Privacy Policy

Think Swift Pty Ltd

Effective Date: March 2026  |  Version 1.0

1. Introduction

Think Swift Pty Ltd (ABN 90 685 252 902) ("ThinkSwift", "we", "us", or "our") is committed to protecting the privacy of individuals who interact with us, including visitors to our website (thinkswift.com.au), prospective clients, current clients, and other individuals whose personal information we handle in the course of our business.

This Privacy Policy explains how we collect, use, disclose, store, and otherwise handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By visiting our website or engaging with our services, you acknowledge that you have read and understood this Privacy Policy.

2. About ThinkSwift

ThinkSwift is a Melbourne-based boutique custom software agency. We design and build bespoke AI-powered software, automation solutions, and custom operating systems for established businesses. Our registered office is located at:

Think Swift Pty Ltd

4th Floor, 459 Church St

Cremorne VIC 3121

Australia

privacy@thinkswift.com.au

3. What Personal Information We Collect

We may collect the following types of personal information:

3.1 Information you provide directly

• Name, job title, and organisation name
• Business and personal email addresses
• Phone numbers
• Postal and business addresses
• Information submitted via contact forms, enquiry forms, or Penny (our AI digital receptionist)
• Information shared during discovery workshops, project briefings, or client onboarding
• Payment and billing information (processed via secure third-party payment providers)

3.2 Information collected automatically

• IP addresses and device identifiers
• Browser type and operating system
• Pages visited on thinkswift.com.au and the duration of visits
• Referring URLs and search terms
• Cookies and similar tracking technologies (see Section 9)

3.3 Information from third parties

• Publicly available business information (e.g., LinkedIn profiles, company websites)
• Referrals from existing clients or business partners
• Information shared through integrated third-party platforms used in the delivery of our services

4. How We Collect Personal Information

We collect personal information through a number of channels, including:

• Directly from you when you contact us via our website, email, phone, or in person
• Via Penny, our AI digital receptionist embedded on our website or client websites
• Through our project delivery and client engagement processes
• From publicly available sources during business development activities
• Through cookies and analytics tools on our website
• From third-party platforms where you have provided consent for your information to be shared

Where it is lawful and practical to do so, we will collect personal information directly from the individual concerned.

5. Why We Collect and Use Personal Information

We collect and use personal information for the following purposes:

5.1 Service delivery

• To provide, manage, and improve our software development and AI services
• To communicate with clients about project progress, deliverables, and outcomes
• To onboard clients and manage ongoing engagements

5.2 Business operations

• To respond to enquiries and provide quotes or proposals
• To process invoices and manage billing
• To comply with our contractual and legal obligations
• To manage our internal business systems and administration

5.3 Marketing and communications

• To send relevant updates, case studies, and content about our services (where you have consented or where we have a legitimate interest)
• To conduct business development and outreach activities
• To personalise our communications to your business context

5.4 Website improvement

• To analyse website traffic and user behaviour to improve our website and services
• To troubleshoot technical issues

We will only use your personal information for the purpose for which it was collected, or for a directly related purpose that you would reasonably expect. We will seek your consent before using your information for any other purpose.

6. Disclosure of Personal Information

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

We may disclose your personal information to:

• Our team members who need access to deliver services to you
• Trusted third-party service providers who assist us in operating our business, including cloud hosting providers (e.g., Microsoft Azure, Vercel, Supabase), project management tools, CRM platforms, and communication tools — all subject to appropriate confidentiality and data protection obligations
• AI platform providers used in the delivery of our services (e.g., Anthropic, OpenAI, Google), where personal information may be processed as part of AI-powered features
• Professional advisors such as accountants, lawyers, or auditors, where necessary
• Regulatory authorities or law enforcement agencies if required by law or if we have a good-faith belief that disclosure is necessary to comply with a legal obligation, protect our rights, or prevent harm
• A successor entity in the event of a business sale, merger, or restructure, subject to that entity agreeing to handle your personal information consistently with this Privacy Policy

Where we engage third-party service providers to process personal information on our behalf, we take reasonable steps to ensure they are bound by appropriate privacy obligations.

7. Overseas Disclosure

Some of the third-party services we use to deliver our work may store or process data on servers located outside Australia, including in the United States and other jurisdictions. These include cloud infrastructure providers and AI platform providers.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure they are bound by enforceable privacy protections comparable to the Australian Privacy Principles. By engaging with our services, you consent to your personal information being transferred to and processed in these overseas jurisdictions where applicable.

8. Data Storage and Security

We take data security seriously. ThinkSwift is currently pursuing ISO 27001 certification and maintains a number of technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include:

• Access controls and role-based permissions
• Encrypted data storage and transmission
• Secure cloud infrastructure with reputable, enterprise-grade providers
• Regular security reviews and vulnerability assessments
• Staff awareness of privacy and data handling obligations

No method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect personal information, we cannot guarantee absolute security. In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required under the Notifiable Data Breaches scheme.

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience and collect information about how visitors use our site. Cookies are small text files stored on your device.

We use the following types of cookies:

• Essential cookies: Required for the website to function correctly
• Analytics cookies: Used to understand how visitors interact with our website (e.g., Google Analytics)
• Marketing cookies: Used to deliver relevant content and measure the effectiveness of our campaigns

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website. For more information, refer to your browser's help documentation.

10. Retention of Personal Information

We retain personal information for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal and contractual obligations, or as required by applicable laws (including the Corporations Act 2001 (Cth) and taxation legislation).

When personal information is no longer required, we take reasonable steps to destroy or de-identify it in a secure manner.

11. Your Privacy Rights

Under the Privacy Act 1988 (Cth), you have the right to:

• Access the personal information we hold about you
• Request that we correct personal information that is inaccurate, out of date, incomplete, or misleading
• Make a complaint if you believe we have interfered with your privacy
• Opt out of receiving direct marketing communications from us at any time

To exercise any of these rights, please contact us using the details in Section 13. We will respond to your request within a reasonable timeframe (generally within 30 days). We do not charge a fee for access or correction requests, though we reserve the right to charge reasonable costs for requests that are excessively complex.

12. Direct Marketing

We may use your personal information to send you marketing communications about our services, insights, and relevant content where you have consented or where we have a legitimate business interest to do so.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any email we send you
• Contacting us directly at privacy@thinkswift.com.au

We will honour opt-out requests promptly. Please note that even after opting out of marketing, we may still contact you in relation to an existing engagement or for administrative purposes.

13. Complaints and Contact

If you have a concern or complaint about how we have handled your personal information, we encourage you to contact us in the first instance so we can attempt to resolve the matter directly:

Privacy Officer

Think Swift Pty Ltd

4th Floor, 459 Church St, Cremorne VIC 3121

hello@thinkswift.com.au

We will acknowledge your complaint within 5 business days and endeavour to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner

Website: www.oaic.gov.au

Phone: 1300 363 992

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. The current version will always be available on our website at thinkswift.com.au.

Where changes are material, we will notify existing clients directly. We encourage you to review this policy periodically.

This Privacy Policy was last updated in March 2026.

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