Privacy Policy
Last updated 31 October 2026. Version 2.3, replacing the version dated 25 October 2026.
1. About this Policy
This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website (Site).
In this Privacy Policy, 'we', 'us', or 'our' means:
Entity: XLR8 Media, operated by XLR8 Media Holdings Pty Ltd ATF Llewellin Family Trust, ABN 75 533 606 065, Level 17/9 Castlereagh St, Sydney NSW 2000.
We are committed to complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act.
2. Personal Information We Collect
2.1 Information from Clients
When you engage our Google Ads services, we may collect:
- Your name and the name of your business or agency
- Your email address and phone number
- Your business address and ABN
- Credit card details for payment processing (handled via PCI DSS compliant processors)
- Campaign preferences, target suburbs, and service requirements
- Website URLs and digital assets used in advertising campaigns
- Performance data from your advertising campaigns (impressions, clicks, click-through rate, ad position and calls, and conversions or leads where they are tracked)
- Communications between you and our team
2.2 Information about People Who Respond to Our Clients' Campaigns
When someone responds to an advertising campaign we run for a client (a prospective lead), we may collect personal information about them. What we collect depends on how the campaign is set up:
- Calls made from the call button in an ad: the caller's phone number and the date and time of the call
- Lead forms, where a campaign uses one: the details the person enters, such as their name, email address, phone number, enquiry details and property information
- Conversion tracking on a client's website, where it is set up: the actions a person takes after clicking an ad, such as submitting an enquiry form, and the details collected by that form
This information is collected for the purpose of delivering it to you as the campaign client and is handled in accordance with our standard data security practices. Call details are emailed to the client the next business day.
2.3 Information from Website Enquiries
When you send an enquiry or check suburb availability through our Site, we collect the details you enter: your name, phone number, email address, agency, suburb and message. We use them to reply to you, and a copy is kept on our web server as a backup in case an email does not arrive.
2.4 Information Collected Automatically
When you visit our Site, we may automatically collect:
- Your IP address and browser type
- Device and operating system information
- Pages visited and time spent on our Site
- Referring website and clickstream data
- Location data (at suburb or city level, where permitted)
3. How We Use Personal Information
We collect, hold, use, and disclose personal information for the following purposes:
- To provide Google Ads campaign management services to you
- To contact and communicate with you about your campaigns and account
- For internal record keeping, invoicing, and administrative purposes
- To deliver call details and lead contact details to you as the campaign client
- For analytics, platform improvement, and business development
- To send you service updates, performance reports, and renewal communications
- For advertising and marketing, including promotional information about our services
- To comply with our legal obligations and resolve disputes
- To consider employment applications where relevant
4. Disclosure of Personal Information to Third Parties
We may disclose personal information to:
- Google LLC, for the purpose of creating, managing, and optimising your Google Ads campaigns
- Payment processors, for the purpose of processing campaign fees and invoices
- Our employees, contractors, and related entities for the purpose of providing services to you
- Credit reporting agencies, courts, tribunals, and regulatory authorities in the event of payment default or legal proceedings
- Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law
- Analytics and advertising platforms (such as Google Analytics) for Site performance measurement
We do not sell personal information to third parties.
5. Overseas Disclosure
Our website is hosted in Sydney, Australia. Client and campaign information is stored in Google products such as Google Workspace and Google Sheets, and our email runs on Microsoft 365. Website enquiries are sent to us through our email delivery provider, Brevo, which may process them outside Australia. These and some of our other service providers may store or process data outside Australia, including in the United States and Singapore. Where data is transferred overseas, we take reasonable steps to ensure the recipient complies with the Australian Privacy Principles or is subject to a comparable privacy regime.
6. Data Security
We are committed to ensuring that personal information we collect is secure. We implement suitable physical, electronic, and managerial procedures to safeguard personal information against misuse, interference, loss, and unauthorised access, modification, or disclosure.
Despite these measures, no system is completely secure. We cannot guarantee the security of information transmitted over the internet. Transmission is carried out at your own risk.
7. Notifiable Data Breaches
In the event of a data breach that is likely to result in serious harm to any individual whose information is involved, we will:
- Assess the breach promptly and take steps to contain it
- Notify affected individuals as soon as practicable
- Report the breach to the Office of the Australian Information Commissioner (OAIC) where required under the NDB scheme
- Take remedial action to prevent future breaches
If you become aware of any actual or suspected security breach involving your information, please contact us immediately at info@xlr8.media.
8. Data Retention
We retain personal information for the following periods:
- Client contact information: duration of relationship plus 7 years
- Campaign and performance data: duration of relationship plus 7 years
- Financial records and invoices: 7 years (as required by Australian tax law)
- Caller phone numbers from ad calls: shortened to the first four digits after 90 days
- Lead form and conversion details, where collected: 12 months from campaign end, unless earlier deletion is requested
- Website enquiries that do not lead to an engagement: 2 years
- Communications (email, phone records): 3 years unless longer retention is required
- Site analytics data: up to 14 months (the Google Analytics retention setting)
9. Cookies and Web Beacons
We may use cookies on our Site from time to time. Cookies are text files placed in your browser to store preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties such as Google and Facebook to cause our advertisements to appear on your social media and online media feeds as part of retargeting campaigns.
We may also use web beacons (clear GIFs) to monitor visitor behaviour, count page visits, and deliver cookies. You can control cookies through your browser settings, though disabling them may affect Site functionality.
10. Your Rights
10.1 Access
You may request details of the personal information we hold about you. An administrative fee may be payable. In certain circumstances permitted by the Privacy Act 1988, we may decline access requests.
10.2 Correction
If you believe any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us. We will take reasonable steps to correct it.
10.3 Deletion
You may request deletion of your personal information, subject to legal retention requirements. Where deletion is not possible (e.g., financial records required by law), we will advise you accordingly.
10.4 Opt-Out of Marketing
To unsubscribe from our email database or marketing communications, contact us using the details below or use the unsubscribe facility in any marketing email.
11. Privacy Complaints
If you believe we have breached the Australian Privacy Principles or this Privacy Policy, please contact us:
Contact: Email: info@xlr8.media | Phone: 02 8287 3333 | Post: Level 17/9 Castlereagh St, Sydney NSW 2000
We will acknowledge complaints within 2 business days and respond within 30 days with an outcome or progress update.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
12. Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended version on our Site with a new 'Last Updated' date. We recommend you check our Site regularly. For material changes, we will notify active clients by email.
13. Contact Us
- Email: info@xlr8.media
- Phone: 02 8287 3333
- Address: Level 17/9 Castlereagh St, Sydney NSW 2000
- Website: xlr8.media
- ABN: 75 533 606 065
Last Updated: 31/10/2026 | Version 2.3 | Replaces version dated 25/10/2026
© XLR8 Media Holdings Pty Ltd ATF Llewellin Family Trust. All rights reserved.
