1. Introduction
Purpose of this Policy
Commuserv (ABN 76 220 621 605) (“Commuserv”, “we”, “us” or “our”) is committed to protecting the privacy and security of the personal information we collect, hold, use and disclose. We recognise that the way we handle your personal information is fundamental to the trust you place in us.
This Privacy Policy explains how we manage personal information in accordance with the Privacy Act 1988 (Cth) (the “Privacy Act”) and the Australian Privacy Principles (APPs) contained in that Act. Where relevant, we also have regard to guidance issued by the Office of the Australian Information Commissioner (OAIC) and to our obligations under the Spam Act 2003 (Cth) in relation to electronic marketing.
This Policy applies to personal information we collect through our website, our marketing and customer relationship activities, our events and webinars, and our general dealings with customers, prospective customers, suppliers, contacts and other individuals. By providing us with your personal information, or by using our website and services, you agree to your personal information being handled as set out in this Policy.
Who We Are
Commuserv is an Australian business that provides [brief description of Commuserv’s business and services] to its customers. We are the entity responsible for the personal information handled in accordance with this Policy.
If you have any questions about this Policy or about how we handle your personal information, you can contact our Privacy Officer by email at hello@commuserv.com.au or by phone on (08) 8211 6000. Our full contact details are set out in Section 19 (Contact Us).
2. Personal Information We Collect
The types of personal information we collect depend on how you interact with us. “Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not it is recorded in a material form.
Information You Provide to Us
When you contact us, request information, register for an event or webinar, download our content, or otherwise engage with us, we may collect:
Information We Collect Automatically
When you visit our website or interact with our online content, we may automatically collect certain technical and usage information, including:
Information We Receive From Third Parties
In some circumstances we may receive personal information about you from third parties, including:
Where we receive personal information about you from a third party and it was not reasonable or practicable to collect it from you directly, we will take reasonable steps to ensure you are made aware of the matters set out in this Policy.
3. How We Collect Personal Information
Direct Collection
We collect most personal information directly from you when you interact with us, including through:
Automated Collection
We also collect information automatically through technologies used on our website, including:
Third-Party Collection
We may collect personal information through third-party platforms and partners that support our marketing, events and customer relationship activities, including:
4. Why We Collect and Use Personal Information
We collect, hold, use and disclose personal information for the purposes described below, and for related purposes that you would reasonably expect.
Service Delivery
Business Operations
Marketing and Communications
Website and User Experience
Where we require your consent to collect, use or disclose your personal information for a particular purpose, we will seek that consent. In other cases, we rely on the collection and use being reasonably necessary for our functions and activities, and consistent with the APPs.
5. HubSpot CRM and Marketing Automation
We use HubSpot as our customer relationship management (CRM) and marketing automation platform. HubSpot helps us manage our contacts, communications and marketing activities.
How HubSpot Is Used
Data Processed Through HubSpot
HubSpot processes this information on our behalf and in accordance with its own privacy and security obligations. Some of this information may be stored or processed outside Australia — see Section 11 (Overseas Disclosure and International Processing).
6. Website Analytics and Tracking Technologies
Our website uses cookies and similar tracking technologies to help it function, to understand how it is used, and to support our marketing. A cookie is a small text file placed on your device when you visit a website.
Cookies
Strictly Necessary Cookies
Analytics Cookies
Functional Cookies
Advertising Cookies
Cookie Preferences
You can manage your cookie preferences through the cookie settings available on our website and through your browser controls. Most browsers allow you to refuse or delete cookies. Please note that if you disable certain cookies, some parts of our website may not function as intended.
7. Google Analytics
We use Google Analytics, a web analytics service provided by Google, to help us understand how visitors use our website.
How We Use Google Analytics
Information Collected
Google Analytics collects this information using cookies and similar technologies. The information generated is processed by Google in accordance with its own privacy practices. You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on or by adjusting your cookie preferences.
8. Online Advertising
We use a number of advertising platforms to promote our business, measure the effectiveness of our campaigns, and reach relevant audiences. These platforms may use cookies and similar technologies, and may combine the information they collect with information they already hold.
Google Ads
Meta Ads (Facebook and Instagram)
LinkedIn Ads
Advertising Audiences
Our advertising activities may involve the creation and use of audiences, including:
You can manage many advertising preferences through the settings offered by Google, Meta and LinkedIn, and through your browser and device controls.
9. Direct Marketing
Marketing Communications
From time to time we may send you marketing communications that we believe may be of interest to you. These may include:
Marketing Consent
We send marketing communications where we have your consent to do so, or where we are otherwise permitted to under applicable law, such as where you have an existing business relationship with us and the communication relates to similar products or services. Every commercial electronic message we send will identify us as the sender and include a functional unsubscribe facility, consistent with the Spam Act 2003 (Cth).
Opt-Out Rights
You can opt out of receiving marketing communications from us at any time by using the unsubscribe link included in our emails, by updating your preferences, or by contacting our Privacy Officer. We will action your request within a reasonable period. Please note that even after you opt out of marketing, we may still send you non-marketing communications, such as those relating to a service you have requested or important service and security notices.
10. Disclosure of Personal Information
We do not sell your personal information. We may disclose your personal information in the circumstances described below, and always in accordance with the APPs.
Service Providers
We may disclose personal information to trusted service providers who help us operate our business, website and marketing, including:
We require our service providers to handle personal information consistently with this Policy and with their own applicable privacy and security obligations.
Business Transactions
If we are involved in a business transaction such as a merger, acquisition, sale of assets or corporate restructure, personal information may be disclosed to the parties involved and their advisers, subject to appropriate confidentiality arrangements.
Legal Requirements
We may disclose personal information where required or authorised by law, including to meet regulatory obligations, to comply with a court order or subpoena, or to respond to a lawful request from a law enforcement or government agency.
11. Overseas Disclosure and International Processing
International Service Providers
Some of the service providers we use store or process personal information outside Australia. This is primarily in the United States, where a number of our technology and marketing providers are based, and may include other countries in which those providers or their sub-processors operate data centres. The providers that may process personal information overseas include our CRM and marketing platform, analytics and advertising platforms, and cloud service providers referred to in this Policy.
Safeguards
Where we disclose personal information to overseas recipients, we take reasonable steps to protect that information, including:
By providing us with your personal information, you acknowledge that it may be disclosed to and processed by recipients located outside Australia as described above.
12. Security of Personal Information
Security Measures
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Our security measures include:
Security Limitations
While we take reasonable steps to protect your personal information, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we manage these risks on an ongoing basis and continually review our practices.
13. Data Retention
Retention Principles
We retain personal information only for as long as it is required. In determining how long to keep personal information, we consider:
When personal information is no longer required for any of these purposes, we take reasonable steps to destroy or de-identify it.
Disposal and De-Identification
We use secure destruction processes for personal information that is no longer needed, and we de-identify personal information where it is appropriate and practicable to do so.
14. Access and Correction
Access Requests
You have the right to request access to the personal information we hold about you. To make a request, please contact our Privacy Officer at hello@commuserv.com.au. We may need to verify your identity before providing access, and we will respond to your request within 30 days. In limited circumstances permitted by law we may decline access, in which case we will explain our reasons in writing.
Correction Requests
If you believe that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you can ask us to correct it. We will take reasonable steps to correct the information within 30 days. If we do not agree that a correction is required, we will let you know and explain why, and you may ask us to associate a statement with the information noting that you consider it inaccurate.
15. Privacy Complaints
Internal Complaints Process
If you have a concern or complaint about how we have handled your personal information, please contact our Privacy Officer at hello@commuserv.com.au or on (08) 8211 6000. We will acknowledge your complaint promptly, investigate it, and respond to you within 30 days. If we need more time to resolve your complaint, we will let you know and keep you informed of our progress.
External Review
If you are not satisfied with the way we have handled your complaint, you can contact the Office of the Australian Information Commissioner (OAIC):
16. Data Breaches
Managing Data Breaches
We maintain processes to identify, contain, assess and respond to data breaches. If we become aware of a suspected or actual data breach, we will:
Notifiable Data Breaches
Where a data breach is likely to result in serious harm to any individual whose personal information is involved, and we are unable to prevent that likely harm through remedial action, we will comply with our obligations under the Notifiable Data Breaches scheme in the Privacy Act. This may include notifying the affected individuals and the OAIC as required by law.
17. Third-Party Websites
External Links
Our website may contain links to third-party websites. These websites are operated independently and have their own privacy practices. We are not responsible for the content or privacy practices of third-party websites, and we encourage you to review their privacy policies before providing any personal information to them.
18. Changes to This Policy
Updates
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. When we make changes, we will publish the updated Policy on our website and update the effective date shown at the top of this document. We encourage you to review this Policy periodically. Your continued use of our website and services after any change indicates your acceptance of the updated Policy.
19. Contact Us
Privacy Contact
If you have any questions, requests or complaints regarding your personal information or this Policy, please contact:
General Enquiries
For general enquiries, please use the contact form on our website or contact us by email at hello@commuserv.com.au or by phone on (08) 8211 6000.
Effective date: 16 July 2026
