Privacy Policy

1 INTRODUCTION

(a) This Privacy Policy explains how Angela Elizabeth Ann Norris trading as Clarity Intelligence, ABN 47 534 306 924 (Clarity Intelligence, we, us or our), collects, holds, uses, discloses and protects personal information in connection with our website at clarityintelligence.com.au (Website), the Clarity Intelligence Platform (Platform) and our related products and services.

(b) Clarity Intelligence provides a cloud-based business software platform incorporating artificial intelligence (AI) tools to assist businesses with sales, marketing, content creation, reporting and operational activities. In providing these services, we may collect personal information directly from individuals and process personal information made available by our business customers through the Platform, including information relating to their employees, customers, prospective customers and other contacts.

(c) We are committed to protecting personal information and handling it responsibly, in accordance with applicable Australian privacy laws. This Privacy Policy explains the types of personal information we collect, how we collect and use it, the circumstances in which it may be disclosed to third-party service providers, including providers located outside Australia, and how individuals may request access, correction or deletion of their information or raise privacy concerns.

(d) This Privacy Policy should be read together with our SaaS Terms and Conditions, where applicable. By using our Website or Platform, you acknowledge that your personal information may be handled as described in this Privacy Policy. Where consent is required by law, we will seek that consent separately or through an appropriate consent mechanism.

(e) We may update this Privacy Policy from time to time by publishing a revised version on our Website. Where changes materially affect how we handle personal information, we will take reasonable steps to notify affected individuals where appropriate. The updated Privacy Policy will take effect from the date specified in the revised version.

(f) If you have any questions or concerns about how we handle personal information, please contact us at privacy@clarityintelligence.com.au.

2 TYPES OF PERSONAL INFORMATION WE COLLECT

(a) The types of personal information we collect and process depend on how you interact with our Website, Platform and Services and may include:

  (i) name, email address, telephone number, business address and other contact details;

  (ii) business name, position, role, industry and other information relating to your business or professional activities;

  (iii) Account registration details, usernames, authentication information, user roles and access permissions;

  (iv) billing details, subscription information, transaction records and payment-related information processed through our payment provider;

  (v) information contained in business profiles, documents, prompts, instructions, communications and other materials uploaded or provided through the Platform;

  (vi) information relating to employees, customers, prospective customers and other contacts supplied by our business customers or accessed through authorised integrations;

  (vii) information obtained from connected third-party services, including customer relationship management systems, email accounts, calendars, document storage services, social media accounts and advertising platforms;

  (viii) AI-generated content and associated information, including draft communications, reports, images, videos and other outputs that may contain personal information;

  (ix) technical and usage information, including IP addresses, device and browser information, session identifiers, activity records, error logs and information about how the Platform is accessed and used; and

  (x) information provided when you contact us, request support, respond to surveys or otherwise communicate with us.

(b) Payment information is processed through Stripe or another authorised payment provider. We do not ordinarily receive or store complete payment card details.

(c) We do not require sensitive information for ordinary Account registration. However, information provided by business customers through the Platform or connected services may include sensitive information. You should only provide such information where necessary and where you have the appropriate lawful authority to do so.

3 PERSONAL INFORMATION OF MINORS

(a) The Platform is intended for business use, and individuals registering an Account must be at least 18 years old.

(b) Our Services are not specifically directed towards children. However, we may process personal information relating to individuals under 18 where that information is lawfully provided by a business customer through Client Data or authorised third-party integrations.

(c) Business customers are responsible for ensuring that they have the necessary lawful authority to collect and provide personal information relating to minors, including obtaining any required parental or guardian consent.

(d) Where we become aware that personal information relating to a minor has been collected or processed inappropriately, we will take reasonable steps to address the issue in accordance with applicable law.

(e) Parents or guardians may contact us at privacy@clarityintelligence.com.au with any concerns or requests relating to personal information about a minor.

4 HOW WE COLLECT PERSONAL INFORMATION

(a) We may collect personal information directly from you, from our business customers or through third-party services where:

  (i) you visit or interact with our Website;

  (ii) you register for an Account, commence a free trial or purchase a Subscription;

  (iii) you are invited to access the Platform as an Authorised User;

  (iv) you provide business information, documents, prompts, instructions or other content through the Platform;

  (v) you connect or authorise access to third-party accounts, applications or services;

  (vi) a business customer provides information about its employees, customers, prospective customers or other contacts through the Platform;

  (vii) you communicate with us by email, telephone, online forms, social media or other channels;

  (viii) you request technical support, make an enquiry or provide feedback; or

  (ix) you otherwise interact with our Platform or Services.

(b) We may also receive personal information through authorised integrations with third-party services, including GoHighLevel, Google Workspace, Microsoft 365, Meta, LinkedIn and Canva, depending on the services connected to your Account and the permissions granted. The Platform integrates with Gmail, Google Calendar and Google Drive. Clarity Intelligence’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including its Limited Use requirements.

(c) Where personal information is provided by a business customer, we generally process that information on the customer’s behalf to provide the Platform and its functionality, in accordance with the customer’s instructions, our SaaS Terms and Conditions and applicable law.

5 COOKIES AND SIMILAR TECHNOLOGIES

(a) Our Website and Platform may use cookies, browser local storage and similar technologies to support essential functionality, maintain sessions, improve security and understand how our services are used.

(b) The Platform uses its hosting provider’s built-in visitor analytics, including a session identifier stored in browser local storage. The Website is built using Framer and uses Framer’s built-in visitor analytics, which records page views, referring websites, country and device type. Neither the Platform nor the Website currently uses Google Analytics, advertising pixels or other separately installed third-party advertising tracking technologies.

(c) You can manage or disable cookies through your browser settings, although doing so may affect the functionality of certain services.

(d) If we introduce additional analytics, advertising or tracking technologies, we will update this Privacy Policy and implement any consent mechanisms required by applicable law.

6 USE OF YOUR PERSONAL INFORMATION

(a) We collect, use and process personal information where reasonably necessary to operate our Website, Platform and Services, including for the following purposes:

  (i) to register and administer Accounts, manage Authorised Users and provide access to the Platform;

  (ii) to provide AI-powered functionality, including processing prompts, business information, documents and other Client Data to generate AI Outputs;

  (iii) to enable integrations with authorised third-party services, including customer relationship management systems, email, calendars, document storage, social media and advertising platforms;

  (iv) to manage Subscriptions, process payments, administer AI credits and add-ons, and maintain billing and transaction records;

  (v) to communicate with you about your Account, provide technical support, respond to enquiries and send service-related notices;

  (vi) to maintain, monitor, secure and improve the Platform, investigate technical issues and prevent fraud, unauthorised access or misuse;

  (vii) to analyse Platform performance and usage, including through aggregated or de-identified information where appropriate;

  (viii) to comply with applicable laws, regulatory requirements and lawful requests, resolve disputes and enforce our agreements;

  (ix) to send information about our products, services and promotions where permitted by law; and

  (x) for other purposes disclosed to you at the time of collection or otherwise permitted by applicable law.

(b) Where we process personal information provided by a business customer, including information relating to its employees, customers, prospective customers or other contacts, we generally do so on the customer’s behalf to provide the functionality requested or authorised through the Platform.

(c) We do not use personal information contained in a business customer’s Client Data for our own direct marketing purposes. Information obtained through Meta and LinkedIn integrations is used only for customer-authorised functions, including publishing approved posts and creating advertising campaigns in a paused state. We do not sell that information, use it to advertise to individuals or combine it with another business’s data. We delete that information when the connected account is disconnected or the customer’s Account is deleted, subject to the retention and backup provisions of this Privacy Policy. You may also request deletion of that information by contacting privacy@clarityintelligence.com.au.

7 DIRECT MARKETING

(a) We may use contact information collected directly from you to send updates, promotional communications and information about our products and services where permitted under applicable law, including the Spam Act 2003 (Cth).

(b) You may opt out of receiving marketing communications at any time by using the unsubscribe facility provided or contacting us at privacy@clarityintelligence.com.au.

(c) Opting out of marketing communications will not prevent us from sending necessary Account, billing, security or service-related communications.

8 DISCLOSURE TO THIRD PARTIES AND OVERSEAS PROCESSING

(a) We may disclose or make personal information available to third-party service providers where reasonably necessary to operate the Platform and provide our Services.

(b) These providers may include:

  (i) Floot, which provides Platform development, hosting and associated infrastructure and AI functionality;

  (ii) Amazon Web Services and Neon, which provide cloud infrastructure and database services;

  (iii) AI processing providers accessed through Floot, including Fireworks AI, through which GLM models developed by Z.ai are operated, with Baseten used as a fallback, and OpenAI and Google, whose models are used for certain Platform functions;

  (iv) fal.ai, which provides image and video generation functionality;

  (v) Stripe, which processes payments and associated billing information;

  (vi) Amazon Simple Email Service and other authorised email delivery providers; and

  (vii) providers of Connected Services, including GoHighLevel, Google Workspace, Microsoft 365, Meta, LinkedIn and Canva, where integrations have been authorised by the relevant business customer.

(c) The Platform’s hosting and database infrastructure is located in the United States, including the AWS and Neon us-east-1 region. Personal information may also be processed by AI providers and other service providers located in the United States or other countries, depending on the services used and their processing arrangements.

(d) Floot has advised that its AI providers operate under commercial API terms that prohibit training on customer data; Fireworks AI and Baseten do not retain prompts or outputs, and their AI processing is not restricted to any particular country or region. OpenAI response storage is disabled, although OpenAI may retain abuse-monitoring logs for up to 30 days. Google’s Gemini image model operates through Google Vertex AI, which may cache inputs and outputs for up to 24 hours and may retain prompts for abuse monitoring for an unspecified period. We do not use Client Data to train AI models for other customers of the Platform and do not make absolute assurances regarding third-party data handling. fal.ai retains records of prompts and generated results for 30 days by default, and Clarity Intelligence has not changed this setting.

(e) All images and videos generated or uploaded through the Platform are stored in the Platform’s own storage using publicly accessible links. These links are not publicly listed or intended to be readily discoverable, but anyone who obtains the relevant link can access the associated media. Publicly accessible links are necessary to enable services such as Facebook, Instagram and LinkedIn to retrieve media for customer-authorised publishing. Documents uploaded to the Knowledge Space remain private and are not subject to this public-link arrangement.

(f) We take reasonable steps to assess and select service providers and implement appropriate safeguards for personal information, including measures required under applicable Australian privacy laws.

(g) We may also disclose personal information where required or authorised by law, to professional advisers where reasonably necessary, or with your consent.

(h) We do not sell personal information collected through the Platform.

9 AUTOMATED DECISION-MAKING

(a) The Platform uses AI and other automated technologies to process information, generate draft content, analyse business information, support authorised integrations and perform requested functions.

(b) These processes may involve personal information contained in prompts, documents, communications, business records and other Client Data.

(c) We may also use automated processes to support Account security, identify unusual activity, monitor technical performance and administer Platform functionality.

(d) The Platform operates on a human-in-the-loop basis. AI-generated content and proposed actions require review and approval by an Authorised User, followed by a separate human action before communications are sent, content is published or advertising activities are undertaken.

(e) We do not provide the Platform as an automated decision-making service for determining an individual’s eligibility for employment, credit, insurance or other similarly significant matters.

(f) Business customers remain responsible for decisions made using information or AI Outputs generated through the Platform.

(g) Where applicable law requires additional information about automated processes that make or substantially inform decisions significantly affecting individuals, we will provide that information and comply with any applicable rights concerning those decisions.

(h) You may contact us at privacy@clarityintelligence.com.au if you have concerns about automated processing of your personal information.

10 SECURITY

(a) We take reasonable technical and organisational measures to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure.

(b) These measures may include secure authentication, password hashing, encryption of stored access credentials, access controls, separation of customer data and security measures implemented through our cloud infrastructure and service providers.

(c) We restrict access to personal information to authorised personnel and service providers who reasonably require access for legitimate business purposes.

(d) You are responsible for maintaining the confidentiality of your Account credentials, managing Authorised User access and promptly notifying us of suspected unauthorised access or security incidents.

(e) Although we take reasonable steps to protect personal information, no internet-based system or method of electronic storage is completely secure, and we cannot guarantee absolute security.

(f) If a data breach occurs, we will investigate and respond to the incident and comply with applicable notification obligations.

11 RETENTION AND DELETION

(a) We retain personal information for as long as reasonably necessary to provide our Services, administer Accounts, comply with legal obligations, resolve disputes and fulfil legitimate business purposes.

(b) When a Subscription ends, we will delete or de-identify the associated Account data from active systems within 30 days, except where retention is required or permitted by applicable law or otherwise contemplated by our SaaS Terms and Conditions. Customer data is backed up daily, and those backup copies are retained for 30 days; the hosting platform separately maintains database recovery copies for 7 days. Copies remaining in backups after deletion from active systems will be deleted or overwritten within a further 30 days. Information processed by third-party service providers may be subject to their separate retention arrangements.

(c) Certain information, including billing, taxation and accounting records, may be retained for at least 5 years or any longer period required by applicable law.

(d) Where personal information is no longer required for a lawful purpose, we will take reasonable steps to delete or de-identify it in accordance with applicable legal requirements.

12 LINKS

(a) Our Website and Platform may contain links to third-party websites, applications and services that are not operated or controlled by us.

(b) We are not responsible for the privacy practices, content or security arrangements of those third parties.

(c) When you access a third-party website or service, its own privacy policy and terms may apply. We recommend reviewing those documents before providing personal information.

13 REQUESTING ACCESS, CORRECTION OR DELETION OF YOUR PERSONAL INFORMATION

(a) You may contact us to request access to personal information we hold about you or to request correction of information that is inaccurate, incomplete, misleading or out of date.

(b) You may also request deletion of your personal information where appropriate, subject to any applicable legal obligations or other lawful grounds for retaining the information.

(c) To make a request, please contact privacy@clarityintelligence.com.au and provide sufficient information for us to identify the relevant records. Without limiting an individual’s privacy access rights, an Account admin may download a copy of the business’s data and AI Outputs using the “Download my data” function on the Platform’s Billing page; uploaded files, images and videos are included in the export as links, and assistance with an export may be requested at hello@clarityintelligence.com.au.

(d) We may need to verify your identity before processing a request to protect personal information from unauthorised disclosure or alteration.

(e) We will acknowledge privacy requests within 5 days of receipt and respond within 30 days of receipt. Some requests may require additional time to investigate or complete, subject to applicable legal requirements, and we will keep you informed where appropriate.

(f) Where personal information is held or processed on behalf of a business customer, we may need to refer the request to that customer or coordinate with them to address it.

(g) In some circumstances, we may be unable to provide access to, correct or delete particular information, including where retention or restricted access is required or permitted by law. Where appropriate, we will explain the reason for our decision.

(h) We will comply with applicable legal requirements when responding to requests concerning personal information.

14 COMPLAINTS

(a) If you have a concern or complaint about how we collect, use, disclose, store or otherwise handle personal information, please contact us at privacy@clarityintelligence.com.au.

(b) Please provide sufficient details of your concern so that we can investigate and respond appropriately.

(c) We will acknowledge privacy complaints within 7 days of receipt and aim to investigate and resolve complaints within 30 days. Where additional time is required, we will keep you informed of our progress.

(d) If you are dissatisfied with our response, you may be entitled to lodge a complaint with the Office of the Australian Information Commissioner (OAIC), where the matter falls within its jurisdiction.

(e) Further information about privacy complaints is available from the OAIC at www.oaic.gov.au.

15 CONTACT US

For further information about this Privacy Policy, our privacy practices, or to request access, correction or deletion of personal information or make a privacy complaint, please contact us using the following details:

(a) Name: Angela Elizabeth Ann Norris trading as Clarity Intelligence

(b) ABN: 47 534 306 924

(c) Email: privacy@clarityintelligence.com.au

(d) Address: 17 Kurmond Street, Jamisontown NSW 2750, Australia

(e) Website: clarityintelligence.com.au

(f) Last updated: 10 November 2026