PRIVACY POLICY
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Club Sticky
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Last updated: July 20261. INTRODUCTION
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Club Sticky (Vacation Group Pty Ltd T/A Club Sticky, ABN 35 688 592 323) ("we," "us," "our," or "Club Sticky") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and otherwise handle your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).This Privacy Policy applies to:Clients who engage us for marketing and content services
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Website visitors
Individuals who contact us
Influencers and content creators we work with
Any other person whose information we collect
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Please read this Privacy Policy carefully. If you do not agree with our privacy practices, please do not use our services or website.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect personal information only when it is reasonably necessary to provide our services or conduct our business. This may include:Information You Provide Directly
Contact Information: Your name, email address, phone number, company name, job title, and business addressAccount Information: Login credentials, payment details, and banking information for invoicing and payment processingBusiness Information: Details about your business, brand, products, services, and marketing goalsCommunication Records: Emails, messages, meeting notes, and feedback you provide to usClient Content: Photos, videos, captions, hashtags, and other content you provide for us to publish on your behalfSensitive Information: We do not intentionally collect sensitive information (such as health information, racial or ethnic origin, political opinions, etc.) unless you voluntarily provide it and consent to its use.Information Collected Automatically
Website Usage: We may collect information about how you interact with our website, including pages visited, time spent, and links clicked (via cookies and similar technologies)Device Information: Your device type, operating system, browser type, IP address, and referring websiteSocial Media Data: When managing your social media accounts, we may have access to Instagram analytics, engagement data, and audience insightsLocation Information: General location data (city/region) based on IP address, not GPS trackingInformation from Third Parties
Service Providers: We may receive information from payment processors, cloud storage providers, and other third-party tools we use to deliver servicesSocial Media Platforms: Instagram and other platforms may provide analytics, account data, and performance metricsInfluencers & Partners: Information about content creators, collaborators, or partners we work with

3. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information for the following purposes:Service Delivery: To provide marketing, content creation, social media management, and related services as outlined in our agreement with you
Communication: To respond to your inquiries, send invoices, provide updates, and communicate about our services
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Payment Processing: To process payments, manage billing, and maintain financial records
Account Management: To manage your account, access, and service delivery
Reporting & Analytics: To create performance reports, analytics, and insights about your campaigns and audience
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Compliance: To comply with legal obligations, including tax, accounting, and regulatory requirements
Improvement: To improve our services, website functionality, and user experience
Marketing: With your consent, to send you information about our services, updates, and promotional offers (you can opt out at any time)
Legal Purposes: To establish, exercise, or defend legal claims; prevent fraud; and enforce our agreements
Safety & Security: To protect the security and integrity of our systems, services, and customer data
We will not use your personal information for purposes other than those disclosed in this Privacy Policy without obtaining your prior consent.

4. IMPORTANT: CLIENT DATA VS. AGENCY DATA
Your Personal Information (as a Client)
If you are a client of Club Sticky, your personal information (name, business address, contact details, payment information, etc.) is handled in accordance with this Privacy Policy and our Professional Services Agreement.Your Business Data (Content & Accounts)
When you engage Club Sticky to manage your social media accounts or create content:Account Access: You grant us administrative or editor access to your Instagram accounts and other platforms for service delivery purposes onlyContent Ownership: All content, photos, videos, and materials you provide to us remain your property. We manage and publish this content on your behalfAnalytics & Performance Data: We collect and use Instagram analytics, engagement metrics, and audience data to create reports and optimize your campaignsThird-Party Access: Instagram and other platforms may collect additional data about your account and audience; this is governed by their respective privacy policies, not oursPost-Service Access: When our engagement ends, you must change all passwords and remove our access. We do not retain ongoing access to your accounts or data unless you request it

5. WHO DO WE SHARE YOUR INFORMATION WITH?
We may disclose your personal information in the following circumstances:Service Providers
We may share information with third parties who assist us in delivering services, including:Cloud storage and project management tools (Google Drive, Monday, Asana, Canva)
Payment processors and accounting software
Email and communication platforms
Website hosting and analytics providers
Social media management tools
All service providers are bound by confidentiality obligations and must handle your information securely.Social Media Platforms
When we manage your Instagram and other social media accounts, those platforms have access to your account data, content, and audience information in accordance with their Terms of Service and Privacy Policies.Legal Requirements
We may disclose your information if required to do so by law, court order, government agency, or regulatory authority.Business Transfers
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If Club Sticky is acquired, merges with another business, or sells assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.Consent
We will not share your personal information with third parties for purposes other than those listed above without obtaining your prior consent.

6. HOW DO WE PROTECT YOUR INFORMATION?
We implement a range of security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:Secure Access: Password-protected accounts and multi-factor authentication where available
Encryption: Secure HTTPS connections for website and data transmission
Cloud Security: Use of reputable, secure cloud storage providers with encryption
Limited Access: Only authorized personnel can access client data; access is on a need-to-know basis
Data Retention: We retain personal information only as long as necessary to provide services or comply with legal obligations
Physical Security: Secure office facilities with restricted access
However, no method of transmission over the Internet or electronic storage is 100% secure. While we use reasonable security measures, we cannot guarantee absolute security. You acknowledge the risks associated with transmitting information and use our services at your own risk.7. YOUR PRIVACY

RIGHTS & CHOICES
Access Your Information
You have the right to request access to the personal information we hold about you. To request access, contact us using the details below.Correct Your Information
If your personal information is inaccurate, incomplete, or out-of-date, you can request that we correct it. Please notify us of any changes.Delete Your Information
You may request deletion of your personal information, subject to:Legal obligations to retain the information
The need to retain information for service delivery or dispute resolution
Our legitimate business interests
We will not delete information that is reasonably necessary to provide services or protect legal rights.Opt Out of Marketing
You can opt out of receiving marketing emails and promotional communications at any time by clicking the "unsubscribe" link in any email or by contacting us directly.Privacy Preferences
You can control what information you share with us. However, refusing to provide necessary information may prevent us from providing services.

8. COOKIES & WEBSITE TECHNOLOGY
Cookies
Our website may use cookies (small text files stored on your device) to:Remember login information and preferences
Track website usage and improve functionality
Analyze visitor behavior and website performance
Enable social media features
You can control cookies through your browser settings. Disabling cookies may affect website functionality.Analytics & Tracking
We may use analytics tools (such as Google Analytics) to understand how visitors use our website. These tools collect information about pages visited, time spent, and user behavior. This information is not personally identifiable unless you provide it.Third-Party Services
Our website may contain links to third-party websites and services. We are not responsible for their privacy practices. Please review their privacy policies separately.9. INTERNATIONAL DATA TRANSFERS
Club Sticky is based in Australia and stores personal information in Australia. If we transfer your information to other countries (such as for cloud storage or service providers), we will take steps to ensure that your information is protected in accordance with this Privacy Policy and Australian Privacy Laws.10.

CHILDREN'S PRIVACY
Our services are not directed to children under 13 years of age. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information and terminate the child's account.

11. HOW LONG DO WE KEEP YOUR INFORMATION?
We retain personal information for as long as:Necessary to provide services and fulfill the purposes outlined in this Privacy Policy
Required by law or regulation
Necessary to establish, exercise, or defend legal claims
After the end of our service engagement, we typically retain client information for:7 years for accounting and tax purposes
Longer if required by law or for legal dispute resolution
We will securely delete or de-identify information when it is no longer needed, unless legal obligations require us to retain it.

12. PRIVACY COMPLAINTS & DISPUTES
If you believe we have breached the Australian Privacy Principles or this Privacy Policy, you may lodge a complaint with us.To Make a Complaint
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Please contact us with details of your complaint (see contact information below). We will acknowledge your complaint within 5 business days and investigate within 30 days.External Resolution
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):Office of the Australian Information Commissioner
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Website: www.oaic.gov.au

13. UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date.Your continued use of our services after changes are posted constitutes your acceptance of the updated Privacy Policy.

14. CONTACT US
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If you have questions about this Privacy Policy, wish to access or correct your information, or would like to lodge a complaint, please contact us:

Club Sticky
Vacation Group Pty Ltd T/A Club Sticky
ABN 35 688 592 323
Address:
165 Stirling Highway
Nedlands, Western Australia 6009
Email:
taryn@clubsticky.com.au

15. DEFINITIONS
Australian Privacy Principles (APPs): The privacy standards set out in the Privacy Act 1988 (Cth) that apply to how we collect, use, and disclose personal information.Personal Information: Information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether it is recorded in a material form or not.Sensitive Information: Information about an individual's racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, membership in professional or trade associations, political party membership, sexual orientation or practices, criminal record, and health information.De-identified Information: Information that cannot be linked to a specific individual, either directly or indirectly.

END OF PRIVACY POLICY
This Privacy Policy is effective from July 2026 and applies to all personal information collected by Club Sticky from that date forward.