Privacy Policy

Social Target Pty Ltd trading as Pure Digital Agency (ABN 63 618 477 633) | Version 2.0 | Effective 01 August 2026

This policy explains how we collect, use, hold and disclose personal information, in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. It applies to our clients and their personnel, prospective clients, visitors to our websites, and individuals whose personal information we handle in delivering marketing, advertising, lead generation and AI services for our clients.

1 WHO WE ARE

Pure Digital Agency is a marketing and advertising agency based in Subiaco, Western Australia. We provide digital marketing, advertising management, lead generation, marketing automation and AI services to business clients. Contact: info@pureagency.com.au | 1300 366 379 | Unit 1 / 2 Centro Avenue, Subiaco WA 6008.

2 WHAT WE COLLECT

Clients and prospective clients: names, roles, business contact details, billing and payment details, and records of our communications and dealings.

Individuals who respond to campaigns we run for clients: when you submit an enquiry through an advertisement, form or landing page operated as part of a client’s campaign, we collect the information you provide, which typically includes your name, contact number, email address, postcode and your responses to enquiry questions. This information is collected for, and provided to, the client whose product or service you enquired about.

Website visitors and audiences: technical and usage data collected through cookies, pixels and similar technologies (including the Meta pixel and Google tags), such as device information, pages viewed and interactions, used for analytics, campaign measurement and remarketing.

AI system interactions: where you interact with a chatbot or AI voice agent we operate for a client, we collect the content of that interaction, which may include recordings and transcripts. Where calls are recorded, this is disclosed at the time in accordance with applicable law. Where a client’s campaign form expressly requests information that may be sensitive (for example eligibility or health-related details), it is collected with your consent through that form and handled in accordance with this policy.

3 HOW WE COLLECT IT

We collect personal information directly from you (forms, enquiries, email, phone, chat and voice interactions), through the advertising and social media platforms that operate campaign forms (such as Meta and Google), through our websites and analytics tools, and through the CRM and automation systems we operate for ourselves and our clients.

4 HOW WE USE IT

We use personal information to: deliver our services to clients, including delivering campaign enquiries (leads) to the client whose campaign you responded to; operate, personalise and measure advertising campaigns; operate chatbots, voice agents and marketing automation; manage client accounts, billing and payments; improve our services; comply with our legal obligations; establish, exercise and defend our legal rights, including recovering amounts owed to us; and communicate with you where you have asked us to or would reasonably expect us to. We may also use information in aggregated and de-identified forms to analyse, benchmark and improve our services. We do not sell personal information.

5 AI PROCESSING

We use artificial intelligence tools in delivering some services, including chatbots, voice agents, workflow automation and data analysis. Information you provide in these interactions, and data our clients ask us to analyse, may be processed by third-party AI platforms for the purpose of delivering the service. We do not use our clients’ confidential information to train AI models made available to others, and we do not knowingly permit AI providers to train their models on client data without permission.

6 WHO WE DISCLOSE TO

We disclose personal information to: the client on whose behalf a campaign, form, chatbot or voice agent was operated (enquiries you submit are provided to that client); our service providers, including advertising and social media platforms, hosting, CRM, analytics, automation, AI and telephony providers, and payment processors; our professional advisers and insurers; a purchaser or prospective purchaser of our business or its assets (under appropriate confidentiality obligations); debt collection agencies and commercial credit reporting bodies (such as CreditorWatch) in relation to unpaid business accounts; and otherwise where required or authorised by law.

7 OVERSEAS DISCLOSURE

Some of our service providers, including advertising platforms, cloud hosting and AI providers, store or process data outside Australia, including in the United States. Where personal information is disclosed overseas, we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles.

8 STORAGE, SECURITY AND RETENTION

We hold personal information in secure cloud systems with access controls, and take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. We retain personal information for as long as it is needed for the purposes described in this policy or as required by law, and take reasonable steps to destroy or de-identify it when it is no longer needed. We are subject to the Notifiable Data Breaches scheme and, in the event of an eligible data breach, will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

9 COOKIES AND REMARKETING

Our websites and client campaigns use cookies, pixels and similar technologies for analytics, measurement and remarketing. You can manage cookies through your browser settings, and manage ad preferences through the settings offered by platforms such as Meta and Google.

10 MARKETING COMMUNICATIONS

Where we send direct marketing, you can opt out at any time using the unsubscribe facility in the message or by contacting us. We comply with the Spam Act 2003 (Cth).

11 ACCESS, CORRECTION AND COMPLAINTS

You may request access to, or correction of, the personal information we hold about you by contacting us at the details above. We will respond within a reasonable period; we may charge a reasonable fee for giving access, and may decline a request where permitted by law (with reasons). Where practicable, you may deal with us anonymously or using a pseudonym, although this may limit the services we can provide. If you have a privacy complaint, contact us first and we will investigate and respond. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (oaic.gov.au).

12 CHANGES TO THIS POLICY

We may update this policy from time to time. The current version, with its effective date, is published at https://pureagency.com.au/legal/privacy-policy. Material changes will be notified on our website.