1. About This Policy

Verve Solution Pty Ltd (ABN 34 652 306 262) (“we”, “us”, “our”) is committed to protecting the privacy of individuals who interact with our website and services.

This Privacy Policy explains how we collect, use, disclose, store and protect your personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the 13 Australian Privacy Principles (“APPs”) contained in Schedule 1 of that Act.

As a private sector entity operating in Victoria, Australia, we are bound by the federal Privacy Act 1988 (Cth). The Victorian Privacy and Data Protection Act 2014 (Vic) applies to Victorian public sector bodies; however, as a private company we acknowledge and align our practices with the spirit of Victorian privacy standards and the guidance of the Office of the Victorian Information Commissioner (OVIC) where relevant.

By accessing or using our website, you consent to the collection and use of your information as described in this policy.

2. About Us

Verve Solution Pty Ltd is a web design and digital services company registered in Victoria, Australia.

Registered Name	Verve Solution Pty Ltd
ABN	34 652 306 262
State	Victoria, Australia
Website	www.vervesolution.com.au
Privacy Contact Email	info@vervesolution.com.au

3. What Personal Information We Collect

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not (Privacy Act 1988, s 6).

We may collect the following types of personal information:

3.1 Information You Provide Directly

• Full name
• Email address
• Phone number
• Postal or business address
• Details of your enquiry, project brief or message
• Any other information you choose to submit through our contact or enquiry forms

3.2 Information Collected Automatically

When you visit our website, our servers and analytics tools may automatically collect:

• IP address and approximate geographic location
• Browser type, version and operating system
• Pages visited, time on site and referring URL
• Device identifiers and screen resolution
• Cookie and session data (see Section 8 — Cookies)

3.3 Sensitive Information

We do not intentionally collect sensitive information (such as health information, racial or ethnic origin, political opinions, religious beliefs, or biometric data). If you inadvertently provide sensitive information, we will handle it in accordance with APP 3 and, where applicable, the Health Records Act 2001 (Vic).

4. How We Collect Personal Information

We collect personal information by lawful and fair means, and where it is reasonably practicable to do so, directly from you (APP 3). We collect information when you:

• Submit an enquiry or contact form on our website
• Send us an email or telephone us
• Request a quote or proposal for our services
• Subscribe to any newsletter or email communications
• Interact with us through social media platforms
• Browse our website (via cookies and analytics tools)

We will only collect personal information that is reasonably necessary for one or more of our business functions or activities (APP 3.2).

5. Why We Collect and Use Your Personal Information

We collect, hold, use and disclose your personal information for the following primary purposes:

• Responding to your enquiries and providing information about our services
• Delivering web design, development and digital services you have engaged us for
• Preparing quotes, proposals and project agreements
• Managing our ongoing client relationship and communications
• Sending invoices and processing payments
• Improving our website and services
• Complying with our legal obligations under applicable laws
• Sending service-related announcements or newsletters (where you have consented or as permitted by the Spam Act 2003 (Cth))

We will not use or disclose your personal information for any secondary purpose without your consent, unless an exception applies under the Privacy Act (APP 6).

6. Disclosure of Personal Information

We may share your personal information with third parties in the following circumstances:

• Service providers and contractors who assist us in operating our website, processing data or providing our services (e.g., hosting providers, email platforms, analytics providers), bound by confidentiality obligations
• Professional advisers including lawyers and accountants, where necessary
• Government or regulatory authorities, where required or authorised by law
• Other parties with your explicit consent

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

7. Cross-Border Disclosure of Personal Information

As an organisation with both Australian and overseas operations, personal information we collect may be accessed by, transferred to, or processed by staff or systems located outside Australia. This section explains how we handle cross-border disclosures in accordance with APP 8 of the Privacy Act 1988 (Cth).

7.1 Our Overseas Office

Verve Solution Pty Ltd operates an overseas office whose staff may remotely access personal information held by us in the course of delivering services on behalf of the Australian entity. This remote access constitutes a cross-border disclosure under the Privacy Act 1988 (Cth).

The country in which our overseas office is located may not have a privacy law that is substantially similar to the Australian Privacy Principles. Accordingly, we take the following steps to protect your personal information when it is accessed by our overseas team:

• Internal data handling agreements and confidentiality obligations binding all overseas staff to privacy standards equivalent to the APPs
• Access controls that restrict which staff members can access personal information, limiting access to what is strictly necessary for the service being performed (need-to-know basis)
• Mandatory training for overseas staff on Australian privacy obligations and our internal data handling procedures
• Prohibition on overseas staff storing, copying or retaining personal information on local devices or unauthorised systems
• Regular oversight by Australian management to ensure compliance with this policy and our internal privacy procedures

7.2 Third-Party Overseas Service Providers

In addition to our overseas office, some of the third-party platforms and tools we use (such as website hosting, email marketing and analytics software) may store or process data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure those recipients handle your personal information in accordance with the Australian Privacy Principles or a substantially similar law or binding scheme (APP 8).

Where we are unable to take such reasonable steps, we will seek your express consent before disclosing personal information to that overseas recipient. If you consent, you acknowledge that APP 8.1 will not apply to that specific disclosure and we will not be responsible for the overseas recipient’s handling of your information.

8. Cookies and Website Analytics

Our website uses cookies — small text files stored on your device — to improve your browsing experience and to understand how visitors use our site. We use first-party cookies and may use third-party tools such as Google Analytics.

Cookies we may use include:

• Essential cookies — required for the website to function correctly
• Analytics cookies — to understand visitor behaviour and improve our website
• Preference cookies — to remember your settings and preferences

You may disable cookies through your browser settings at any time. Disabling cookies may affect certain functionality of our website. You will still be able to access all content and information on our site even if cookies are disabled.

We do not use cookies to identify individual users and we do not merge analytics data with personal information you have provided to us.

9. Security of Personal Information

We take all reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification or disclosure (APP 11). Our security measures include:

• Secure HTTPS encryption for all web traffic
• Access controls restricting personal information to authorised personnel only
• Use of reputable and security-compliant hosting and software providers
• Regular review of our data handling practices and systems
• Secure disposal or de-identification of personal information when no longer required

While we take reasonable precautions, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee the absolute security of information transmitted to or from our website.

10. Notifiable Data Breaches

We are committed to complying with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988. 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:

• Conduct a prompt assessment of the suspected breach
• Notify affected individuals as soon as practicable if the breach is likely to cause serious harm
• Notify the Office of the Australian Information Commissioner (OAIC)

11. Retention and Destruction of Personal Information

We retain personal information only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. When personal information is no longer needed, we will take reasonable steps to destroy it or permanently de-identify it (APP 11.2).

Client records and related correspondence may be retained for up to 7 years to comply with Australian tax and company record-keeping obligations.

12. Your Rights — Access and Correction

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

To make a request:

• Submit your request in writing to our Privacy Contact (see Section 17)
• Provide sufficient information to identify yourself and specify the information requested
• We will respond within 30 days and, where access is granted, provide it in a format agreed with you
• We will not charge a fee for making a request, but may charge a reasonable cost-recovery fee if the request is complex

We may decline access in limited circumstances permitted by APP 12.3, such as where providing access would pose a serious threat to health or safety, or would unreasonably impact on the privacy of another individual. If we decline, we will provide written reasons.

13. Anonymity and Pseudonymity

Where it is lawful and practicable to do so, we provide you with the option to interact with us without identifying yourself or by using a pseudonym (APP 2). For example, you may browse our website without providing personal information.

However, to respond to a specific enquiry or provide services, we will generally need to identify you.

14. Direct Marketing

We may send you marketing communications where you have consented to receive them, or where permitted under APP 7 and the Spam Act 2003 (Cth). Every marketing communication will include a clear and simple way for you to opt out.

If you request to opt out of direct marketing, we will action your request promptly and at no cost to you. Even after opting out of marketing, you may still receive transactional and service-related communications.

15. Third-Party Websites and Links

Our website may contain links to external websites operated by third parties. We are not responsible for the privacy practices of those websites. We encourage you to review the privacy policies of any third-party sites you visit, as this policy does not extend to those websites.

16. Privacy Complaints

If you believe we have not complied with our obligations under the Privacy Act 1988 or this Privacy Policy, you may lodge a complaint with us:

• Submit your complaint in writing to our Privacy Contact (see Section 17)
• We will acknowledge receipt within 5 business days
• We will investigate and respond with our findings within 30 days
• If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC)

17. How to Contact Us

For all privacy-related inquiries, access or correction requests, or complaints, please contact our Privacy Officer:

Privacy Officer	Verve Solution Pty Ltd
Email	info@vervesolution.com.au
Post	Victoria, Australia
ABN	34 652 306 262

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations or business operations. When we make material changes, we will update the Effective Date at the top of this document and, where appropriate, notify you directly.

We encourage you to review this policy periodically. Continued use of our website after any changes constitutes your acceptance of the updated policy.

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Verve Solution Pty Ltd • ABN 34 652 306 262 • Victoria, Australia

This Privacy Policy was last reviewed 26 June 2026.