Privacy Policy

This Privacy Policy describes how TradeWise Group Pty Ltd (ABN [INSERT ABN]) ("TradeWise", "we", "us", "our") collects, holds, uses, and discloses personal information.

This policy applies to all personal information collected through our website (tradewisegroup.au), our business tools and calculators (including the Business Valuation Scorecard), our marketing activities, and our client engagement processes.

We are an Australian business operating primarily in Australia. This policy is prepared in accordance with:

• The Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs)
• The Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act
• The Spam Act 2003 (Cth) in relation to electronic communications
• The Do Not Call Register Act 2006 (Cth) in relation to telephone marketing

Where our services are accessed by individuals in the United Kingdom or European Union, we also aim to meet the standards of the UK GDPR and EU GDPR respectively, to the extent reasonably practicable. However, our primary legal obligations are under Australian law.

TradeWise Group Pty Ltd is a business management services company providing outsourced operations, financial management, HR, systems, marketing, and exit planning services to trade business owners in Australia and internationally.

For the purposes of the Privacy Act 1988, TradeWise Group Pty Ltd is the APP entity responsible for personal information collected through our website and business activities.

We collect personal information that is reasonably necessary for our business functions and activities. The types of personal information we may collect include:

3.1 Identity & Contact Information

• First name and last name
• Email address
• Phone number (including mobile)
• Business name and trading name
• Business address and state/location

3.2 Business Information

• Trade type and industry (e.g. plumbing, electrical, HVAC)
• Number of employees
• Self-reported financial information (annual revenue, net profit, owner salary) provided voluntarily through our Business Valuation Scorecard tool
• Self-reported business situation and goals
• Scorecard responses and calculated scores

3.3 Technical & Usage Information

• IP address and general geographic location
• Browser type and version
• Pages visited, time spent on pages, and navigation paths
• Device type and operating system
• Referring website or source
• Cookie identifiers and session data (see Section 9)

3.4 Sensitive Information

We do not intentionally collect sensitive information as defined under the Privacy Act (such as health, racial, or political information). If you voluntarily provide any sensitive information, we will handle it in accordance with APP 3.

3.5 Financial Information

The financial figures entered into our Business Valuation Scorecard (revenue, profit, salary) are used solely to calculate an indicative valuation estimate. This information is transmitted to our CRM (HubSpot) for the purpose of follow-up — please see Section 8 regarding overseas disclosure. We do not collect bank account details, credit card numbers, or tax file numbers.

We collect personal information in the following ways:

4.1 Directly From You

• When you complete our Business Valuation Scorecard
• When you submit an enquiry, contact form, or request a strategy call
• When you book a meeting through our HubSpot scheduling tool
• When you engage with us as a client, prospect, or partner
• When you email, call, or otherwise communicate with us directly
• When you subscribe to our email communications

4.2 Automatically Through Our Website

• Through HubSpot analytics and tracking embedded on our website (see Section 9)
• Through standard web server logs
• Through cookies and similar tracking technologies

4.3 From Third Parties

• From referral partners or introducers who refer clients to us
• From publicly available sources (e.g. business registries, LinkedIn) where relevant to our engagement

Where we collect personal information about an individual from a third party, we will take reasonable steps to notify that individual in accordance with APP 5.

4.4 Anonymity Option

In accordance with APP 2, where it is lawful and practicable, you may interact with us anonymously or using a pseudonym. However, if you wish to receive personalised services, a strategy call, or valuation results, we will need to collect your personal information.

We collect personal information only for purposes that are directly related to our business functions and activities. These purposes include:

• Providing and personalising our services to business owners
• Responding to enquiries and scheduling strategy calls
• Delivering Business Valuation Scorecard results and follow-up communications
• Assessing whether our services are appropriate for your business
• Managing client relationships and ongoing service engagements
• Sending relevant marketing communications (with your consent or where we have a legitimate interest)
• Improving and developing our website, tools, and services
• Complying with our legal obligations under Australian law
• Fraud prevention and security purposes

We will not collect personal information unless it is reasonably necessary for one or more of the above purposes (APP 3.2).

We will only use or disclose your personal information for the primary purpose for which it was collected, or for a secondary purpose if you would reasonably expect us to use it for that purpose, or with your consent (APP 6).

6.1 We May Disclose Your Information To:

• HubSpot Inc. — our CRM and marketing automation platform (see Section 8 for overseas disclosure details)
• IT service providers — hosting, website infrastructure, and software vendors who support our operations
• Professional advisers — lawyers, accountants, and consultants where necessary for our business operations
• Regulatory and government bodies — where required or permitted by law (e.g. the Australian Taxation Office, ASIC)
• Prospective buyers or partners — only in the context of a business transaction involving TradeWise, and subject to confidentiality obligations

6.2 We Will Not:

• Sell your personal information to third parties
• Share your financial information with third parties for their own commercial purposes
• Use your personal information for purposes unrelated to our services without your consent

We may use your personal information to send you marketing communications about our services, tools, events, and resources where:

• You have provided your consent; or
• We have collected your information in the course of a commercial relationship and the communication is related to similar products or services (consistent with APP 7 and the Spam Act 2003)

All marketing emails sent by us will include a clear and functional unsubscribe mechanism. You may opt out of receiving marketing communications at any time by:

• Clicking "unsubscribe" in any email we send you
• Emailing us at kate@tradewisegroup.au with the subject "Unsubscribe"

We will process all opt-out requests within 5 business days in accordance with the Spam Act 2003 (Cth). Opting out of marketing will not affect communications required to fulfil services you have requested.

In accordance with APP 8, we are required to disclose when your personal information may be transferred to overseas recipients.

8.1 HubSpot Inc. (United States)

We use HubSpot Inc., a company headquartered in the United States, as our customer relationship management (CRM) and marketing automation platform. Personal information submitted through our website forms — including the Business Valuation Scorecard — is transmitted to and stored on HubSpot's servers, which may be located in the United States or other countries.

HubSpot participates in the EU–US Data Privacy Framework and maintains privacy protections consistent with international standards. You can review HubSpot's Privacy Policy at legal.hubspot.com/privacy-policy.

8.2 Our Obligations Under APP 8

Before disclosing your personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the APPs in relation to your information. By submitting information through our website, you acknowledge that your personal information may be transferred to and stored overseas as described above.

8.3 Other Overseas Transfers

We may use other cloud-based software providers who store data on servers outside Australia (e.g. hosting services, analytics platforms). We take reasonable steps to ensure these providers maintain appropriate security standards.

Our website uses cookies and similar tracking technologies to improve your experience and help us understand how visitors use our site.

9.1 What Are Cookies?

Cookies are small text files placed on your device by a website. They are widely used to make websites work efficiently and to provide information to the website owner.

9.2 Cookies We Use

• HubSpot tracking cookies — used to track website visits, identify returning visitors, and associate form submissions with browsing activity. HubSpot uses the __hstc, hubspotutk, __hssc, and __hssrc cookies for this purpose.
• Essential cookies — necessary for the website to function correctly
• Analytics cookies — help us understand how visitors interact with our website (pages viewed, time on site, traffic source)

9.3 Managing Cookies

You can control and manage cookies through your browser settings. You can choose to:

• Accept all cookies
• Reject all non-essential cookies
• Delete existing cookies

Note that disabling cookies may affect the functionality of our website and tools. Instructions for managing cookies vary by browser — refer to your browser's help documentation for specific guidance.

9.4 Do Not Track

Some browsers send "Do Not Track" signals. Our website does not currently respond to these signals, however we respect your right to manage cookies as described above.

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and from unauthorised access, modification, or disclosure, in accordance with APP 11.

Our security measures include:

• Secure HTTPS encryption for all data transmitted through our website
• Access controls and authentication requirements for internal systems
• Use of reputable, security-certified third-party platforms (including HubSpot)
• Regular review of our data handling practices
• Staff awareness of privacy and data security obligations

10.1 Notifiable Data Breaches

We are subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988. In the event of an eligible data breach — one that is likely to result in serious harm to affected individuals — we will:

• Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable
• Notify affected individuals as required
• Take immediate steps to contain the breach and prevent further harm

While we implement reasonable security measures, no method of electronic data transmission or storage is completely secure. We cannot guarantee the absolute security of information transmitted to us online.

We retain personal information for as long as reasonably necessary to fulfil the purposes for which it was collected, or as required by law.

• Prospect information (e.g. scorecard submissions with no ongoing engagement) — retained for up to 3 years for marketing and follow-up purposes, unless you request deletion earlier
• Client information — retained for a minimum of 7 years following the conclusion of an engagement, as required by Australian tax and corporate law
• Website analytics data — retained in accordance with HubSpot's data retention policies

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it in accordance with APP 11.2.

12.1 Access (APP 12)

You have the right to request access to the personal information we hold about you. We will respond to access requests within 30 days. We will not charge a fee for making an access request, however we may charge a reasonable fee to cover the cost of providing access where the request is complex.

We may refuse access in limited circumstances permitted under APP 12.3 (e.g. where access would be unlawful, or unreasonably impact another individual's privacy). If we refuse access, we will provide written reasons.

12.2 Correction (APP 13)

If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you may request that we correct it. We will take reasonable steps to correct the information within 30 days of your request.

12.3 Deletion

You may request that we delete personal information we hold about you. We will honour deletion requests where we are not legally required to retain the information. Please note that some information may need to be retained for legal, regulatory, or audit purposes.

12.4 UK and EU Residents — Additional Rights

If you are located in the United Kingdom or European Union, you may have additional rights under the UK GDPR or EU GDPR respectively, including:

• The right to data portability
• The right to object to processing
• The right to restrict processing
• Rights in relation to automated decision-making

Please contact us at kate@tradewisegroup.au to exercise any of these rights. We will respond in good faith and in accordance with applicable law.

12.5 How to Make a Request

To exercise any of the above rights, please contact us at kate@tradewisegroup.au with the subject line "Privacy Request". We may need to verify your identity before processing your request.

If you believe we have interfered with your privacy or breached the Australian Privacy Principles, you have the right to make a complaint.

13.1 Complain to Us First

We ask that you contact us in the first instance to give us the opportunity to resolve your concern:

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If more time is required, we will notify you of the expected timeframe.

13.2 Office of the Australian Information Commissioner (OAIC)

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

13.3 UK Residents

UK residents may also lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

13.4 EU Residents

EU residents may lodge a complaint with the relevant national Data Protection Authority (DPA) in their country of residence.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or for other operational reasons. When we make material changes, we will update the "Last updated" date at the top of this page.

We encourage you to review this policy periodically. Continued use of our website or services following any changes constitutes your acceptance of the updated policy.

For significant changes that materially affect how we handle your personal information, we will endeavour to notify you directly via email where we hold your contact details.

For any questions, requests, or concerns regarding this Privacy Policy or the way we handle your personal information, please contact us:

We are committed to resolving privacy concerns promptly and transparently.