Privacy policy

LumiLogic Media is a business name of Reece Capital Pty Ltd ACN 688 020 608 ATF Reece Legacy Portfolio Trust ABN 82 273 879 607.

References to "we", "our", "us" and "LumiLogic Media" mean Reece Capital Pty Ltd (ACN 688 020 608) as trustee for the Reece Legacy Portfolio Trust (ABN 82 273 879 607), trading as LumiLogic Media, and its officers, employees and agents.

LumiLogic Media recognises the importance of protecting the personal information we collect. We handle personal information in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth). [Wording depends on the coverage decision in the draft notes.]

This Privacy Policy explains how we collect, hold, use and disclose personal information that we collect from you, or that you or our clients provide to us. Please read it carefully. By giving us personal information, you acknowledge that you have read this Privacy Policy.

1. Collection of personal information

We collect personal information that is reasonably necessary to provide our digital marketing services (paid search and social advertising, search engine optimisation, websites and landing pages, content, email marketing and lead generation), and to run our business. Depending on how you deal with us, this may include:

• your name, job title, business name and ABN;
• contact details, including email address, phone number and business address;
• the content of enquiries, emails, messages and meeting notes;
• billing and payment details needed to invoice and receive payment (we do not store full card numbers);
• access details for accounts you ask us to manage, such as ad accounts, analytics, website and CRM platforms, granted through those platforms' own permission settings;
• information about how you use our website and respond to our emails and ads (see section 6);
• if you apply to work with us, your application details and referee information.

If you are a client, we may also collect:

• brand assets, product and pricing information, and creative such as images, video and copy you supply;
• campaign and performance data from your advertising, analytics, search console, social media, e-commerce and CRM accounts, such as spend, clicks, conversions and lead records;
• photos, video, quotes or testimonials of you or your staff, only with written consent for that use.

We collect most information directly from you, for example when you complete a form on our website or landing pages, submit a lead form inside a social media or search ad, download a guide, subscribe to our emails, book a meeting, message us on social media, email or call us, or engage us. We may also collect information from publicly available sources such as business directories and company websites, from people who refer you to us, and from our partners and service providers.

We do not ask for sensitive information (such as health information, racial or ethnic origin, or political or religious views). If you choose to give it to us, we will handle it only with your consent and only as needed for the purpose you gave it.

You can deal with us anonymously or using a pseudonym where that is practical, for example when making a general enquiry. We will need your name and contact details to provide our services. If you do not give us information we ask for, we may not be able to respond to you or act for you.

2. Holding of personal information

We hold personal information electronically in cloud-based systems run by our service providers, including our customer relationship management system, accounting software, email and document storage. Access is limited to people who need it to do their work, and is protected by passwords and multi-factor authentication. See section 7 for where those systems are hosted.

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, change or disclosure. No system is completely secure, so we cannot guarantee that unauthorised access or disclosure will never occur. If a data breach is likely to cause you serious harm, we will tell you and, where required, the Office of the Australian Information Commissioner (OAIC).

3. Retention of personal information

We keep personal information only for as long as we need it for the purposes in this policy, or as long as the law requires. Records we must keep for tax purposes, such as invoices and payment records, are generally kept for five years. When we no longer need information, we take reasonable steps to destroy it or de-identify it.

4. Use and disclosure of personal information

We use personal information to respond to enquiries; plan, run, optimise and report on campaigns; build and test websites and landing pages; manage client accounts; invoice and receive payment; market our own services; and meet our legal obligations.

We may disclose personal information:

• to service providers who help us run our business, such as hosting, CRM, accounting, email, payment, analytics and advertising platforms, and contractors working on client projects;
• to our professional advisers, such as accountants, lawyers and insurers;
• to the advertising and technology platforms we operate on your behalf, as part of the services you engage us for;
• where we are required or authorised by law, or to protect the rights, property or safety of LumiLogic Media, our clients or others;
• with your consent.

Direct marketing. We may send you emails or text messages about our services, insights and events. We send commercial messages only with your consent, express or inferred from our business relationship, as the Spam Act 2003 (Cth) requires. Every message identifies LumiLogic Media and includes a free unsubscribe option, and we action unsubscribe requests within 5 working days. You can also opt out at any time by contacting us. We may show our ads to people who have visited our website (see section 6). We do not buy email lists and we do not sell personal information.

Case studies and testimonials. We publish client results, names, logos or testimonials only with the client's written consent, and only real results.

We also use personal information in the computer programs and artificial intelligence tools described in section 9. The providers of those tools process it only to provide the service to us, under terms that restrict how they use it.

5. Information we handle for our clients

When we run marketing for a client, we may handle personal information about that client's customers and leads, for example enquiry form submissions, CRM records, email lists and custom advertising audiences.

We handle that information on our client's behalf and only to deliver the services they engaged us for. Our client decides why the information is collected and is responsible for telling its customers how it is used. We do not use one client's customer information for another client or for our own marketing, and we do not use it in case studies or public material. Where we share customer lists with advertising platforms (for example to build matched audiences), we use the platform's hashing or encryption features where they are available.

Common ways we handle this information for clients:

• Lead capture. Running forms on client websites and landing pages, and lead forms inside Meta, LinkedIn and Google ads, then passing those leads to the client's CRM or inbox.
• Audiences. Uploading customer lists to ad platforms to build custom, lookalike and exclusion audiences. Platforms match the hashed list against their users and then discard unmatched records, under their own terms.
• Conversion tracking. Setting up website tags and server-side or offline conversion uploads (such as the Meta Conversions API and Google Ads enhanced conversions) so platforms can measure which ads produced a lead or sale.
• Email and SMS campaigns. Sending campaigns to a client's own subscriber list, using the consent the client holds.
• Reporting. Analysing campaign and website data to report results to the client, usually in aggregate.

The client owns its ad accounts, analytics and customer data, and grants us access through each platform's own user permissions. When an engagement ends, we remove our access and return or delete client customer data we hold, unless the law requires us to keep it.

If you are a customer of one of our clients and have a question about your information, please contact that business first. You can also contact us using the details in section 11.

6. Cookies, website analytics and advertising

When you visit our website, we and our service providers use cookies and similar technologies (such as pixels, tags and local storage) to make the site work, understand how it is used, and measure and improve our marketing. These may collect your device and browser type, IP address, approximate location, the pages you view, the links and buttons you use, the website or ad that referred you, and cookie or advertising identifiers.

We use the following third-party tools: [confirm against the live site's tags before publishing]

• Google Analytics and Google Ads (Google LLC): to measure website traffic and performance, and the effectiveness of our advertising, including conversion tracking and remarketing.
• Meta Pixel (Meta Platforms, Inc.): to measure our advertising on Facebook and Instagram, and to show relevant ads to people who have visited our website.
• [CRM provider]: to run our enquiry forms and manage our customer relationships. [State where its data is hosted.]

We may also use: [confirm each before publishing; delete any not used]

• LinkedIn Insight Tag (LinkedIn Corporation): to measure and retarget our LinkedIn advertising.
• Session recording and heatmap tools (such as Microsoft Clarity or Hotjar): to see how visitors scroll and click so we can improve page layouts. These tools are set to mask what you type into forms.
• Call tracking: to work out which ad or page led to a phone call. Calls to tracked numbers may be recorded, and you will be told at the start of the call.
• A/B testing tools: to compare versions of a page or ad.

When we run campaigns for clients, the same kinds of tools are placed on our clients' websites. Those clients' own privacy policies govern that tracking.

You can control cookies through your browser settings. You can opt out of interest-based advertising with Google (Google Ads Settings and the Google Analytics Opt-out Browser Add-on) and Meta (your Facebook and Instagram ad preferences). Each provider handles data under its own privacy policy.

7. Overseas disclosure

Where practical, we hold personal information in Australia. Some of our service providers, including providers of website hosting, analytics, advertising, artificial intelligence, meeting transcription, email and document storage, are global businesses. Personal information may be processed or stored outside Australia by those providers or their sub-processors, including in the United States. Some providers also use artificial intelligence within their own products in ways we do not control.

Before we disclose personal information to an overseas provider, we take reasonable steps to make sure it is handled consistently with the Australian Privacy Principles, including through contract terms and by sharing only what the service needs.

8. Access, correction and deletion

Access. You can ask for access to the personal information we hold about you by emailing [email]. We will respond within a reasonable time, usually 30 days, and provide access in the way you ask where that is reasonable and practicable. We may charge a reasonable fee for providing access, and will tell you the fee before we proceed. If we refuse access on a ground the law allows, we will tell you why in writing and how to complain.

Correction. You can ask us to correct the personal information we hold about you by emailing [email]. We will take reasonable steps to make sure it is accurate, up to date, complete, relevant and not misleading. If we previously disclosed it to another organisation, you can ask us to tell that organisation, and we will do so unless it is impracticable or unlawful. If we refuse to correct it, you can ask us to attach a statement that you believe the information is inaccurate, out of date, incomplete, irrelevant or misleading.

Deletion. You can ask us to delete your personal information by emailing [email] with the subject "Data Deletion Request", your full name, email address and a description of the information. We may need to verify your identity first. We will respond within 30 days and either confirm deletion or explain why we cannot, for example where the law requires us to keep a record.

9. Decisions made using computer programs and artificial intelligence

We use computer programs, including rules-based software and artificial intelligence tools, to help us run our business. This section explains what personal information those programs use and what decisions they are involved in. [Confirm against the APP 1.7 assessment before publishing.]

9.1 Kinds of personal information used by these programs

• your name, business name, job title and contact details;
• the content of your enquiry, emails, messages and meeting notes or transcripts;
• information about your business, such as industry, location, size, budget and marketing goals;
• how you interact with our website, landing pages, emails and ads, including clicks, form submissions, conversions and cookie or advertising identifiers;
• for our clients' customers and leads, the information our client provides to us or that their campaigns collect (see section 5).

9.2 Decisions made solely by computer programs

At present, no decision about you that could significantly affect your rights or interests is made solely by a computer program. A person at LumiLogic Media makes every decision described in 9.3.

9.3 Decisions where a computer program does something substantially and directly related to the decision

A person at LumiLogic Media makes these decisions, but a computer program may produce information, a score or a recommendation that is a key part of how the decision is made:

• how we prioritise and respond to an enquiry, where software qualifies or scores leads;
• whether we take on a new client, or continue to act for a client;
• for our clients' campaigns, which audiences are targeted, which people see an ad, and which leads are passed to the client, where advertising platforms' automated bidding and targeting, and CRM rules, segment, score or route people.

9.4 Artificial intelligence tools

We use generative artificial intelligence tools to help write ad copy, emails, web and social content, generate creative concepts, research keywords and audiences, analyse campaign performance, summarise information, transcribe and summarise meetings, and assist with software and website development. The tools we use include [confirm: Anthropic Claude, OpenAI ChatGPT, Google Gemini, Microsoft Copilot, Fireflies]. Advertising platforms and other providers also use artificial intelligence within their products. We do not allow these tools to make a decision about you on their own. A person reviews the output before it is relied on. We limit the personal information we enter into these tools to what the task needs, and we keep a register of each tool, what it is used for and the provider's terms. Information entered into these tools may be processed outside Australia (see section 7).

9.5 Asking about a decision

You can ask us how a decision about you was made, what information was used, and ask us to review it, using the details in section 11. We will tell you the outcome of a review in writing.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The current version is always on our website, with the date it was last updated. If a change materially affects how we handle your information, we will tell you.

11. Questions and complaints

If you have a question, want to make a request, or wish to complain about how we have handled your personal information, contact us:

• Email: [email]@lumilogicmedia.com
• Phone: [phone]
• Mail: [postal address]

We will acknowledge your complaint, investigate it within a reasonable time (usually 30 days), and tell you the outcome in writing.

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

Last updated: [date of publication].