Privacy Policy

Ivorey Pty Ltd ACN 682 606 702 t/a Ivorey of Happy Valley SA 5159 (“Ivorey”, “we”, “us” or “our”) is committed to providing quality services to you and to respecting your privacy.

This privacy policy sets out how we collect, use, process, store, share and disclose your Personal Information (as defined in section 1 below) from the operation of our website at https://ivorey.io/ (“Website”), our product, being a software platform comprising a comprehensive suite of marketing and sales tools designed to empower businesses to create, manage, and automate their customer interactions (“Platform”), our services, including support and solution enhancement and done-for-you services, where we may act on your behalf to configure, implement, or operate aspects of the Platform (each of the Website, Platform and services, together the “Services”) (“Privacy Policy”).

Please note that if you are an Ivorey customer, when you signed up for any of our Services, you agreed to our terms and conditions by entering into an agreement with Ivorey, which includes obligations in this Privacy Policy.

We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) and the General Data Protection Regulation (EU 2016/679) (the “GDPR”), and any other relevant laws pertaining to privacy of individuals in jurisdictions which our Services are available (collectively, “Privacy Laws”).

We are a data controller for the purposes of the GDPR, but in some circumstances may be a data processor. We ensure that we will take all necessary and reasonable steps to comply with the relevant Privacy Laws and to deal with inquiries or complaints from individuals about compliance with the relevant Privacy Laws.

By accessing and using our Services, you freely and expressly consent to the collection, use, processing, storage and disclosure of Personal Information by us as set out in this Privacy Policy.

1. Information collected by Ivorey

Personal information is any information relating, directly or indirectly, to an identified or identifiable natural person (“Personal Information”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

The type of Personal Information we collect from you includes, without limitation, the following:

Identification and Contact Details: your full name, mailing address, email address, telephone number(s), date of birth, gender, profession, role and place of work.

Billing Information: credit or debit card information using a third-party payment provider and your ABN.

Traffic Information: your device ID, device type, geo-location information, computer and connection information, screen resolution, site usage, session information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information

Product Information: details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries.

Provided Information: any additional information relating to you that you provide to us directly, or indirectly through use of our Services.

User Content: any information which you publicly post to Ivorey, or submit through interactive features of our Services, including reviews, comments or messages. This also includes any content you share with us via social media platforms when interacting with our pages, tagging us, or participating in campaigns or promotions.

Survey/Feedback Information: information you provide to us through customer surveys or requests for feedback. Biographical Information: information provided when you inquire about or apply for a position with Ivorey.

Done-For-You Services Information: information you provide to us in connection with our done-for-you services. This may include business or operational details, instructions, content, and any other data required for us to deliver those services on your behalf.

Other: any other Personal Information that may be required in order to facilitate your dealings with us.

2. How we collect your Personal Information

We will collect Personal Information only by lawful and fair means and never in an unreasonably intrusive way. Generally, we will collect your Personal Information:

directly from you, where you provide information to us or interact with us;

automatically in the course of using our Services; and

from our business partners or other third-party sources that provide consumer data, such as information about your interests, demographic information, and marketing details.

If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested.

We require individuals to provide accurate, up to date and complete Personal Information at the time it is collected.

3. We do not collect sensitive Personal Information

We will not collect sensitive Personal Information or special categories of Personal Information (as defined under the relevant Privacy Laws) from you. We ask that you do not send us, or do not disclose, any sensitive personally identifiable information (such as information related to racial or ethnic origin, sex life or sexual orientation, political opinions, religious or other beliefs, genetic or biometric data, health criminal background or trade union membership) on or through our Services.

If we do require special categories Personal Information, we will advise you of the purpose for our request and will require that you provide express consent to us collecting that information as part of you using our services.

4. Information about minors

Our Services are not intended for users under the age of 18. We acknowledge that the definition of a “minor” changes between jurisdictions, however, we do not knowingly seek or collect Personal Information from any children below the age of 18 years. Any Personal Information found to have been provided by a user under the age of 18 will be removed as soon as possible and we will cease the use of that Personal Information and deactivate any related account.

5. How your Personal Information is used

We use, process and disclose your Personal Information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):

providing our Services to you;

administering, protecting, improving or optimising our Services;

manage, operate and improve our Services and grow our business, including data analytics, conducting research for understanding our customer base and the effectiveness of our marketing, events, promotional campaigns, advertisements and publications, and diagnose or fix technology problems;

creating industry reports from de-identified data;

verifying your identity or age;

billing you for purchasing our products and service;

informing you about our Services, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us;

responding to any inquiries or comments that you submit to us;

access, recruit and hire staff;

perform any other function that we believe reasonable and necessary to protect the security or proper functioning of our Services;

any other purpose you have consented to; and

any use which is required or authorised by a relevant Privacy Law, including detecting, investigating and preventing conduct which may violate our policies, are fraudulent or illegal and protect the rights of Ivorey, you or others.

Where we:

have your express consent;

have a legal basis; or

are otherwise permitted by relevant Privacy Laws,

we may use and process your Personal Information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.

At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at [email protected].

6. Who we may need to disclose your Personal Information to

We may disclose your Personal Information to the following service providers:

Outsourcing Companies: third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes set out in section 5.

Software Providers: third-party service providers that supply enterprise-level software used to deliver our Platform. This includes HighLevel, Inc. which provides CRM, automation, and customer communication tools. HighLevel, Inc. may access or process your Personal Information for the purposes of operating and supporting the Platform, in accordance with its Security and Compliance Overview and Data Processing Agreement.

Analytics: as a part of providing you with, measuring and improving our Services, we may engage with analytics providers who collect information utilising tracking technologies on our Website and software to measure visits and traffic on our Website or servers which provide you the Services.

Related Bodies: we may share information with other entities in the Ivorey corporate group, for purposes consistent with this Privacy Policy.

Consented Parties: any person or entity to whom you have expressly consented to us disclosing your Personal Information to.

External Advisors: our external business advisors, auditors, lawyers, insurers and financiers.

Payment Providers: our payment processing service provider to enable billing transactions.

Legal: any person or entity to whom we are required or authorised to disclose your Personal Information to in accordance with the relevant Privacy Laws.

We will only disclose any Personal Information you have provided to any entity outside of Ivorey if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Privacy Policy, for example a third-party payment provider to process your payment (each entity outside of Ivorey, known as a “Service Provider”).

When entering into a transaction with us you expressly and freely consent to your Personal Information being disclosed or transferred to any of our Service Providers. We will take steps reasonably necessary to ensure your Personal Information is treated securely and in accordance with this Privacy Policy. We use reasonable endeavours to ensure that each Recipient receiving your Personal Information is bound by the relevant Privacy Laws (including the standard contractual clauses approved by the European Commission). The standard contractual clauses are available on the European Commission’s website at https://ec.europa.eu/info/law/law-topic/data-protection_en.

7.How we store and protect your Personal Information

We take all reasonably necessary measures to protect the information we collect through our Services which are stored electronically. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information.

However, we cannot guarantee the absolute security of any Personal Information transmitted over the internet and therefore you disclose information and Personal Information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your Personal Information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.

If we no longer need your Personal Information for any of the purposes set out in this Privacy Policy, or as otherwise required by the relevant Privacy Laws, we will take such steps as are reasonable in the circumstances to destroy your Personal Information or to de-identify it.

8.What is our legal basis?

Under the GDPR, we must have a legal basis to process Personal Information collected from individuals residing in the European Union. We rely on several legal bases to process your Personal Information, including:

where it is necessary to provide you with access to, and use of, the Services;

for our legitimate interests to provide, operate and improve our Services;

where you have freely and expressly consented to the processing of your Personal Information by us, which you may withdraw at any time; or

where we are under a legal obligation to process your Personal Information.

9. Cross-border disclosure of Personal Information

We may disclose your Personal Information to third-party recipients located in or outside of the jurisdiction in which Personal Information is provided in order to provide our Services to you in accordance with applicable laws.

In order to protect your information, we take care where possible to work with subcontractors and service providers who we believe maintain an acceptable standard of data security compliance.

When entering into a transaction with us you consent to your Personal Information being disclosed or transferred to such third-party recipients and you acknowledge and agree that we have no obligation to take such steps as are reasonable in the circumstances to ensure that the information that is transferred or disclosed to the third-party recipients will be treated in a manner that is consistent with the relevant Privacy Laws. You also agree that insofar as the law allows, we have no liability to you or anyone else for any breach by a third-party recipient of the relevant Privacy Laws.

10. Direct marketing and communications

Where we:

have your express consent (which you may withdraw at any time by contacting us in writing at [email protected];

have a legal basis; or

are otherwise permitted by relevant Privacy Laws,

we may use and process your Personal Information to send you information about our Services as well as other products and services we believe may be suited to you and your interests or we may invite you to attend special events.

At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above will continue. You can opt out by following the unsubscribe instructions located here and included in the relevant marketing communication, or by contacting us in writing at [email protected].

11. Cookies

We use cookies, web beacons and similar technologies (collectively “Cookies”) on our Website. By accessing or using this Website, you agree that we can store and access Cookies in accordance with this Privacy Policy. You will be able to accept or reject the collection of Cookies by us.

Cookies are small files that can be stored on and accessed from a user’s device when the user accesses a website. They enable authorised web servers to recognise you across different websites, services, devices and browsing sessions.

We may use Cookies to enable users to access and use our Website and Services, including to:

identify users of our Website and Services;

process user requests;

improve user experience;

remember user preferences on our Website;

monitor the use of our Website and for analysis of our user base;

facilitate communication with users;

control access to certain content on our Website; and

protect our Website.

You can delete and refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website.

Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you direct your browser to our Website.

Ivorey uses the AdWorks and Remarketing List features of Google Analytics for Display Advertises. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on, to enable you to opt-out of Google’s programs.

12.Choices regarding Your privacy

You may be provided with choices with how we collect and process your information, including:

opting out or adjusting preferences for Cookies when your device accesses the Website;

customising your browser settings to disable or reject Cookies across the internet. It's important to note that deleting Cookies or declining them in your browser settings might affect the functionality of our Services; and

using your mobile device's operating system to select options on how it collects and utilises your information for interest-based advertising, if accessing the Services from a mobile device).

13. Notices specific to certain jurisdictions

We are dedicated to ensuring that individuals in certain jurisdictions have access to their privacy rights as provided by the Privacy Laws of your jurisdiction. We have set out details below dependent on your location.

Australia
You have the right to both ask:

for access to Personal Information that we hold about you; and

that we correct Personal Information we hold about you.

If you ask, we must within a reasonable timeframe (as set by law) give you access to your Personal Information and take reasonable steps to correct it if we consider it is incorrect, unless there is a law that allows or requires us not to.We will notify you in writing and explain our reasons if we refuse to give you access to, or correct, your Personal Information.

European Economic Area

For the purposes of the GDPR, we are a ‘data controller’ of your Personal Information. Under the GDPR, an individual residing in the European Union has enhanced privacy rights, including the right to:

require us to correct any Personal Information held about you that is inaccurate or incomplete;

require the deletion of Personal Information concerning you in certain situations;

data portability for Personal Information you provide to us where feasible. Please note, we do not support transfers of your Personal Information to other businesses or agencies that use the same software from which our Platform is derived and through which we deliver our Services;

object or withdraw your consent at any time to the processing of your Personal Information;

object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you; or

otherwise restrict our processing of your Personal Information in certain circumstances.

Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your Personal Information. In some instances, this means that we may retain some data even if you withdraw your consent.

We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.

If you believe that we hold Personal Information about you that is not accurate, complete or up to date, then you may request that your Personal Information be amended. We will respond to your request to correct your Personal Information within a reasonable timeframe (as set by the applicable law), and you will not be charged a fee for correcting your Personal Information.

14. Access, Management or Deleting your Personal Information

Subject to some exceptions provided by the relevant Privacy Laws, you may request access to your Personal Information in our customer account database, or seek correction of it, by contacting us at [email protected].

Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.

We may charge a reasonable fee that is not excessive to cover the charges of retrieving your Personal Information from our customer account database. We will not charge you for making the request.

If you believe that we hold Personal Information about you that is not accurate, complete, or up to date, then you may request that your Personal Information be amended. We will respond to your request to correct your Personal Information within a reasonable timeframe, and you will not be charged a fee for correcting your Personal Information.

15. Third Party Sites and Services

Our Services may contain links to other third-party websites and services including social media networks. This Privacy Policy applies solely to information collected by us via our Services.

16. Contacting Us

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us in writing at [email protected].

17. Notices and Revisions

We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice. Non-material changes and clarifications will take immediate effect, and material changes will take effect 30 days after the posting of the amended Privacy Policy on the Website.

18. Enforcement

We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personally identifiable information that cannot be resolved between us and the individual.

Last updated: 20 June 2025.

View our Privacy Policy and Terms and Conditions here.

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