal Information
To provide our Services to you and enable you to access and use our platform, Siphon.	·   Identity Data ·   Contact Data
To contact and communicate with you about our Services [including in response to any support requests you lodge with us or other enquiries you make with us].	·   Identity Data ·   Contact Data ·   Profile Data
To contact and communicate with you about any enquiries you make with us via our website.	·   Identity Data ·   Contact Data
For internal record keeping, administrative, invoicing and billing purposes.	·   Identity Data ·   Contact Data ·   Financial Data ·   Transaction Data
For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms and to measure the performance of our emails and advertising.	·   Profile Data ·   Technical and usage Data
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.	·   Identity Data ·   Contact Data ·   Technical and usage Data ·   Profile Data ·   Marketing and communications Data
To offer additional benefits to you.	·   Identity Data ·   Contact Data ·   Profile Data ·   Interaction Data ·   Marketing and communications Data
If you have applied for employment with us; to consider your employment application.	·   Identity Data ·   Contact Data ·   Professional Data
To comply with our legal obligations or if otherwise required or authorised by law.

 

Our disclosures of personal information to third parties

We may disclose personal information to:

• our employees, contractors and/or related entities;
• IT service providers, cloud computing providers such as AWS, SAAS providers such as HubSpot and Accelo, data storage, web-hosting and server providers;
• marketing, analytics or advertising providers;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators such as Stripe;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred, including in the event of a merger, acquisition or sale of business assets, and including disclosure to our advisers, potential purchasers' advisers, and the inclusion of your information in any transferred assets;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

Storage and Access

While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.

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 rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. You can also ask us to add a statement to your information noting your requested correction.

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

Step 1: Contact our privacy officer

• Email: privacy@folks.com.au
• Phone: + 61 2 9516 2677
• Post: Suite 501, 83 Mount Street, North Sydney, NSW 2060, Australia

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
• 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 the 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 may use cookies, tracking pixels and similar technologies on our website and in our emails from time to time 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 may 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 may 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 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

Links to other websites

Our website may contain links to other parties’ websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at:

Creative Folks Pty Ltd (ACN 004 252 466)

Email: privacy@folks.com.au

Last update: 30 September 2026