Goldroom Privacy Policy

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This Privacy Policy is implemented by Aspire Live Pty Ltd trading as Goldroom (ABN 99 662 218 135, a subsidiary of Aspire Digital Group Pty Ltd ABN 22 656 250 109) (“Goldroom”, “we”, “us”, “our”). It explains how personal information is collected, stored, used, handled, disclosed, and protected by Goldroom when you:

• visit our website (https://goldroom.io/)
• contact us or request a consultation
• engage our digital, consulting, marketing, design or related services
• subscribe to communications
• interact with our content, analytics tools or marketing

This Policy is designed to comply with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles (“APPs”). This policy is also designed to comply with GDPR principles (where applicable) and international data handling best practice. It also describes the rights and choices available to you regarding the use, access, and correction of your personal information.

1. Who We Are

Goldroom provides branding, marketing, digital, design, media, signage, consulting and related services. We operate in Australia and may deliver services internationally through affiliates, related entities, or contractors.

Privacy Officer contact:
Email: [email protected]
Address: 70 Stirling Terrace, Albany, WA, Australia
Phone: +61 8 9841 1466

2. Types of Information We Collect

The types of information we collect depend on the nature of our interaction with you. You do not have to provide us with your personal information, but if you choose not to, we may not be able to provide you with our services.

Information You Provide

We may collect:

• name
• email address
• phone number
• business information
• job title
• project details
• messages submitted via forms
• consultation booking information

Client Information

Where you become a client, we may collect:

• company details
• billing information
• project assets
• access credentials provided to deliver services
• marketing data
• website analytics access
• technical environment details

Automatically Collected Information

We may collect:

• IP address
• device type
• browser type
• pages visited
• referral source
• session data
• usage behaviour
• cookie identifiers

Third-Party and Verification Sources

We may collect information from publicly available resources and third-party providers to the extent permitted by law.

Goldroom Media Network (Digital Signage)

Where you interact with or pass by our physical Out-of-Home (OOH) screens, we may utilise aggregated audience measurement technology (such as footfall tracking or general demographic estimation) to measure campaign performance. We do not collect identifying biometric data or facial recognition via these screens unless explicitly consented to at the venue.

3. Sensitive Information

Sensitive information is a subset of personal information that is given a higher level of protection under the Privacy Act 1988 (Cth).

Goldroom does not ordinarily collect sensitive information in the course of providing marketing and design services. If sensitive information is collected, it will only be with your consent, or where required or authorised by or under an Australian law or a court/tribunal order.

4. How We Collect Information

We collect information through:

• website forms
• consultation booking forms
• email communications
• service onboarding
• client platforms
• cookies and tracking tools
• analytics platforms
• third-party integrations

We will collect personal information by lawful and fair means, and only where it is reasonably necessary for our functions or activities, in accordance with APP 3.

5. How We Use Your Personal Information

We use personal information to:

• respond to enquiries
• provide consultations
• deliver services
• manage client relationships
• improve website performance
• conduct analytics
• send service communications
• send marketing (with consent)
• manage contracts
• process payments
• maintain security
• comply with legal obligations

We will not use personal information for a purpose other than the purpose for which it was collected (the “primary purpose”), unless you would reasonably expect the secondary use, you have consented, or it is required or authorised by law.

Where required, processing is based on consent, contractual necessity, legitimate business interests, legal obligations, or service delivery requirements.

We will not sell or rent your personal information.

6. Cookies and Tracking

Goldroom uses cookies and similar technologies for:

• website functionality
• analytics
• performance optimisation
• marketing measurement
• user experience improvement

Users can control cookies through browser settings. Examples of tools used may include Google Analytics, Meta tracking pixels, advertising platforms, and session cookies.

If you choose to block cookies, you may not be able to use certain features, and preferences dependent on cookies may be lost.

Opting Out of Analytics

You can opt out of data collection by third-party analytics providers via their opt-out mechanisms. We use analytics to understand usage, improve performance, and inform content decisions.

7. Disclosure of Personal Information

We may disclose your personal information in limited circumstances as described below.

We may disclose personal information to:

(a) Service providers – that support our service delivery, including technology platforms, hosting providers, CRM systems, and payment processors.

(b) Analytics providers – for website analytics and performance measurement.

(c) Contractors – engaged to assist with service delivery.

(d) Professional advisers – including lawyers, auditors, and insurers.

(e) Legal authorities – where required or authorised by law.

(f) Related entities – within the Aspire group for purposes consistent with this Policy.

(g) Business transfers – if Goldroom undergoes a merger, acquisition, restructure, or investment, information may be transferred subject to confidentiality.

We do not sell personal information.

Client Data (Agency Processing)

Where Goldroom processes data on behalf of clients (for example, managing a client’s marketing campaigns, website analytics, or customer data):

(a) we act as a service provider / processor;

(b) the client remains the controller;

(c) we process data according to client instructions; and

(d) clients are responsible for lawful collection and appropriate consents.

8. Cross-Border Disclosure of Personal Information

Information may be processed or stored outside Australia where service providers operate internationally, including via cloud platforms, marketing tools, project management tools, and development infrastructure.

Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the overseas recipient does not breach the APPs, in accordance with APP 8.

We use reputable service providers with appropriate controls and contractual data protection obligations.

9. Data Security

We implement reasonable safeguards including:

• access controls
• secure platforms
• encryption where appropriate
• least-privilege access
• vendor due diligence
• internal confidentiality obligations
• incident response procedures

No system is completely secure, and we cannot guarantee absolute security.

10. Data Retention

We retain information:

• as long as necessary for service delivery
• for legal obligations
• for dispute resolution
• for business record keeping
• for analytics and improvement (in de-identified form)

When no longer required, information is deleted or de-identified.

You may request deletion by contacting us. If we no longer need your information and are not required by law to retain it, we will take necessary steps to destroy or de-identify it.

11. Notifiable Data Breaches

Goldroom complies with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth).

If we become aware that there are reasonable grounds to believe that an eligible data breach has occurred, we will:

(a) take all reasonable steps to contain the breach and evaluate the risks;

(b) notify the OAIC as soon as practicable if the breach is likely to result in serious harm; and

(c) notify affected individuals as soon as practicable, providing information about the breach, the kind of information involved, and recommended steps.

12. Your Rights – Access and Correction

Under APP 12, you have the right to request access to the personal information we hold about you. We will respond within 30 days.

Under APP 13, if you believe that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request correction.

We may need to verify your identity before processing your request.

We may refuse access in certain circumstances permitted by law and will provide written reasons.

Depending on jurisdiction, you may also request deletion, restriction, objection to processing, data portability, or withdrawal of consent. Requests can be submitted via the contact details below.

13. Marketing Communications

We may send updates, insights, service announcements, and marketing communications.

You may unsubscribe from marketing at any time. We comply with the Spam Act 2003 (Cth).

Service communications (e.g. billing, project updates) cannot always be opted out of.

14. Third-Party Links

Our website may link to third-party platforms. We are not responsible for their privacy practices. Your interaction with those websites is subject to their own terms and policies.

15. Children

Our services are not directed to children under 18. We do not knowingly collect children’s personal information.

16. Complaints

If you wish to make a complaint about our privacy practices, please contact our Privacy Officer using the contact details below.

Your complaint will be acknowledged within 7 days and investigated. We will respond within 30 days.

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

Name: Office of the Australian Information Commissioner
Address: GPO Box 5218, Sydney NSW 2001
Phone: 1300 363 992
Website: www.oaic.gov.au

Goldroom will cooperate with external complaints handling or investigations by the OAIC or any other authorised regulator, and will comply with any lawful orders, decisions, or directions.

17. Changes to This Policy

We may update this Privacy Policy from time to time. We will publish the updated version on the website with a revised date.

If there are material changes, we will provide reasonable notice where required by law.

Your continued use of our services after publication indicates acceptance.

18. Contact Us

For questions about this Privacy Policy or our personal information handling processes:

Privacy Officer
Email: [email protected]
Address: 70 Stirling Terrace, Albany, WA, Australia
Phone: +61 8 9841 1466

For complaints, please use the same contact details and mark your correspondence as a “Privacy Complaint” addressed to the Privacy Officer.