Privacy Policy

As a brand communication agency, Cluse & Co collects, holds and discloses personal information. We take privacy seriously and are committed to complying with the Australian Privacy Principles in the Privacy Act 1988 (Cth).

Why do we collect personal information?

We collect personal information to:

provide services to our clients
communicate with our clients and contacts
gain feedback about our services
inform our clients and contacts about business opportunities and industry developments
market our services and send invitations to our events
market our clients’ services and send invitations to our clients’ events
manage our employees and contractors
generally carry on our business

What personal information do we collect?

We limit personal information to a business or organisation name, the relevant individual’s name, gender and position (eg marketing manager) and phone and email contact details. Where relevant we may record an individual’s relationship with our existing contacts and business associates (our network) which could benefit the client or potential client.

How we collect personal information

We collect personal information directly from an individual when that individual meets with us (i.e. gives us a business card); communicates with us by letter, telephone, email or fax; subscribes to our publications; registers for or attends our events; or submits information through our websites, blogs or other social media outlets. Our websites and social media pages may use cookies and similar technologies, including through third parties, to analyse traffic.

We may also collect information about an individual from our clients, potential clients and their contacts and business associates and agents, from the individual’s employer and from publicly available records or a third party, eg a provider of an employment or other reference.

Anonymity and pseudonyms

Individuals have the right not to identify themselves, or to use a pseudonym when dealing with us. However, if we request personal information and it is not provided, we may not be able to provide services to or otherwise assist the relevant individual.

General use and disclosure

We use and disclose personal information for the primary purpose for which it was collected, related purposes and other purposes authorised by the Privacy Act. In general, we use and disclose personal information for the purposes set out above.

Use and disclosure for direct marketing

We will only use an individual’s personal information to market our services or to send invitations to our events where we give that individual an opportunity to request us not to use the information for such purposes. We will not use an individual’s personal information for such purposes if the individual requests us not to do so.

To whom do we disclose personal information?

We may disclose personal information:

to other persons in connection with the provision of our services, including our clients and their contractors and other advisers, and to contacts and business associates of our clients and their contractors and advisers
to our employees, contractors and advisers
to credit reporting and debt collection agencies
to anyone else whom the individual authorises us to disclose the information to
as otherwise authorised by the Privacy Act

Our contractors, auditors, insurers and legal and other professional advisers may access personal information where they need it to provide their services to us. They are required to keep it confidential and to protect it.

Disclosure to overseas recipients

Some of the service providers we use store or process information outside Australia. Where that happens, we take reasonable steps to ensure the information is protected in a way consistent with the Australian Privacy Principles.

Beyond those providers, we do not disclose personal information to overseas recipients without the consent of the individual concerned or as otherwise permitted by the Privacy Act.

Artificial intelligence

We use artificial intelligence (AI) tools in our business. Where personal information is involved:

We only use personal information with an AI tool where it is reasonably necessary for the purpose the information was collected for, or for a related purpose the individual would reasonably expect.
We do not use personal information to train AI models, and we do not allow our providers to use the information we submit to train theirs.
We do not use AI to make a decision that has a legal or similarly significant effect on an individual without human review.
Some AI providers store or process information outside Australia. Our approach to this is set out under “Disclosure to overseas recipients”.
Individuals may ask us whether AI tools were used in handling their personal information, and may ask us not to use AI tools in our dealings with them where that is practicable.

How do we keep personal information secure?

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. We require everyone we share personal information with to do the same.

Unless we are required by law to keep it, we de-identify or securely destroy personal information when it is no longer reasonably needed.

Integrity of personal information

We take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete and that the personal information we use or disclose is, having regard to the purpose of such use or disclosure, accurate, up to date, complete and relevant.

To that end, we encourage you to contact us to update or correct any personal information we hold about you.

Accessing your personal information

You may request access to personal information we hold about you. We may require you to verify your identity and to specify what information you require. We deal with all requests for access to personal information as required by the Privacy Act. We may charge a fee where we provide access and may refuse to provide access if the Privacy Act allows us to do so.

Correction of personal information

We take reasonable steps to correct all personal information we hold to ensure that, having regard to the purposes for which it is held, the information is accurate, up to date, complete, relevant and not misleading. You may request corrections to personal information we hold about you. We deal with all requests for correction to personal information as required by the Privacy Act. We may refuse to correct personal information if the Privacy Act allows us to do so.

Payment card data

Where our work for a client touches systems that handle payment card data, we support the client’s own obligations under the applicable card industry standards. Cluse & Co does not store, process or transmit payment card data itself.

Complaints

If you wish to make a complaint about this Privacy Policy or our collection, use or disclosure of personal information, please contact us in the first instance. We will investigate your complaint and try to promptly resolve your complaint directly with you.

If you are not satisfied with the outcome, then you may make a complaint to the Office of the Australian Information Commissioner (OAIC).

For information about how to make such a complaint, please refer to the OAIC website http://www.oaic.gov.au/.

Contact us

To request access to or correction of personal information, to request not to receive marketing material or invitations from us, to ask about our use of AI tools, or to make a privacy complaint to us, please contact:

Privacy Officer

Cluse & Co

26 Anderson Street

Thebarton, South Australia, 5031

Phone: +618 7085 1402

Email: info@cluseco.com.au

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time and without notice by publication on our website. We recommend that you regularly review our Privacy Policy to ensure you are aware of any changes.

This Privacy Policy was last updated in September 2026.