Privacy Policy
Last updated: 3 September 2026
1. Introduction
1.1 This Privacy Policy (“Policy”) is issued by Novo Digital Agency Pty Ltd (ABN 40 683 857 954) (“we”, “us”, “our”, “the Company”).
1.2 The Company is bound by the Australian Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) contained therein, and complies with these obligations regardless of any turnover-based exemption that may otherwise apply to the Company.
1.3 By accessing or using the Company’s website located at novodigitalagency.com.au (“Website”), submitting an enquiry, engaging with the Company’s proposal or client portal, or otherwise engaging with the Company, you (“you”, “your”) acknowledge that you have read, understood, and agree to the terms of this Policy.
1.4 If you do not agree to this Policy, you must not access or use the Website or provide personal information to the Company.
2. Definitions
In this Policy, unless the context otherwise requires:
“Automated Decision-Making” means the use of a computer program, system, or process (including artificial intelligence tools) to make a decision, or to do something that is substantially and directly related to making a decision, that could reasonably be expected to significantly affect your rights or interests.
“Personal Information” has the meaning given to it under the Privacy Act, and includes any information or opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not, and whether or not it is recorded in a material form.
“Sensitive Information” has the meaning given to it under the Privacy Act.
“Third-Party Service Provider” means any external platform, tool, or service provider engaged by the Company in connection with the operation of the Website, delivery of services, or business administration, as further described in clause 5.
3. Collection of personal information
3.1 Information provided directly
The Company collects Personal Information that you voluntarily provide when:
- submitting an enquiry through the Website contact form, including your name, email address, telephone number (if provided), business name, website URL (if provided), and the content of your enquiry;
- booking a discovery call or other appointment through the Company’s scheduling platform;
- corresponding with the Company by email, telephone, video call, or other means;
- engaging the Company to provide services, including through a proposal, engagement agreement, or client portal; or
- signing a proposal or agreement electronically through the Company’s proposal and e-signature platform, in which case the Company collects your name, email address, the document version signed, the date and time of signing, and the IP address from which the signature was made.
The Company will only collect Personal Information that is reasonably necessary for, or directly related to, one or more of its functions or activities.
3.2 Information collected automatically
When you access the Website, certain technical and behavioural information may be collected automatically through the use of Third-Party Service Providers, as set out in clause 5.
3.3 Information collected about prospective clients
The Company may collect business contact information (such as name, business email address, job title, and business name) about prospective clients from publicly available sources or through business data and prospecting platforms, for the purpose of identifying and contacting businesses that may benefit from the Company’s services. Where this occurs, the Company relies on the reasonable expectation that business contact information of this kind may be used for legitimate business-to-business outreach, and provides an unsubscribe or opt-out mechanism in any such communication.
3.4 Recorded meetings
Where the Company conducts a discovery call, strategy session, or other meeting by video conference, the meeting may be recorded and transcribed using a meeting intelligence platform, as set out in clause 5.2. You will be notified before or at the start of any recorded meeting.
3.5 Anonymity and pseudonymity
Where lawful and practicable, you may interact with the Company anonymously or by pseudonym. However, if you do not provide your Personal Information when requested, the Company may be unable to respond to your enquiry or provide its services.
4. Use of personal information
4.1 Primary purpose
The Company collects and uses Personal Information for the primary purpose for which it was collected, including:
- responding to enquiries and communicating with you regarding the Company’s services;
- assessing the suitability of the Company’s services for your requirements;
- providing and administering services engaged by you, including through the Company’s client and proposal portals;
- maintaining business records and fulfilling legal, regulatory, and accounting obligations;
- identifying and contacting prospective clients whose businesses may benefit from the Company’s services; and
- improving the Website and the Company’s service delivery.
4.2 Secondary purposes
The Company will not use or disclose Personal Information for a secondary purpose unless:
- you have consented to the use or disclosure;
- you would reasonably expect the Company to use or disclose the information for the secondary purpose and it is related (or, in the case of Sensitive Information, directly related) to the primary purpose; or
- the use or disclosure is required or authorised by or under an Australian law or a court or tribunal order.
4.3 Direct marketing
4.3.1 The Company may send direct marketing communications, including periodic newsletters and service updates, to clients and other individuals who have provided their contact details to the Company or otherwise consented to receive such communications.
4.3.2 Every direct marketing communication will include a functional means of opting out or unsubscribing. The Company will not send any further direct marketing communication to an individual who has opted out.
4.3.3 The Company’s direct marketing practices are conducted in accordance with both the Privacy Act and the Spam Act 2003 (Cth).
5. Disclosure of personal information to third parties
5.1 General
The Company does not sell, rent, trade, or otherwise transfer Personal Information to third parties for their own commercial purposes.
5.2 Third-Party Service Providers
The Company engages the following categories of Third-Party Service Provider in connection with the operation of the Website, delivery of services, and business administration. By using the Website or engaging the Company’s services, you acknowledge that certain information may be processed by these providers in accordance with their respective privacy policies:
Website analytics and behaviour tracking – Google Analytics and Microsoft Clarity are used to collect aggregated information about Website usage, including pages visited, session duration, device type, browser, approximate geographic region, and, in the case of Microsoft Clarity, session recordings and heatmaps. This information does not personally identify individual visitors.
Maps – Certain pages may incorporate a Google Maps embed. Interaction with the embedded map may result in information being collected by Google.
Scheduling – The Company uses a third-party scheduling platform to facilitate discovery call and appointment bookings. Any Personal Information provided in connection with a booking is processed by that platform in addition to this Policy.
Meeting intelligence – The Company uses a meeting intelligence platform to record, transcribe, and summarise video calls, including the use of AI-based transcription and summarisation. Recordings and transcripts may be retained by the Company for reference in delivering services.
Customer relationship management – The Company uses a CRM platform to record and manage contact and enquiry information for prospective and current clients.
Prospecting and business data enrichment – The Company uses a business data and prospecting platform to identify and obtain business contact information for prospective clients, as described in clause 3.3.
Email marketing – Where you have consented to receive direct marketing communications, your name and email address are held on an email marketing platform for that purpose.
Accounting and billing – The Company uses accounting and payment platforms to issue invoices and process payments, as further described in clause 6.
Business email hosting – The Company’s business email is hosted by a third-party email provider, which may store email content and metadata outside Australia.
Website hosting and infrastructure – The Website and client websites are hosted on infrastructure managed by the Company’s hosting and server management providers, and content delivery and security services are provided by a third-party network provider.
5.3 Other disclosures
The Company may also disclose Personal Information:
- where required or authorised to do so by law, a court order, or a regulatory authority;
- to the Company’s professional advisers (including legal, accounting, and compliance advisers) subject to obligations of confidentiality; or
- in connection with the sale, merger, or acquisition of the Company or its business, provided that the recipient agrees to handle Personal Information in accordance with the APPs.
6. Automated decision-making and use of artificial intelligence
6.1 The Company uses artificial intelligence tools, including large language models, to assist with tasks such as drafting content, preparing proposals and reports, conducting search engine optimisation analysis, and summarising meeting recordings.
6.2 The Company does not use Automated Decision-Making to make, or to substantially and directly contribute to, any decision that significantly affects your rights or interests, such as a decision to decline to provide services to you or to alter pricing or terms offered to you. Where artificial intelligence tools are used in the course of preparing a proposal, report, or communication, the output is reviewed by a person at the Company before it is relied upon or sent to you.
6.3 Where this Policy or the Company’s practices change such that Automated Decision-Making is used in a way that significantly affects your rights or interests, the Company will update this Policy to describe the kinds of Personal Information involved, the kinds of decisions affected, and how you may seek review of such a decision.
7. Payment information
7.1 The Company does not collect, process, or store payment card or financial account information directly.
7.2 Payments for services are facilitated through third-party accounting and payment processing platforms. Any financial information provided in connection with a payment is handled by the relevant third-party provider in accordance with their own privacy and security policies and, where applicable, payment card industry standards.
8. Cookies
8.1 The Website uses cookies (small text files placed on your device) to support website functionality and the analytics tools described in clause 5.2.
8.2 You may configure your web browser to refuse cookies or to notify you when cookies are being set. Please note that disabling cookies may affect the functionality of certain features of the Website.
8.3 The Company does not use cookies to collect Sensitive Information.
9. Data storage and security
9.1 The Website and client websites are hosted on server infrastructure located in Australia. Other business systems used by the Company, including email hosting, CRM, scheduling, meeting intelligence, and marketing platforms, may store information on servers located outside Australia, as described in clause 10.
9.2 The Company takes reasonable steps to protect Personal Information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including through the use of appropriate technical and organisational security measures.
9.3 Notwithstanding clause 9.2, the Company cannot guarantee the absolute security of information transmitted over the internet. Any transmission of Personal Information to the Company is made at your own risk.
9.4 Where Personal Information is no longer required for the purpose for which it was collected and no legal obligation requires its retention, the Company will take reasonable steps to destroy or de-identify the information.
10. Cross-border disclosure
10.1 A number of the Third-Party Service Providers described in clause 5.2 are based outside Australia, including in the United States and the European Union. By using the Website or engaging the Company’s services, you consent to the transfer of your information to recipients located overseas in connection with the services described in clause 5.2.
10.2 Where Personal Information is disclosed to an overseas recipient, the Company takes reasonable steps to ensure that the recipient handles that information in a manner consistent with the APPs, to the extent practicable.
11. Access and correction
11.1 You have the right to request access to Personal Information that the Company holds about you, and to request the correction of information that is inaccurate, out of date, incomplete, irrelevant, or misleading.
11.2 To make a request for access or correction, please contact the Company using the contact details set out in clause 13. The Company will respond within a reasonable time and, in any event, within 30 days of receipt of a valid request.
11.3 The Company may decline a request for access or correction in circumstances permitted under the Privacy Act, and will provide written reasons for any such refusal.
11.4 The Company does not charge a fee for making a request for access or correction, though reasonable administrative costs may apply in some circumstances.
12. Complaints
12.1 If you believe that the Company has breached its obligations under the Privacy Act or this Policy in relation to your Personal Information, you may lodge a complaint by contacting the Company using the details set out in clause 13.
12.2 The Company will acknowledge receipt of your complaint within 5 business days and will endeavour to resolve the complaint within 30 days. Where a complaint requires further investigation, the Company will notify you of the expected timeframe for resolution.
12.3 If you are not satisfied with the Company’s response, you may refer your complaint to the Office of the Australian Information Commissioner (“OAIC”) at:
Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001 oaic.gov.au 1300 363 992
13. Contact details
All privacy-related enquiries, access requests, correction requests, and complaints should be directed to:
14. Amendments to this Policy
14.1 The Company reserves the right to amend this Policy at any time. Any amendments will take effect upon publication of the updated Policy on the Website, with the “Last updated” date updated accordingly.
14.2 Your continued use of the Website following the publication of any amendment constitutes your acceptance of the amended Policy. The Company encourages you to review this Policy periodically.
15. Governing law
This Policy is governed by and construed in accordance with the laws of the State of Victoria, Australia. Any disputes arising in connection with this Policy are subject to the exclusive jurisdiction of the courts of Victoria.