First Optimise – Privacy Policy

Last updated: 22 October 2025 (AEST)

1. About this Policy

This Privacy Policy describes how First Optimise Pty Ltd ("First Optimise", "we", "us", or "our") collects, uses, discloses, and safeguards your personal information when you use our websites, products, and services, including firstoptimise.com and related subdomains (the "Website"), and when you otherwise interact with us (together, the "Services").

We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). Where relevant, we also consider other applicable privacy laws in the locations in which our users are based.

By using the Services, you agree to the collection and use of information in accordance with this Policy.

2. Key definitions

  • Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable (whether true or not and whether recorded in a material form or not).

  • Sensitive information has the meaning given in the Privacy Act (e.g., health information). We do not intentionally collect sensitive information and ask that you do not provide it to us.

  • Usage data means information collected automatically through your use of the Services (e.g., device type, browser, pages visited, time on page, IP address).

  • Cookies are small data files placed on your device to operate, improve, and personalise the Services.

3. What we collect

The personal information we collect depends on how you interact with us. It may include:

  1. 3.1 Information you provide directly

  • Contact details (name, email address, phone number, organisation, role)

  • Account and authentication information (if you create an account)

  • Enquiry and support information

  • Billing and transactional information (if you purchase Services)

  • Training/workshop participation details and feedback

  1. 3.2 Information collected automatically

  • Usage data (IP address, pages viewed, referring/exit pages, timestamps, approximate location)

  • Device and browser information (type, version, operating system)

  • Cookie identifiers and similar technologies

  1. 3.3 Information from third parties

  • Lead and marketing partners

  • Payment and billing providers

  • Analytics and advertising partners

We collect personal information directly from you wherever practicable. We may also collect it from publicly available sources and third parties where lawful and reasonable.

4. How we use personal information

  • Provide and operate the Website and Services

  • Respond to enquiries and provide customer support

  • Set up and manage accounts and authenticate users

  • Deliver audits, training, workshops, and consulting

  • Process payments and manage invoices

  • Send operational communications (e.g., updates, notices)

  • Market and promote our Services, including newsletters and offers (you can opt out at any time)

  • Monitor, analyse, and improve the Website and Services (user experience, performance, security)

  • Detect, prevent, and address technical or security issues, fraud, or misuse

  • Comply with legal obligations and enforce our agreements

5. Cookies and tracking technologies

  • operate core Website functions (e.g., session management);

  • remember your preferences;

  • measure Website performance and usage; and

  • support marketing/advertising.

You can control cookies through your browser settings. If you disable cookies, parts of the Website may not function properly. For more detail, see our Cookie Notice (if published) or contact us.

Where the EU/UK GDPR applies, we process personal data on the following legal bases: (i) performance of a contract or to take steps at your request prior to entering into a contract; (ii) legitimate interests (e.g., to secure and improve the Services, respond to enquiries, and market to business contacts); (iii) compliance with legal obligations; and (iv) consent (e.g., for certain marketing or cookies, where required). You can withdraw consent at any time.

7. When we share personal information

  • Service providers and vendors who help us operate, host, analyse, support, bill, or market the Services

  • Professional advisors (e.g., legal, accounting, auditors)

  • Business partners (e.g., co‑hosted events, joint offerings)

  • Prospective or actual buyers (in connection with a merger, acquisition, asset sale, or similar corporate transaction)

  • Authorities where required by law or to protect rights, safety, and security

We do not sell personal information.

8. Overseas disclosures

Some recipients of personal information may be located outside Australia. Where we disclose personal information overseas, we will take reasonable steps to ensure the recipient protects it in a manner consistent with the APPs (e.g., by using appropriate contractual safeguards). By using the Services, you understand that your information may be processed in countries with different privacy laws to those in your jurisdiction.

9. Data security

We use reasonable technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure and we cannot guarantee absolute security.

10. Data retention

We retain personal information only for as long as necessary for the purposes described in this Policy (including to comply with legal, accounting, or reporting requirements), and then we take reasonable steps to de‑identify or securely destroy it.

11. Your choices and rights

  • Marketing: You can opt out of marketing emails by using the unsubscribe link or contacting us.

  • Cookies: You can control cookies via your browser settings.

  • Access and correction (Australia): You may request access to the personal information we hold about you and request corrections if it is inaccurate, out‑of‑date, incomplete, irrelevant, or misleading. We may ask you to verify your identity and will respond within a reasonable period.

  • EEA/UK rights (where applicable): You may have additional rights, including to object to processing, restrict processing, data portability, and to lodge a complaint with your local data protection authority.

12. Children’s privacy

Our Services are not directed to individuals under 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can take appropriate steps.

The Website may contain links to third‑party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.

14. Changes to this Policy

We may update this Privacy Policy from time to time. The updated version will be posted on the Website with a revised "Last updated" date. Your continued use of the Services constitutes acceptance of the updated Policy.

15. How to contact us

First Optimise Pty Ltd

Email: [email protected]

Jurisdiction: Victoria, Australia

15.1 Complaints (Australia)

If you make a privacy complaint, we will respond within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

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