BWRM Pty Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information. We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers. This Personal Information is obtained in many ways including [interviews, correspondence, by telephone and facsimile, by email, via our website www.bwrm.com, from your website, from media and publications, from other publicly available sources, from cookies] and from third parties. We don’t guarantee website links or policy of authorised third parties. We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing. When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. Sensitive information will be used by us only:

• For the primary purpose for which it was obtained
• For a secondary purpose that is directly related to the primary purpose
• With your consent; or where required or authorised by law.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances, we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.

Who handles your information for us

We use service providers to run our business and our website. Those that handle your Personal Information for us do so only to provide their service to us, under agreements that require them to protect it. Advertising and analytics providers (Google, Meta, Microsoft) and embedded content also use what they collect under their own privacy policies. They are:

• Google: Google Workspace for our email, chat, calendars, video calls (with notes taken by Gemini) and documents; Google Cloud, which runs our website and holds its database and the files you send us in Australia (our server logs, which include connection addresses, are kept for 30 days); Google Business Profile for our members' business listings; Google Analytics and Google Ads, which measure how visitors use our website and respond to our advertising.
• Microsoft: Clarity, which records how visitors use our website.
• Meta (Facebook): the enquiry forms inside our Facebook advertising.
• HubSpot: an earlier copy of our contact records, and a few remaining membership and invoice emails with their unsubscribe links, until that account is closed.
• Typeform: earlier answers to our suitability quiz and personality test.
• Intercom: the support chat in our members' portal, and our earlier help centre.
• Atlassian (Jira): our members' production jobs; Zapier passes support replies to them.
• Stripe: card payments. Stripe holds your card details; we never see them.
• Xero: invoicing and accounting.
• DocuSign: agreements signed electronically.
• Resend: the emails our website sends, and replies to them.
• Anthropic: the assistant on our website and the writing help in our tools. What you type to the assistant is sent to Anthropic to generate a reply, and is not used to train its models.
• Discord: our members' community.
• Gelato and Canva: printed products and design templates our members order through us.
• Netlify: hosts our membership pricing tool and the connection that passes members' details and invoices to Xero.
• Elfsight: our Instagram feed, shown on our website and on members' pages.
• Embedded players, maps, fonts and code libraries (YouTube, Vimeo, OpenStreetMap, Apple Podcasts, Google Fonts, jsDelivr) receive your connection address when a page shows them.

Some of these providers hold information outside Australia, mainly in the United States and the European Union. Where they do, we rely on their contractual commitments and their own privacy policies, which are published on their websites.

How long we keep your information

• Conversations with the assistant on our website: 12 months. If you ask for a conversation to be passed to our team, it is kept with your enquiry.
• Enquiries and forms sent through our website, and the emails, notes, tasks, calls and meetings we record about you: 24 months, unless you are, or have been, a client or member, or asked our assistant about our services. A record filed on a business or a deal and not on a person is kept with that file.
• Records of the automated emails our website sent you: 24 months after each email, and the record of an email sequence 24 months after its last email, once it has ended, after which only the fact that it ran is kept; unless you are, or have been, a client or member.
• Your contact details, what you told us in forms and quizzes, and whether you opened or clicked our emails: until you ask us to remove them. Copies of enquiries sent to our team, and to the member who takes them, by email or Google Chat, stay there.
• Clients' and members' files, including agreements and invoices: at least 7 years, as the law requires.

After these periods the information is deleted by an automated daily process; backup copies are overwritten within 12 weeks. What HubSpot, Typeform and Intercom hold is not covered by these periods; it goes when we close those accounts. To ask for your information to be removed sooner, write to info@bwrm.com.au; we will do so unless the law requires us to keep it.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing. BWRM (IP) Pty Ltd will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information. In order to protect your Personal Information, we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at info@bwrm.com.au