Snapshot 138327
Normalized text
Scripts and page chrome removed; this is what change detection compares.
Privacy Policy October 1, 2026 Think Grow Pty Ltd (ABN 34 605 404 448) and each of its related group companies, including but not limited to Think & Grow (UK) Ltd (Company Number 10554839) (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our website, in person, or through other means. It applies to each member of the Group, and a reference to "we", "us" or "our" is a reference to the member of the Group that handles your personal information. Last updated: 2 October 2026 Our website may contain links to third-party sites and services. Those sites and services have their own privacy policies, and we encourage you to review them. We have no control over, and cannot accept responsibility or liability for, the content or privacy practices of any third-party sites or services. This policy does not apply to your activities on any third-party site after you leave our website. For individuals located in the European Economic Area (EEA), United Kingdom or Switzerland: additional rights and protections apply to you under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (UK GDPR). Please refer to Appendix 1 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with GDPR and UK GDPR requirements. For individuals located in California, United States: additional rights apply to you under the California Consumer Privacy Act (CCPA) and California Civil Code Section 1798.83. Please refer to Appendix 2 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with these laws. Quick overview We collect information you provide to us and information we gather when we interact with you We use this information to provide our services and improve your experience We protect your information using secure systems and processes You have rights regarding your personal information, including access and correction rights Information we collect Identity and contact details Name, date of birth, address, email address and phone number Professional details Social media profile Service related information Payment and transaction details for products and services you have purchased from us, or enquiries about our products and services Your preferences for our services and your marketing preferences Feedback and survey responses Digital information IP address and general location information derived from your IP address Search and browsing behaviour Website usage patterns Cookie preferences Device type and operating system Unique device identifiers Device settings Professional information (for job applicants and workers) Employment history Professional experience Required authorisations and licences Professional registrations Information about your right to work in the relevant jurisdiction Sensitive information We handle sensitive information with extra care and protection, and we only collect this information with your consent or when legally permitted. This includes: Racial or ethnic origin Biometric information We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorised by law. How we collect personal information Directly from you when you: interact with us, contact us, or fill out forms. Automatically when you: visit our website, use our technologies, or interact with our online services. From third parties: service providers, business partners, public sources, government organisations, and organisations or people authorised by you. From publicly available sources: such as ASIC and other regulatory bodies, and professional networking sites such as LinkedIn. From members of our Group: other members of our Group, where necessary for the purposes set out in this policy. Why we collect, hold, use and disclose personal information We collect and use your personal information to run our business and provide our services as set out below. Business operations To manage our relationship with you as a customer or supplier To process and deliver our products and services To handle your enquiries, support requests, and communications To maintain accurate records for billing and administration Client onboarding and verification To assess whether to take you on as a new client or provide services to you, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks when required or permitted by law To retain records of verification checks as required by law Communication and support To respond to your questions and support requests To communicate important updates about our services To handle enquiries made through our website or platforms To manage your participation in surveys, feedback sessions, or events Service improvement To conduct analytics and market research To improve our business operations and services To develop and enhance our applications and platforms To understand how our services are used Marketing and promotions To send you promotional information about our services and events To inform you about products or services that may interest you To manage your marketing preferences To run competitions, promotions, and special offers To provide additional benefits to our customers Employment purposes To assess employment applications To evaluate candidate qualifications To manage professional certifications and licences To maintain employment records Legal and compliance To comply with our legal obligations To respond to court orders or legal processes To maintain required business records To fulfil regulatory requirements or reporting obligations To protect our legal rights and interests, or as authorised by law Combining information To combine information you provide to us, and information we collect automatically, with general information or research data we receive from other trusted sources To combine data and insights from our marketing and market research activities with information about how visitors use our website, to improve our website and your experience of it Group operations To share information between members of our Group (in accordance with applicable laws) so that we can manage our relationship with you, provide our services and operate our website To manage and administer our Group's business, including for internal reporting, compliance and risk management Our disclosures of personal information to third parties We may disclose personal information to: Service providers IT service providers Data storage providers Web hosting and server providers Payment processors Marketing and advertising providers (Google AdSense, HubSpot Inc.) Analytics providers (Google Analytics) Identity verification and compliance screening service providers Recruitment and applicant-tracking providers (RecruitCRM) Professional advisers Bankers Auditors Insurers and insurance brokers Legal advisers Business partners Our existing or potential agents Our business partners or contractors Our parent, subsidiary or affiliated companies, including but not limited to members of our Group Our employees, contractors and related entities, where necessary for them to perform their roles Corporate transactions If we merge with or are acquired by another company, or sell our business assets: Your information may be disclosed to our advisers Your information may be disclosed to the potential purchaser's advisers Your information may be included in the transferred assets Legal and regulatory bodies Courts and tribunals Regulatory authorities, including as required for reporting obligations Law enforcement officers Credit reporting agencies, in the event you fail to pay for goods or services we have provided to you Other parties Third parties you have authorised Emergency services when necessary Any other parties as required or permitted by law Overseas disclosure Storage and access We are a global business and some of our Group may be based outside of Australia or the United Kingdom. We may store your personal information in Australia and the United Kingdom. However, your information may be accessed from or transferred to locations outside Australia or the United Kingdom, including the United States, Germany and Singapore, in these circumstances: When our service providers are located overseas When we work with overseas business partners When using cloud-based services or data storage solutions When personal information is shared between members of our Group Our approach to overseas disclosure Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law, by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards, and by monitoring how recipients handle your information. Your privacy rights and choices Providing information You can choose whether to provide personal information to us. However, if you do not provide certain information, we may not be able to provide some services. Let us know if you do not want to provide information and we will let you know when information is required versus optional. Access to your information You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access. If we cannot provide access, we will explain why and explore alternative ways to share relevant information. Correction rights You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading, and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction. Deletion of your information If you ask us to delete your account, we will delete your personal information within 60 days of the deletion of your account, except where we are required or entitled to retain it for legal, regulatory or legitimate business reasons. Marketing communications You can opt out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable. Notification of data breaches We will comply with all laws applicable to us in respect of any data breach, including notifying affected individuals and relevant regulators where required by law. Non-discrimination We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service (for example, providing user support), we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services because you have exercised your privacy rights. How to contact us about your rights or to make a complaint Step 1: Contact our privacy officer Email: humans@thinkandgrowinc.com Post: Level 3, 88 Jolimont Street, East Melbourne, VIC 3002, Australia What to include: your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers. Step 2: Our response We will: Verify your identity before processing your request Investigate thoroughly (for complaints) or process your request (for rights) Respond to you in writing within reasonable timeframes and as required by law Explain what actions we will take and keep you updated on progress Not charge you for making a request (except for reasonable access fees if applicable) Help you understand and exercise your rights Step 3: If you are not satisfied (complaints only) If you are not satisfied with our response to your complaint, you can ask for a review by our senior management, or contact external bodies: Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au) UK residents: Information Commissioner's Office (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, helpline: 0303 123 1113, Website: ico.org.uk/make-a-complaint) You do not have to contact us first before going to the ICO, but we would appreciate the opportunity to try to resolve your concerns directly with you. This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices. Children's privacy We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information from children under 13. Protecting your information We use multiple layers of security to protect your information. Technical safeguards Enterprise-grade encryption for data storage and transmission Regular security testing and monitoring Automated threat detection systems Operational security Staff training on security and privacy Strict access controls based on job requirements Regular security audits and incident response procedure testing Physical security Secure premises with controlled access Secure disposal of physical documents Equipment security protocols Public information Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available. How long we keep your information We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it. Cookies and analytics What we use We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services. Cookies Cookies are small text files stored on your device that help us recognise your browser, remember your preferences, and make your interactions with our website more efficient. We use the following categories of cookies: Essential cookies: crucial to your experience of our website, enabling core features such as logins, account management and payment processing. Performance cookies: track how you use our website during your visit, helping us understand usage patterns and diagnose problems. This information is typically anonymous and aggregated. Functionality cookies: collect information about your device and settings (such as language and time zone) so we can provide customised content. Targeting and advertising cookies: help determine what promotional content is relevant to you, and may be used to deliver targeted advertising and measure the effectiveness of our campaigns. Tracking pixels Tiny, invisible images in web pages and emails Help us understand how you interact with our content Allow us to measure email engagement Enable more relevant content delivery Your control You can manage these technologies by: Adjusting your browser settings to block or delete cookies Using privacy-focused browser extensions Configuring your email client to block images Using our cookie preference settings Note: blocking all cookies may affect website functionality and your user experience. Google Analytics We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages. Meta advertising tools We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences. Google AdSense and HubSpot We use Google AdSense to display advertisements on our website, and HubSpot Inc. to manage our marketing communications and customer relationship data. These tools may use cookies to collect information about your browsing activity. Use of location services data We collect your approximate location, derived from your IP address, when you visit our website, for the following purposes: To understand where our users are located, for analytics and market research purposes To improve our website and services To detect and prevent fraud As permitted by law We collect this information automatically when you visit our website. If you do not want us to collect this information, you can adjust your browser or device settings to limit location sharing. Artificial intelligence (AI) technologies Overview We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business. How we use AI We may use AI technologies to: Conduct analysis and data processing Generate and modify content and coding Improve and optimise our services and operations Automate routine tasks and communications Personalise your experience with our services Support quality assurance processes Assist with customer support and queries Data protection and security When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards. Your rights and our commitments Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to: Transparency and control We will inform you when AI is used to make decisions that may significantly affect you We maintain human oversight and review of significant AI-generated decisions Our staff are trained to understand AI limitations and verify outputs before relying on them We implement processes to verify the accuracy of AI-generated outputs Security We use appropriate technical and organisational measures to maintain the security and integrity of your personal information We regularly test and monitor AI outputs for accuracy and reliability Risk mitigation We regularly assess and document risks associated with using AI to process personal information We implement appropriate measures to address these risks We continuously monitor AI performance and regularly review their impact Amendments We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes. Appendix 1: Additional rights and information for individuals located in the EU or UK Under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (together, the European Data Protection Laws), individuals located in the EU and UK have additional rights which apply to their personal information. Personal information under these Data Protection Laws is often referred to as personal data and is defined as information relating to an identified or identifiable natural person. This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as the lawful basis on how we process the personal information of individuals located in the EU and UK. The GDPR distinguishes between organisations that process personal information for their own purposes (data controllers) and organisations that process personal information on behalf of other organisations (data processors). We, Think Grow Pty Ltd, are a data controller and, in some circumstances, a data processor, with respect to the personal information you provide to us. Legal bases for processing personal information European Data Protection Law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases. Consent - you have clearly agreed to us using your personal data for a specific purpose. Performance of a contract - we need to use your information to fulfil a contract with you, or because you have asked us to do something before entering into a contract. Legal duty - we must use your information to comply with the law. Vital interests - we need to use your information to protect someone's life. Public interest - we need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis. Legitimate interests - we have a genuine business reason to use your information, or a third party does, but only if this does not unfairly override your rights and interests. Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. These assessments consider the nature of our legitimate interest, the impact on you, any safeguards we can implement, your reasonable expectations, and the broader context of our relationship. Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. We have listed the reasons we process your data and the legal basis below. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data. The full purposes of processing are set out in the policy above under "Why we collect, hold, use and disclose personal information" and the legal basis for this processing is set out below. Purpose: Business operations. Legal basis: performance of a contract; legal duty (for billing and record-keeping requirements); legitimate interests. Types of information we use: identity and contact details; service related information; digital information. Purpose: Client onboarding and verification. Legal basis: performance of a contract; legal duty; public interest; legitimate interests. Types of information we use: identity and contact details; financial information. Purpose: Communication and support. Legal basis: legitimate interests. Types of information we use: identity and contact details; digital information. Purpose: Service improvement. Legal basis: legitimate interests. Types of information we use: digital information. Purpose: Marketing and promotions. Legal basis: legitimate interests. Types of information we use: identity and contact details; digital information. Purpose: Employment purposes. Legal basis: legitimate interests; legal duty; consent; performance of a contract. Types of information we use: identity and contact details; professional data. Purpose: Legal and compliance. Legal basis: legal duty. Types of information we use: all relevant personal information. Overseas transfers Your information may be transferred to locations outside the EU or United Kingdom in these circumstances: When required as part of providing our services When our service providers are located overseas When we work with overseas business partners When using cloud-based services or data storage solutions When required by law or legal proceedings When we share personal data between members of our Group, including where personal data is transferred from the United Kingdom to Australia Our approach to overseas transfers When we transfer your personal data outside the EU or United Kingdom, we ensure it receives appropriate protection by: Only transferring your information to countries that European Data Protection Laws recognise as providing adequate protection for personal information, Putting in place a contract with the third party that means they must protect personal data to the same standards as the EU or UK, or Transferring personal data to organisations that are part of specific agreements on cross-border data transfers with the EU or UK. Data retention How long we keep your information We only keep your personal data for as long as we need it to: Provide our services to you Meet our legal, tax, accounting or regulatory obligations Handle any complaints or legal issues that may arise We may keep your information for longer periods if: You make a complaint that we need to investigate or respond to We reasonably believe legal action involving our relationship with you might occur The law requires us to keep it for specific timeframes How we decide retention periods When determining how long to keep your information, we consider: How much information we have and how sensitive it is The risk of harm if the information was accessed without permission Whether we can achieve our purposes in other ways What legal, regulatory, tax or accounting rules require The nature of our relationship with you and the services we provide What happens when we no longer need your information Once we no longer need your personal data, we will securely delete or destroy it in accordance with our data retention policies and legal requirements. You can request information about retention periods for your data and ask for early deletion where legally possible. Rights in relation to personal data In addition to the rights you have in our policy above, you also have the below rights. Right to erasure. You can request deletion of your personal data in certain limited circumstances as set out in European Data Protection Law, such as where the data is no longer necessary or has been unlawfully processed. This right is not absolute and we may be required or entitled to retain your data for legal, regulatory or legitimate business reasons. Right to restrict processing. You can ask us to suspend processing where: You contest the accuracy of the data Processing is unlawful but you do not want erasure We no longer need the data but you need it for legal claims You have objected to processing pending verification of our legitimate grounds Right to data portability. Where technically feasible, you can receive your personal data in a structured, commonly used format or have it transmitted to another controller where: Processing is based on consent or contract Processing is automated Right to object. You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds. Right to withdraw consent. Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing. Contact details for GDPR matters We have appointed a Head of Privacy for you to contact if you have any questions or concerns regarding your privacy, or our policies or practices in relation to GDPR. For any questions about how we process your personal information under GDPR, please contact our Head of Privacy at humans@thinkandgrowinc.com. Appendix 2: Additional disclosures for California Consumer Privacy Act (CCPA) compliance (US) This Appendix 2 applies to individuals who are California residents. Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organisations for their marketing purposes. To make such a request, please contact us using the details provided in this privacy policy with "Request for California privacy information" in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code. Do not track Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "Do Not Track" signals. We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently and with legitimate, legal reasons for doing so. CCPA-permitted financial incentives In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. California notice of collection In the past 12 months, we have collected the following categories of personal information: Identifiers, such as name, email address, phone number, account name, IP address, and an ID or number assigned to your account Demographics, such as age or gender. This category includes data that may qualify as protected classifications under other California or federal laws. Internet activity, such as your interactions with our services Geolocation data Employment and education data, such as data you provide when applying for a job with us Inferences, such as information about your interests, preferences and favourites We collect and use these categories of personal information for the business purposes described in this policy, including to provide and manage our services. Right to know and delete If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us: The categories of personal information we have collected about you The categories of sources from which the personal information was collected The categories of personal information about you we disclosed for a business purpose or sold The categories of third parties to whom the personal information was disclosed for a business purpose or sold The business or commercial purpose for collecting or selling the personal information The specific pieces of personal information we have collected about you To exercise any of these rights, please contact us using the details provided in this privacy policy. Shine the Light If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California's "Shine the Light" law, with third parties and affiliates for their own direct marketing purposes. To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code. To exercise any of these rights, please contact us at humans@thinkandgrowinc.com. Appendix 3: Privacy collection notice Where this notice applies This Privacy Collection Notice forms part of our Privacy Policy. It is displayed with our enquiry, contact and permission forms, and describes how Think Grow Pty Ltd (ABN 34 605 404 448) (we, us or our) collects and handles your personal information in those situations. Privacy collection notice This Privacy Collection Notice describes how Think Grow Pty Ltd (ABN 34 605 404 448) (we, us or our) collects and handles your personal information when you make an enquiry with us, when you give us permission to contact you, or when a member of our team records permission that you have given. We collect personal information from you, and from our own team members recording a conversation they have had with you, so that we can respond to your enquiry or follow up on what you asked for, and for related purposes set out in our Privacy Policy. We may disclose this personal information to third parties, including our personnel, related entities, any third parties engaged by us and acting on our behalf, and as otherwise set out in our Privacy Policy. We store personal information in Australia and the United Kingdom. Your information may be accessed from or transferred to locations outside Australia or the United Kingdom, including the United States, Germany and Singapore, where our service providers, business partners or cloud-based services are located, or when personal information is shared between members of our Group. If you do not provide your personal information to us, it may affect our ability to do business with you. You can unsubscribe from our emails at any time using the link included in every message, or by contacting us. Please see our Privacy Policy for more information about how we collect, store, use and disclose your personal information, including details about overseas disclosure, access, correction, how you can make a privacy-related complaint and our complaint-handling process. If you have questions about our privacy practices, please contact us by email at humans@thinkandgrowinc.com. By providing your personal information to us, or by a member of our team recording permission that you have given, you agree to the collection, use, storage and disclosure of that information as described in this Privacy Collection Notice. Table of contents ...