Privacy Policy

Last updated: 1 July 2025

Clear First Pty Ltd (ABN 94 702 665 969) (“Clear First”, “we”, “us” or “our”) is committed to protecting the privacy and confidentiality of the personal information we hold. This Privacy Policy explains how we collect, use, store and disclose personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1. Who we are

Clear First Pty Ltd is an Australian company based in Melbourne VIC, providing professional business and consulting services. You can contact us about this policy or any privacy matter at ceo@clearfirst.online.

2. The Australian Privacy Principles

The APPs set out standards, rights and obligations around the collection, use, disclosure and handling of personal information. We comply with the APPs and, where applicable, the practices they prescribe for the handling of personal information, including:

• APP 1 – open and transparent management of personal information (including this policy);
• APP 2 – anonymity and pseudonymity where practical;
• APP 3 – collection of solicited personal information;
• APP 4 – dealing with unsolicited personal information;
• APP 5 – notification of the collection of personal information;
• APP 6 – use or disclosure of personal information;
• APP 7 – direct marketing;
• APP 8 – cross-border disclosure of personal information;
• APP 9 – adoption, use or disclosure of government related identifiers;
• APP 10 – quality of personal information;
• APP 11 – security of personal information;
• APP 12 – access to personal information; and
• APP 13 – correction of personal information.

3. Personal information we collect

The types of personal information we may collect include:

• your name, job title and employer or business name;
• your email address and other contact details you provide to us;
• information contained in enquiries, quote requests and correspondence you send us;
• information relevant to the professional business and consulting services we provide to you or your organisation; and
• website usage information collected through cookies and analytics tools.

We do not collect sensitive information (such as health, racial, political or religious information) unless it is reasonably necessary for our functions and you have consented, or the collection is otherwise permitted by law.

4. How we collect personal information

We generally collect personal information directly from you, for example when you:

• submit an enquiry or quote request through our website forms;
• email us at ceo@clearfirst.online;
• engage us to provide consulting services; or
• interact with our website, including through cookies and analytics.

In some circumstances we may collect information about you from third parties, such as your colleagues, referees or publicly available sources, where it is unreasonable or impracticable to obtain it from you directly.

5. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information where it is reasonably necessary for:

• providing professional business and consulting services to you or your organisation;
• responding to enquiries and preparing quotes;
• managing our client relationships, billing and records;
• improving our website, services and communications; and
• complying with our legal and regulatory obligations.

We will not use or disclose your personal information for a purpose other than the primary purpose of collection unless you have consented, you would reasonably expect the use or disclosure, or it is permitted or required by law.

6. Direct marketing

We may use your contact details to send you information about our services that we believe may be relevant to you. Every direct marketing communication will include a simple way to opt out, and you may ask us at any time, by emailing ceo@clearfirst.online, not to receive further marketing communications. We will act on your request promptly and free of charge.

7. Disclosure of personal information

We may disclose personal information to:

• service providers who assist us with hosting, email, analytics, accounting, administrative or professional services;
• professional advisers such as accountants, auditors and lawyers where reasonably required;
• government bodies, regulators or law enforcement agencies where required or authorised by law; and
• other parties where you have consented to the disclosure.

We do not sell or rent personal information to third parties.

8. Overseas disclosure

Some of our service providers, including cloud hosting, email and software providers, may store or process information outside Australia. Where personal information is disclosed overseas, we take reasonable steps to ensure the recipient does not breach the APPs, including through contractual arrangements, or we ensure the disclosure is otherwise permitted under the Privacy Act.

9. Quality and security of personal information

We take reasonable steps to ensure the personal information we collect is accurate, up to date and complete, and to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. Measures we use include access controls, secure storage, and limiting access to personnel who need the information to perform their duties. When personal information is no longer required for a permitted purpose, we take reasonable steps to destroy or de-identify it, subject to any legal retention requirements.

10. Access and correction

You may request access to the personal information we hold about you, and request corrections if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, please email ceo@clearfirst.online. We will respond within a reasonable period. In some circumstances we may decline a request, for example where giving access would be unlawful or would prejudice the privacy of others; if so, we will explain our reasons and provide details of how you may complain.

11. Cookies and website analytics

Our website may use cookies and similar technologies to understand how visitors use the site and to improve its performance. Cookies are small files stored on your device. You can usually adjust your browser settings to refuse cookies, although some parts of the website may not function correctly as a result. Analytics data is generally aggregated and is not used to identify individual visitors.

12. Anonymity and pseudonymity

Where it is lawful and practicable, you have the option of dealing with us anonymously or using a pseudonym, for example when making a general enquiry. However, we generally need your name and contact details to provide quotes, respond to enquiries and deliver our services.

13. Notifiable data breaches

If we become aware of, or suspect, an eligible data breach affecting personal information we hold, we will assess the incident promptly. Where the breach is likely to result in serious harm to affected individuals, we will notify those individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.

14. Privacy complaints

If you have a complaint about how we have handled your personal information, please contact us at ceo@clearfirst.online with the details of your concern. We will acknowledge your complaint and aim to resolve it within a reasonable time. If you are not satisfied with our response, you may lodge a complaint with the OAIC via its website at www.oaic.gov.au.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services or legal obligations. The current version will always be published on this page, together with the date of the last update.

16. Contact us

For any questions about this Privacy Policy or our handling of personal information, please contact:

Clear First Pty Ltd
ABN 94 702 665 969
Melbourne VIC, Australia
Email: ceo@clearfirst.online

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