Overview
Clout Marketing Pty Ltd (“we”, “us”, “our”) is committed to safeguarding your personal information. This policy reflects our obligations under the Privacy Act 1988 (Cth) and the significant reforms enacted through the Privacy and Other Legislation Amendment Act 2024, effective December 2024 onward.
Scope and Definitions
We handle “personal information”—including anything that identifies or reasonably relates to an individual, such as metadata or behavioural data—as expanded by the 2025 reforms.
Collection, Use & Consent
We collect only what’s necessary. Consent must be voluntary, informed, current, specific, unambiguous, and withdrawable. We ensure clear and prominent notice when collecting data from overseas, for automated decision‑making, or for high‑risk activities.
Transparency & Automated Decisions
Where automated systems inform meaningful decisions, we disclose their use clearly in this policy and obtain specific consent after explaining their impact.
Data Security & Privacy‑by‑Design
We implement both technical and organisational safeguards, such as encryption, documented governance, and staff training, to protect personal information. Privacy considerations are embedded into all systems and processes.
Data Breaches & Incident Response
We maintain a Data Breach Response Plan. For notifiable data breaches, we promptly notify both the affected individuals and the OAIC in line with the mandatory NDB scheme.
Statutory Tort & Enforcement
The Privacy Act now includes a statutory cause of action for serious invasions of privacy—including intrusion, misuse, or unauthorised disclosure of private information. Regulators can issue penalty notices and impose substantial fines for breaches.
Children’s Privacy Protections
We anticipate the introduction of a Children’s Online Privacy Code by end‑2025, establishing default high‑privacy settings for minors, stronger consent, and rights to data deletion at adulthood. We commit to relevant updates once enacted.
Overseas Data & Third‑Party Services
When using overseas service providers, we remain responsible for safeguarding data—even if processed offshore—through appropriate contractual controls.
Rights of Access, Correction & Deletion
Individuals may request access to, correction of, or deletion of their personal information. Once enacted, we will comply with extended rights—including potential data erasure upon turning 18 under the Children’s Code.
Privacy Impact Assessments (PIAs)
High‑risk data initiatives—including new automated systems—are preceded by Privacy Impact Assessments to identify and mitigate risks.
Contact & Accountability
We have assigned a Privacy Officer responsible for oversight. You can contact us with questions, complaints, or requests regarding your personal information. We aim to foster a privacy‑focused culture throughout our organisation.
Policy Updates
This Policy may change from time to time and is available on our website. If you have any queries or complaints about our Privacy Policy please contact us at: 32 Harrogate Street, West Leederville WA 6007 or email team@cloutmarketing.com.au.
