RECLUDO LIMITED

Privacy Policy

 

1. Introduction and Our Commitment

Recludo Limited (ACN 675 493 142) (“Recludo”, “we”, “us”, “our”) is an Australian company that operates recludo.com.au and associated digital services (the “Services”). We are committed to protecting the privacy of individuals in accordance with the Privacy Act 1988 (Cth) (the “Privacy Act”) and the thirteen Australian Privacy Principles (“APPs”) contained in Schedule 1 of that Act.

This Privacy Policy explains how we collect, use, hold, disclose, and protect your personal information. It applies to all personal information we collect through our websites, mobile applications, social media accounts, and any direct interactions with us.

Please read this policy carefully. By using our Services, you acknowledge that you have read and understood this policy. We recommend you review this policy periodically, as we may update it from time to time in accordance with section 13 below.

 

2. What Is Personal Information?

Under the Privacy Act, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether it is recorded in a material form or not.

“Sensitive information” is a subset of personal information that includes health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record information, and biometric data. We treat sensitive information with a higher standard of protection and will only collect it where strictly necessary and with your explicit consent, or as otherwise required by law.

 

3. Personal Information We Collect

3.1 Information You Provide to Us

We collect personal information that you voluntarily provide to us, including when you:

  • register for an account or use our Services;
  • complete forms, surveys, or polls on our website;
  • contact us by email, telephone, or other means;
  • subscribe to newsletters or marketing communications;
  • participate in promotions or competitions; or
  • make a purchase or payment through our platform.

The types of personal information we may collect include your name, email address, postal address, telephone number, account credentials, billing and payment information, and any other information you choose to provide.

3.2 Information Collected Automatically

When you visit our website or use our Services, we and our service providers may automatically collect certain technical information, including:

  • IP address and general geographic location derived from it;
  • browser type, version, and operating system;
  • pages visited, links clicked, and time spent on pages;
  • referring URL and exit pages;
  • device identifiers and technical capabilities; and
  • log files and session data.

This information is collected using cookies and similar technologies as described in section 8 below. We use this information in aggregate and, where applicable, individually to improve our Services and to personalise your experience.

3.3 Information from Third Parties

We may receive personal information about you from third-party sources such as social media platforms, analytics providers, advertising partners, and payment processors. Where we do so, we handle that information in accordance with this policy and the APPs.

 

4. How We Use Your Personal Information (APP 6)

We will only use or disclose your personal information for the primary purpose for which it was collected, a directly related secondary purpose, or where you have consented to another use. Our primary purposes for collecting personal information include:

  • providing, operating, and improving our Services;
  • processing transactions and managing your account;
  • communicating with you about your account, transactions, or our Services;
  • sending you marketing and promotional communications (where you have consented or where permitted under the Spam Act 2003 (Cth));
  • conducting analytics, research, and statistical analysis to understand how our Services are used;
  • personalising your experience and delivering relevant advertising;
  • complying with legal obligations; and
  • protecting the security and integrity of our systems and Services.

We will not use your personal information for a secondary purpose that you would not reasonably expect, unless we have obtained your consent or are otherwise permitted to do so under the Privacy Act.

 

5. Direct Marketing (APP 7)

We may use your personal information to send you direct marketing communications about our products and services, and those of selected partners, where permitted by law. Specifically:

  • If you are an existing customer, we may send you marketing communications related to our goods or services that are similar to those you have previously purchased or enquired about, unless you have opted out.
  • If you are not an existing customer, we will only send you marketing communications with your express or implied consent.

Each marketing communication we send will include a clear and functional opt-out mechanism. You may opt out of receiving marketing communications at any time by:

  • clicking the unsubscribe link in any marketing email;
  • emailing us at info@recludo.com.au with the subject line “Marketing Opt-Out”; or
  • contacting us using the details in section 11.

We will give effect to your opt-out request as soon as practicable, and no later than within five (5) business days. Note that even if you opt out of marketing, we may still send you service-related and transactional communications necessary for the operation of your account.

We will not use sensitive information for direct marketing purposes.

We do not share your personal information with third parties for the purpose of allowing those third parties to send you their own direct marketing, unless you have given us your express consent to do so.

 

6. Disclosure of Personal Information to Third Parties (APP 6)

We may disclose your personal information to the following categories of third parties:

  • Service providers and contractors who assist us in operating our Services (such as cloud hosting providers, analytics platforms, email delivery services, and customer support tools);
  • Payment processors who process transactions on our behalf (your payment card details are collected and held by those processors directly and are subject to their own privacy policies);
  • Advertising and analytics partners (such as Google and Meta) for the purpose of delivering targeted advertising and measuring campaign performance;
  • Professional advisers including lawyers, accountants, and insurers; and
  • Government agencies, law enforcement, and regulatory bodies where required or permitted by law.

We require all third-party service providers to handle personal information in a manner consistent with the APPs. We do not sell, rent, or trade your personal information to third parties for their own commercial purposes.

In the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred to the acquiring entity, subject to equivalent privacy protections.

 

7. Cross-Border Disclosure of Personal Information (APP 8)

Some of our service providers and partners are located outside Australia. As a result, your personal information may be disclosed to, stored in, or processed in countries other than Australia, including but not limited to the United States, the United Kingdom, and other countries where our vendors operate.

Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information. This may include entering into data processing agreements with overseas recipients that require them to maintain equivalent privacy protections.

By using our Services, you acknowledge that we may transfer your personal information overseas as described above. Where we are unable to ensure an overseas recipient will comply with the APPs, we will seek your consent prior to disclosure, or rely on another exception permitted under APP 8.

 

8. Cookies and Similar Technologies (APP 1, APP 3)

We use cookies, web beacons, pixel tags, local storage, and similar tracking technologies (collectively, “cookies”) on our website. Cookies are small text files placed on your device that help us recognise you, remember your preferences, and understand how you use our Services.

8.1 Types of Cookies We Use

  • Strictly necessary cookies: Required for the operation of our website and Services. These cannot be disabled without impairing functionality.
  • Performance and analytics cookies: Help us understand how visitors interact with our website (e.g., Google Analytics).
  • Functional cookies: Enable enhanced functionality and personalisation.
  • Targeting and advertising cookies: Used to deliver relevant advertising and to track the effectiveness of our campaigns.

8.2 Your Cookie Choices

Where our website permits it, you may choose to accept or decline non-essential cookies through our cookie consent tool. You may also manage or delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Services, but we will not deny you access to our website solely because you decline non-essential cookies.

We do not respond to browser-based “Do Not Track” signals at this time; however, you may use the opt-out mechanisms described in this section and section 5 to control data collection for marketing purposes.

 

9. Data Quality and Security (APP 10 & APP 11)

We take reasonable steps to ensure that the personal information we hold is accurate, up to date, complete, and relevant for the purposes for which it is used (APP 10).

We implement reasonable technical, administrative, and physical safeguards to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure (APP 11). These measures include, but are not limited to, encryption of data in transit and at rest, access controls and authentication requirements, staff training on privacy obligations, and periodic security reviews.

No method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. If you have concerns about the security of your information, please contact us at info@recludo.com.au.

 

10. Notifiable Data Breaches

We are subject to the Notifiable Data Breaches (“NDB”) scheme under Part IIIC of the Privacy Act. If we become aware of a data breach that is likely to result in serious harm to any individual whose personal information is involved, we will:

  • contain the breach and assess the risk of harm as quickly as practicable;
  • notify the Office of the Australian Information Commissioner (“OAIC”) as soon as practicable; and
  • notify affected individuals directly, or publish a notice on our website if direct notification is not practicable.

Our notification will include a description of the breach, the kinds of information involved, and recommendations for steps individuals can take to protect themselves.

 

11. Access to and Correction of Personal Information (APP 12 & APP 13)

Under the Privacy Act, you have the right to request access to the personal information we hold about you (APP 12), and to request that we correct personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13).

To make an access or correction request, please contact us at info@recludo.com.au with the subject line “Privacy Access Request” or “Privacy Correction Request”. We will respond to your request within 30 days. We may require you to verify your identity before we can process your request.

We will provide access to your personal information free of charge, unless doing so would impose an unreasonable administrative burden, in which case we may charge a reasonable fee. We will notify you of any applicable fee before processing your request.

If we refuse your request for access or correction, we will provide written reasons for the refusal and information about how you may complain about the decision. We will not refuse a correction request without good reason; if we do not agree with a requested correction, we will note your request on the relevant record.

 

12. Privacy Complaints (APP 1)

If you believe we have interfered with your privacy or breached the APPs, you may lodge a complaint with us by contacting:

Privacy Officer Recludo Limited Email: info@recludo.com.au Subject line: “Privacy Complaint”

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If we are unable to resolve your complaint within that time, or you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au
  • Phone: 1300 363 992
  • Mail: GPO Box 5288, Sydney NSW 2001

 

13. Amendments to This Policy

We may amend this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes to this policy, we will:

  • update the “Effective Date” and “Last Reviewed” date at the top of this document;
  • post the updated policy on our website at recludo.com.au; and
  • where required by law or where the changes are material, notify you by email or prominent notice on our website at least 30 days before the changes take effect.

We encourage you to review this policy periodically. Your continued use of our Services after a change takes effect constitutes your acceptance of the updated policy, to the extent permitted by law.

 

14. Children’s Privacy

Our Services are not directed at children under the age of 15, and we do not knowingly collect personal information from children under 15 without verifiable parental consent. If you are under 15, you must not provide us with any personal information without the consent of a parent or guardian.

If we become aware that we have inadvertently collected personal information from a child under 15 without appropriate consent, we will take steps to delete that information as soon as practicable. If you believe we may have collected information about a child, please contact us at info@recludo.com.au.

 

15. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. The specific retention period depends on the nature of the information and the purpose for which it was collected. Factors we consider include:

  • the length of our ongoing relationship with you;
  • whether we are subject to a legal obligation to retain the information for a minimum period (for example, tax records under the Income Tax Assessment Act 1997 (Cth) or financial records under the Corporations Act 2001 (Cth)); and
  • whether retention is advisable given our legal position, including applicable limitation periods.

When personal information is no longer required, we will take reasonable steps to destroy or permanently de-identify it in a secure manner, in accordance with APP 11.

 

16. Governing Law

This Privacy Policy is governed by the laws of the State of New South Wales, Australia, and the Commonwealth of Australia, including the Privacy Act 1988 (Cth). Any disputes relating to this policy or our privacy practices are subject to the exclusive jurisdiction of the courts of New South Wales, and you irrevocably submit to that jurisdiction.

Nothing in this policy limits or excludes any rights you have under the Privacy Act or any other applicable Australian law that cannot be excluded by agreement.

 

17. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

Recludo Limited

Privacy Officer Email: info@recludo.com.au

Website: www.recludo.com.au

Postal: LEVEL 40 2-26 PARK ST, SYDNEY NSW 2000, AUSTRALIA.

 

This policy was last reviewed in May 2026.

 

This Privacy Policy is compliant with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.