Privacy Policy

About this Privacy Policy

This Privacy Policy describes how we collect, use and handle Personal Information both about our Customers and on behalf of our Customers when providing our services.

Gibson Promotions PTY LTD (ABN 28 105 778 676) understands that privacy is a major concern for all our Customers. As part of providing our services, Gibson Promotions PTY LTD is committed to:

• ensuring we comply with the Data Protection Law applying to us; and
• dealing effectively with your enquiries and complaints concerning our compliance with privacy laws, regulations and codes.

This Policy is governed by Australian privacy law. If you are an individual located in the European Union or the United Kingdom, additional protections under the GDPR may apply to your personal information. Contact us using the details below if you would like more information about how those protections apply to you.

Please read this policy carefully to understand how we will treat your Personal Information. If you have any questions, please contact us using the details provided below.

Our services

Gibson Promotions PTY LTD provides call analytics services to Customers, which include small, medium and large businesses. Our services ("Call Analytic Services") include:

• helping Customers track and evaluate the performance of their advertising by measuring and analysing telephone calls generated by online, mobile and offline ad campaigns;
• helping Customers drive sales leads and/or other desired outcomes through targeted ad campaigns and providing related analytics services; and
• providing Customers with call recording and other data services for their inbound calls.

What information we collect and why

Customer information

We collect Customer Information in the following circumstances:

Opening a customer account: If you wish to become a customer, we require your name, residential and email addresses, and telephone number. We may also ask for copies of identity documents (driver's licence, passport, birth certificate and/or utility bills) and payment details such as credit card or bank account information (which may be used to set up a direct debit).

Enquiries, blogs and online interaction: If you send us an enquiry through our site, we may collect your name, phone number and email address. Our site may include publicly accessible blogs or community forums. Any information you provide in these public areas may be read, collected and used by other internet users.

Unfinished quote drafts: Our Letterbox quote form saves the information entered as a draft while it is being completed. A copy stays in that browser for seven days so the form can be restored on a return visit. Each change to a quote field, including typing, deletion, pasting and selection changes, is queued as a draft snapshot before submission. Draft snapshots, campaign attribution, coarse location, browser details and a protected network identifier are also retained in our restricted Australian data warehouse for up to 30 days. We use these records to diagnose form abandonment, invalid traffic and attempted misuse. An unfinished draft is not sent to our CRM, sales inbox or advertising platforms and does not count as an enquiry or conversion.

Credit information: Where we provide credit to Customers, we may collect and hold credit information and credit eligibility information. We may combine credit reporting information from a credit reporting body with our own information about creditworthiness.

Call recordings: Calls to Gibson Promotions PTY LTD offices and service centres may be recorded for verification and quality assurance purposes.

Third-party analytics services: We use Google Analytics 4 (GA4) and Google Tag Manager to evaluate site performance and the effectiveness of our marketing. These load for all visitors when you arrive on the site. We display a cookie notice rather than asking you to opt in. If you would prefer not to be measured, you can block cookies or use your browser's private browsing mode, and you can clear cookies for this site at any time.

Ahrefs Web Analytics: We use Ahrefs Web Analytics for aggregate traffic measurement (pageviews per URL, top referrers, popular content). This service is cookieless, does not use browser fingerprinting, and does not identify individual visitors. Ahrefs processes this data as our sub-processor under its own privacy notice at the Ahrefs privacy policy.

Security (Cloudflare Turnstile): We use Cloudflare Turnstile on our lead forms and AI tools to verify you are a human and not an automated bot. Turnstile may read basic browser signals (user agent, IP address, interaction patterns) to make this determination. Cloudflare processes this data as our sub-processor under its own privacy notice at cloudflare.com/privacypolicy.

Website journey analysis (Microsoft Clarity): We use Microsoft Clarity to understand page-level engagement, clicks and scroll behaviour so we can improve the site experience. Clarity loads for all visitors. Text you type into forms is masked, so session recordings do not capture what you enter. Microsoft processes this data as our sub-processor under its own privacy notice at privacy.microsoft.com.

B2B visitor identification (Leadfeeder): We use Leadfeeder (a Dealfront service) to identify the business or organisation behind anonymous website visits, based on the visitor's IP address. Leadfeeder does not identify individual visitors, only the company or organisation associated with the IP. The Leadfeeder tag loads only after you accept cookies. Leadfeeder processes this data as our sub-processor under its own privacy notice at leadfeeder.com/privacy.

Tracking technologies: Gibson Promotions PTY LTD and our partners may use tracking technologies such as web beacons, e-tags and JavaScript to analyse trends, administer our site, track users' movements, and obtain demographic information about our user base.

AI-powered tools

We provide free tools on our website (Call Performance Check, Website Answer Readiness Check, Grants Directory, Missed Call Calculator). When you use these tools, we collect the information you enter (such as your website URL, email, name, telephone number, business details, brief, and the answers you provide) so we can generate the requested result.

AI processing: The AI tools send your inputs to Anthropic (the makers of Claude, our AI provider) to generate recommendations. Anthropic processes this data on our behalf as a sub-processor. Anthropic does not train on this data by default. Anthropic's privacy notice is available at anthropic.com/privacy.

What we retain: We keep a record of your submission (email, name, telephone number, business, URL, brief, answers, score, and recommendations) in our CRM so Albert can follow up personally. You can request deletion at any time by calling 1800 950 347 or using our contact form.

Individual information (call analytics)

The information we receive from Customers about their current or prospective customers, or that we collect on behalf of Customers through our Call Analytics Services, is called "Individual Information." We process Individual Information in the following circumstances:

Cookies: We collect information from cookies which may include your IP address, browser software, pages visited (including time and date of visit), and keyword searches conducted.

Online usage and analytics data: We collect online usage and analytics data from Customer and third-party websites. This information includes IP address, date and time stamp, device ID, cookie ID, URL and referring URL, browser type, advertising identifiers, header information, and other information about the page or mobile application the user was viewing.

We also collect data on calls placed to our Customers, such as caller ID information, and may link that information to online activity collected, information collected from third parties, and information we have collected offline. We may also record calls placed to our Customers, at the Customer's election.

We do not collect sensitive information as part of providing Call Analytic Services.

How we use personal information

We collect and use the Personal Information described above in order to provide you with the Services in a reliable and secure manner and in particular:

• to identify you;
• to provide our Call Analytic Services, and manage, administer, and control the quality of those services;
• to market our products and services to you, and to enable selected third-party partners to market products and services to you;
• to do research and analysis related to our services, and to develop and improve our services;
• to assist with your enquiries or complaints;
• to protect our rights and property and to comply with our legal obligations; and
• any other purpose required or permitted by law.

Marketing and opting out

We may use and disclose your Personal Information for marketing purposes, including to:

• identify your behaviours, habits and preferences; and
• enable different members of the Gibson Promotions PTY LTD Group and selected third party partners to send you product and service information directly.

You can object to or withdraw your consent from future marketing communications from us at any time by:

• using the 'unsubscribe' link in any email communication; or
• calling us on 1800 950 347 or using our contact form.

Cookies and Google Ads

Gibson Promotions PTY LTD and our service providers may use cookies (persistent or single session) and other tracking technologies to provide Call Analytics Services and to obtain information about the use of our site. We do not use cookies to retrieve information that was not originally sent by us to you in a cookie. You may choose to refuse cookies but some functionality of our site and our Customers' sites may no longer be available to you. See our Cookie Policy for full details.

Functional cookies and browser storage: We use a small set of first-party functional cookies that do not share data with third parties. These include gp_returning (a 90-day first-party cookie that records a visit count and first and last-seen timestamps), gp_tool_gate (a 30-minute signed session cookie that confirms you have passed the bot challenge on our AI tools), and gibson_cookie_notice_v1 (a localStorage flag recording that you dismissed our cookie notice). The Letterbox form also uses localStorage to restore an unfinished draft for seven days; that draft contains the form values entered in that browser. You can clear them at any time by clearing site data for gibsonpromotions.com.au.

Our Customers may use our Call Analytics Services together with Google products such as AdWords, Google Analytics, and DoubleClick-branded services. For information about using Google Ads Settings to manage the Google ads you see, visit google.com/policies/technologies/ads.

Third-party sites

Our site may contain links to third-party sites and social media features (for example, Facebook and Twitter buttons and widgets). We have no control over those third-party sites and are not responsible for their content or privacy practices. For information about how to opt out of having your information collected in mobile applications, please visit ghostery.com.

Access and correction

Individual information

In supplying our Call Analytic Services, we provide information collection services to our Customers and do not have a direct relationship with the individuals whose information we process. If you are an individual (not a Customer) and wish to access, correct or delete Individual Information processed by us, you should direct your query to the Customer concerned (who controls the data). If you no longer wish to be contacted by one of our Customers, please contact that business directly.

Customer information

Customers can access the Customer Information Gibson Promotions PTY LTD holds about them. Your Personal Information will usually be available within 30 days of your request. You have a right to ask us to correct any inaccurate Customer Information we hold about you. We will take reasonable steps to correct your Personal Information to ensure it is accurate, up-to-date, complete, relevant and not misleading.

You can exercise any of these rights by contacting us using the contact details provided below. We may require evidence of your identity when processing your request.

Data sharing and international transfers

We may share your Personal Information with the following recipients:

• Our contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment;
• Third-party social networks, advertising networks and websites, so that we can market and advertise on third party platforms and websites;
• Our third party partners who may contact you regarding their products or services;
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
• Regulators, law enforcement agencies, and other relevant government authorities where legally required; and
• As otherwise required by law.

Gibson Promotions PTY LTD may disclose Personal Information to members of the Gibson Promotions PTY LTD Group or sub-processors in other locations around the world as necessary to provide the Services. The countries to which we may transfer Personal Information include the United States, the United Kingdom, New Zealand, Singapore, Japan, India, Hong Kong and Malaysia.

Change in ownership

If the ownership of Gibson Promotions PTY LTD or any part of it is transferred (for example, as the result of a corporate merger or bankruptcy), or there is a sale of assets, then some or all the Personal Information we hold may be transferred to the new owner. We will notify Customers of any such transfer or sale and outline your choices in the event.

Security

Gibson Promotions PTY LTD will implement and maintain appropriate technical and organisational security measures to protect against Personal Information Breaches and to preserve the security and confidentiality of Personal Information processed by Gibson Promotions PTY LTD.

In accordance with its obligations under Data Protection Laws, Gibson Promotions PTY LTD will inform the competent regulatory authority and the affected Data Subjects in the event of a Personal Information Data Breach affecting Customer Information. Upon becoming aware of a breach affecting Individual Information, Gibson Promotions PTY LTD will notify the Customer without undue delay and provide all relevant information as reasonably requested.

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. Most Personal Information stored in client files will be kept for a minimum of 7 years.

Australian Privacy Principles

Gibson Promotions is committed to providing quality services and has adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). These principles govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au.

Sensitive information

Sensitive information (as defined in the Privacy Act, including racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, criminal record, or health information) will be used by us only:

• For the primary purpose for which it was obtained;
• For a secondary purpose that is directly related to the primary purpose;
• With your consent; or
• Where required or authorised by law.

Definitions

In this policy:

• Customer includes all users of any of our services, prospective customers, suppliers and other third parties, and visitors to our site.
• Data Protection Law means the Privacy Act 1988 (Cth).
• GDPR means Regulation 2016/679 of the European Parliament and of the Council (General Data Protection Regulation).
• Personal Information has the same meaning as defined in the Data Protection Law.
• Personal Information Data Breach has the same meaning as 'eligible data breach' in the Data Protection Law.
• Sub-processor means any third party entity engaged by Gibson Promotions PTY LTD to process Personal Information for Call Analytics Services.

Making complaints

If you have a question or concern about how we have handled your Personal Information, please contact us. We will aim to respond to all requests, complaints and other contacts within a reasonable time, usually 30 days. Gibson Promotions PTY LTD takes all privacy complaints seriously and our Privacy Officer aims to efficiently resolve any issue arising.

Contact us

Privacy Officer
Gibson Promotions PTY LTD
43 Moate Ave, Brighton-Le-Sands NSW 2216
Phone: 1800 950 347
Contact form: gibsonpromotions.com.au/contact

Our Privacy Policy is available on our website, or you can request a copy in a different format by emailing us or telephoning 1800 950 347.

Changes to our privacy policy

We will review this Privacy Policy from time to time and reserve the right to modify or update it at any time. Changes to this Privacy Policy will come into effect immediately when uploaded to our site. If you continue using our products or services after changes are uploaded, you will be taken to have accepted those changes.