Privacy Policy.

1. About This Policy

1.1 This Privacy Policy explains how Marcez Pty Ltd (ACN 637 414 638, ABN 70 637 414 638) trading as Sales Savvy Online (SSO, we, us, our) collects, holds, uses, and discloses personal information in connection with:

• the Sales Savvy Online website at https://salessavvy.online and all associated subdomains (the Website);
• SSO's AI-powered diagnostic tools and interactive instruments (the Tools);
• SSO's online courses, programs, masterclasses, and workshops (the Courses); and
• SSO's marketing, advertising, and client relationship activities.

1.2 SSO is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). Where applicable, SSO also complies with the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK GDPR, and the California Consumer Privacy Act as amended by the CPRA (CCPA).

1.3 By using the Website, completing any Tool, or enrolling in any Course, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described in it.

1.4 This Privacy Policy should be read alongside SSO's Website Terms of Use, available at https://salessavvy.online/terms-and-conditions/.

2. What Personal Information We Collect

2.1 The personal information SSO collects depends on how you interact with us. It may include:

• (a) Identity and contact information:
  • First name and last name
  • Business name
  • Email address
  • Phone number
  • Postal address
• (b) Business and operational information (self-reported through the Tools or application forms):
  • Monthly revenue, website traffic, and conversion metrics
  • Advertising spend and channel information
  • Product range, team structure, and operational details
  • Free-text responses describing your business situation, goals, or challenges
  • Prior agency or service provider history
• (c) Course and program information:
  • Enrolment and payment records
  • Course progress and completion data
  • Communications with SSO in connection with a Course
• (d) Technical and attribution metadata (collected automatically when you use the Website or Tools):
  • IP address and user agent string
  • Referrer URL and UTM campaign parameters
  • Advertising click identifiers (Facebook click ID (fbclid) and Google click ID (gclid))
  • Meta browser cookies (fbp and fbc)
  • Session timestamp, session length, and page interaction events
  • Google Analytics identifiers and usage data
  • Microsoft Clarity session replay and heatmap data
• (e) Communications:
  • Emails, messages, or enquiries you send to SSO
  • Records of your consent to marketing communications

2.2 SSO does not intentionally collect sensitive information (as defined in the Privacy Act, including health information, racial or ethnic origin, political opinions, religious beliefs, or criminal record) through the Website or Tools. If you include sensitive information in a free-text response, SSO will handle it in accordance with this Privacy Policy and the APPs.

2.3 SSO does not collect Tax File Numbers or financial account details through the Website or Tools.

3. How We Collect Personal Information

3.1 SSO collects personal information:

• (a) Directly from you, when you:
  • complete a Tool on the Website or any subdomain;
  • enrol in or purchase a Course;
  • submit an enquiry, application, or contact form;
  • subscribe to SSO's email list or marketing communications; or
  • communicate with SSO by email, phone, or through a community platform.
• (b) Automatically, through the use of cookies, tracking pixels, and analytics tools when you visit the Website or use a Tool. See Section 9 (Cookies and Tracking Technologies) for further detail.
• (c) From third parties, including advertising platforms (Meta, Google) that provide attribution data linking your interactions with SSO's advertising campaigns to your use of the Website or Tools.

3.2 Where practicable, SSO will collect personal information directly from you. Where SSO collects personal information about you from a third party, SSO will take reasonable steps to notify you of that collection as soon as practicable.

4. Why We Collect and Use Personal Information

4.1 SSO collects and uses personal information for the following purposes:

• (a) Delivering Tool outputs: to process your responses using AI-assisted analysis and return a personalised result, report, or recommendation to you;
• (b) Course delivery: to process your enrolment, provide access to Course materials, and communicate with you about your Course;
• (c) Marketing and communications: to send you information about SSO's services, programs, events, and resources that may be relevant to you. You may opt out of marketing communications at any time by clicking the unsubscribe link in any email or by contacting info@salessavvy.online;
• (d) Advertising attribution and measurement: to measure the effectiveness of SSO's advertising campaigns by matching your interactions with the Website or Tools to prior advertising interactions on Meta and Google platforms;
• (e) Analytics and improvement: to analyse usage patterns across the Website and Tools, improve existing products and services, and develop new offerings;
• (f) Client relationship management: to record and manage our relationship with you, including through SSO's CRM platform;
• (g) Legal and compliance obligations: to comply with any applicable law, court order, or regulatory requirement; and
• (h) Protecting SSO's interests: to enforce SSO's Website Terms of Use and protect the rights, property, and safety of SSO, its personnel, and others.

4.2 SSO will not use your personal information for a purpose that is incompatible with the purposes listed in clause 4.1 without first obtaining your consent or as otherwise permitted by law.

5. Disclosure of Personal Information

5.1 Third-Party Service Providers

To deliver its services and fulfil the purposes described in Section 4, SSO discloses personal information to the following third-party service providers:

5.1.1 Each provider is engaged under a written agreement that requires them to handle personal information in a manner consistent with applicable privacy laws. SSO takes reasonable steps to ensure providers maintain appropriate technical and organisational security measures.

5.1.2 SSO may engage additional service providers from time to time. Where a new provider is engaged in a role that involves processing personal information, SSO will update this Privacy Policy accordingly.

5.2 Other Disclosures

SSO may also disclose personal information:

• to professional advisers (lawyers, accountants, auditors) under obligations of confidentiality;
• to a successor entity in the event of a business sale, merger, or restructure, subject to that entity agreeing to handle personal information in accordance with this Privacy Policy; and
• where required or authorised by law, including to regulatory bodies, courts, or law enforcement agencies.

SSO does not sell personal information to third parties.

6. Cross-Border Disclosure

6.1 Several of SSO's service providers are located in, or process data in, the United States and potentially other jurisdictions outside Australia. By using the Website, completing any Tool, or enrolling in any Course, you acknowledge and consent to your personal information being disclosed to overseas recipients in those jurisdictions for the purposes described in Section 4.

6.2 Where personal information is disclosed to an overseas recipient, SSO takes reasonable steps, including contractual protections, to ensure that the overseas recipient does not breach the APPs in relation to that information, in accordance with APP 8.2 of the Privacy Act.

6.3 SSO intends to store its primary database in the AWS Sydney (ap-southeast-2) region. If the storage region changes to a jurisdiction outside Australia, SSO will update this Privacy Policy accordingly.

7. GDPR and UK GDPR (EEA and UK Users)

7.1 This section applies to individuals located in the European Economic Area or the United Kingdom whose personal data is processed by SSO.

7.2 Legal bases for processing. SSO processes your personal data on the following legal bases:

• Performance of a contract / pre-contractual steps (Article 6(1)(b) GDPR): to generate and deliver Tool outputs you have requested, and to deliver Courses you have purchased;
• Legitimate interests (Article 6(1)(f) GDPR): for advertising attribution, analytics, and follow-up communications about SSO's services, where those interests are not overridden by your rights and interests; and
• Consent (Article 6(1)(a) GDPR): where SSO has obtained your explicit consent, including for direct marketing where required by applicable law.

7.3 International transfers. Transfers of your personal data to service providers in the United States or other third countries are made subject to appropriate safeguards, including Standard Contractual Clauses (SCCs) adopted by the European Commission (or equivalent UK transfer mechanisms), or on the basis of an applicable adequacy decision.

7.4 Your rights. You have the right to:

• access your personal data;
• rectify inaccurate personal data;
• request erasure of your personal data ("right to be forgotten");
• restrict or object to processing;
• data portability; and
• withdraw consent at any time without affecting the lawfulness of prior processing.

7.5 To exercise any of these rights, contact SSO at info@salessavvy.online. SSO will respond within the timeframes required by applicable law. You also have the right to lodge a complaint with your local data protection supervisory authority.

7.6 Data retention. SSO retains personal data for as long as necessary to fulfil the purposes described in Section 4, or as required by law. See Section 10 for further detail.

8. CCPA (California Users)

8.1 This section applies to California residents whose personal information is processed by SSO.

8.2 Under the CCPA (as amended by the CPRA), you may have the right to:

• know what personal information SSO collects, uses, discloses, and sells about you;
• delete personal information SSO holds about you, subject to certain exceptions;
• correct inaccurate personal information;
• opt out of the sale or sharing of personal information; and
• non-discrimination for exercising your CCPA rights.

8.3 SSO does not sell personal information. SSO may share personal information with advertising platforms (Meta, Google) for cross-context behavioural advertising purposes. You may opt out of this sharing by contacting info@salessavvy.online or by using the opt-out mechanisms provided by those platforms.

8.4 To exercise your CCPA rights, contact SSO at info@salessavvy.online. SSO will respond within the timeframes required by applicable law.

9. Cookies and Tracking Technologies

9.1 SSO uses cookies and similar tracking technologies on the Website and Tools. These include:

9.2 You may limit certain tracking by:

• adjusting your browser settings to block or delete cookies;
• using browser extensions that block tracking scripts; or
• opting out through the relevant platform's opt-out mechanisms, including Meta's Ad Preferences, Google's My Ad Center, and Microsoft's privacy settings.

9.3 Opting out of tracking does not prevent you from using the Website, completing a Tool, or accessing a Course.

10. Data Retention

10.1 SSO retains personal information for as long as necessary to fulfil the purposes described in Section 4, or as required by law.

10.2 SSO currently retains Tool submission data indefinitely in its primary database unless you request deletion. SSO is reviewing its retention practices and intends to implement defined retention periods. This Privacy Policy will be updated when those periods are confirmed.

10.3 Course enrolment and payment records are retained for a minimum of seven years to comply with Australian tax and accounting obligations.

10.4 Marketing communication records (including consent records and unsubscribe requests) are retained for as long as necessary to manage SSO's marketing obligations and demonstrate compliance.

11. Security

11.1 SSO takes reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include:

• encrypted data transmission (TLS/HTTPS);
• access controls on database and application systems;
• contractual security obligations imposed on service providers; and
• regular review of security practices.

11.2 No method of transmission over the internet or electronic storage is completely secure. SSO does not guarantee the absolute security of personal information.

11.3 In the event of a data breach that is likely to result in serious harm to affected individuals, SSO will comply with its notification obligations under the Notifiable Data Breaches scheme (Part IIIC of the Privacy Act) and, where applicable, under the GDPR's 72-hour breach notification requirement.

12. Access and Correction

12.1 You may request access to, or correction of, personal information SSO holds about you by contacting:

• Email: info@salessavvy.online
• Mail: Sales Savvy Online, Level 24, 300 Barangaroo Avenue, Sydney NSW 2000
• Phone: 1300 384 670

12.2 SSO will respond to access and correction requests within a reasonable time and without charge (except where a charge is permitted by law and you have been notified in advance).

12.3 SSO will take reasonable steps to correct personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading.

12.4 If SSO refuses an access or correction request, SSO will provide written notice setting out the grounds for refusal and the mechanisms available to complain about the refusal, in accordance with the Privacy Act.

13. Deletion Requests

13.1 You may request deletion of your personal information at any time by contacting info@salessavvy.online. SSO will action deletion requests within a reasonable time, subject to any legal obligation to retain the information (including the seven-year retention obligation for financial records described in clause 10.3).

13.2 Deletion from SSO's primary database does not automatically result in deletion from third-party service providers' systems. SSO will take reasonable steps to notify relevant providers of your deletion request.

14. Complaints

14.1 If you have a complaint about how SSO has handled your personal information, please contact SSO in the first instance:

• Email: info@salessavvy.online
• Mail: Sales Savvy Online, Level 24, 300 Barangaroo Avenue, Sydney NSW 2000
• Phone: 1300 384 670

14.2 SSO will acknowledge your complaint within a reasonable time and investigate it within 30 days. SSO will provide you with written notice of the outcome of the investigation.

14.3 If you are not satisfied with SSO's response, you may lodge a complaint with:

• Australia: Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or 1300 363 992
• EU/EEA: your local data protection supervisory authority
• UK: the Information Commissioner's Office (ICO) at www.ico.org.uk
• California: the California Privacy Protection Agency at www.cppa.ca.gov

15. Children's Privacy

SSO's Website, Tools, and Courses are directed at business owners and marketing professionals. SSO does not knowingly collect personal information from individuals under the age of 18. If SSO becomes aware that it has collected personal information from a person under 18 without appropriate consent, SSO will take steps to delete that information promptly.

16. Links to Third-Party Websites

The Website may contain links to third-party websites. SSO is not responsible for the privacy practices of those websites. SSO encourages you to review the privacy policies of any third-party website you visit.

17. Changes to This Privacy Policy

17.1 SSO may update this Privacy Policy from time to time to reflect changes to its data practices, the Tools, the Courses, or applicable law.

17.2 Where changes are material, SSO will provide notice by updating the "Last Updated" date at the top of this page and, where practicable, by notifying affected users by email.

17.3 Continued use of the Website, any Tool, or any Course after any update constitutes acceptance of the revised Privacy Policy.

Last Updated: 16.04.2026