FOCAL GLOW PTY LTD (ABN 12 687 446 064) (“Focal Glow”, “we”, “our”, or “us”) respects your privacy and is committed to protecting the personal information we collect.

This Privacy Policy explains how we collect, use, store and disclose personal information when you interact with us, whether online, by phone, by email, through social media, or in person. It has been prepared in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

By using our website or providing personal information to us, you agree to the terms of this Privacy Policy.

We may collect personal information including:

Contact Information

• Full name
• Email address
• Phone number
• Business name
• Postal or street address

Project Information

• Property address
• Project requirements
• Building plans
• Design documents
• Technical specifications
• Images and project-related information

Architectural and property-related documentation provided to us is treated with a heightened level of confidentiality. Such information is not disclosed to third parties except as strictly necessary to deliver the agreed services.

Website Information

When you visit our website, we may automatically collect information such as:

• IP address
• Device information
• Browser type
• Operating system
• Website pages visited
• Time spent on pages
• Referral sources
• Search terms
• Website interactions

Marketing Information

We may collect information about:

• Marketing preferences
• Newsletter subscriptions
• Event registrations
• Downloaded resources
• Survey responses
• Competition entries

We collect information when you:

• Submit an enquiry form
• Contact us by phone or email
• Request a quotation
• Book a consultation
• Subscribe to our newsletter
• Download resources
• Participate in surveys or promotions
• Interact with us on social media
• Visit our website

We may also collect information from publicly available sources or from third-party service providers where permitted by law.

Where we interact with you through social media, we may collect information made available through those platforms. Focal Glow currently maintains a presence on platforms including Instagram, Facebook and LinkedIn. Each of these platforms operates under its own privacy policy and data practices, which are independent of this Policy. We encourage you to review the privacy policies of any social media platform you use before engaging with us through those channels. Focal Glow does not control the data collection practices of third-party social media platforms.

We collect and process personal information on the following legal bases:

• Consent — where you have provided your consent, for example by subscribing to our newsletter or submitting an enquiry form;
• Contract — where collection is necessary to provide services you have requested or to take steps at your request before entering into a contract;
• Legal obligation — where we are required to collect or retain information to comply with applicable laws or regulatory requirements; and
• Legitimate interests — where collection is necessary for our legitimate business interests, such as improving our services, managing our business relationships, and preventing fraud, provided those interests are not overridden by your privacy rights.

Where we rely on your consent, you may withdraw that consent at any time by contacting us using the details below. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

We collect personal information to:

• Respond to enquiries
• Provide quotations and proposals
• Deliver products and services
• Develop lighting concepts and specifications
• Manage projects
• Process payments
• Communicate with clients
• Improve our website and services
• Conduct analytics and market research
• Maintain business records
• Comply with legal obligations
• Send marketing communications where permitted

If you subscribe to our newsletter or marketing communications, we may send information relating to:

• Lighting products and services
• Design inspiration
• Industry insights
• Company news and updates
• Project features and case studies
• Events and promotions

We only send direct marketing communications to individuals who have expressly opted in or subscribed to receive them. We do not send marketing communications to contacts who have not provided their consent or made a clear request to receive such communications.

You may unsubscribe at any time using the unsubscribe link in our emails or by contacting us directly, and we will action your request promptly. We will only send marketing communications in accordance with the Spam Act 2003 (Cth) and your communication preferences.

Our website may use technologies including:

• Cookies
• Pixels
• Tags
• Web beacons
• Analytics software

These technologies help us understand website performance, improve user experience, measure marketing effectiveness, analyse website traffic and deliver relevant advertising.

We currently utilise Google Analytics 4 (“GA4”), operated by Google LLC. GA4 is configured with IP address anonymisation. For further information about how Google handles data collected through GA4, please refer to Google’s Privacy Policy at policies.google.com/privacy.

We may implement additional analytics, advertising or marketing technologies from time to time, and this Policy will be updated accordingly.

You may manage cookie and tracking preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling cookies may affect the functionality of some parts of our website.

We use third-party technology providers to operate and maintain our website and related services. This may include:

• Website hosting providers
• Content management platforms
• Cloud storage providers
• Analytics providers
• Marketing and communication platforms
• Customer relationship management (CRM) systems
• Professional advisers and contractors

We currently utilise DatoCMS as part of our website infrastructure and content management environment. DatoCMS is operated by DATO SRL. For information about DatoCMS’s data practices, please refer to their privacy policy at datocms.com/legal/privacy-policy.

We take reasonable steps to ensure all third-party service providers handle personal information appropriately and in accordance with applicable privacy laws.

We may disclose personal information to:

• Service providers who assist in operating our business
• Technology and software providers
• Marketing and communication providers
• Professional advisers
• Regulatory authorities where required by law
• Courts, tribunals and law enforcement agencies where legally required

We take reasonable steps to ensure third parties handle personal information appropriately and do not use it for purposes other than those for which it was disclosed.

Some of the technology platforms and service providers we use operate globally. As a result, personal information we collect may be stored or processed overseas, including in countries where our service providers maintain infrastructure.

Before disclosing personal information to an overseas recipient, Focal Glow takes reasonable steps to ensure that the recipient handles personal information in a manner consistent with the Australian Privacy Principles. Where applicable, this is supported by contractual arrangements or other legally recognised mechanisms.

You acknowledge that, despite these steps, overseas recipients may be subject to the laws of their jurisdiction, which may differ from Australian law, and may be required to disclose personal information to foreign authorities in certain circumstances.

Where permission has been obtained from the client, Focal Glow may photograph completed projects and use project-related imagery, descriptions and information for:

• Portfolio presentations
• Website content
• Case studies
• Social media content
• Marketing and promotional materials
• Industry awards and publications

Where appropriate, identifying information may be removed or limited to protect privacy. Clients may withdraw consent for the use of project imagery at any time by contacting us.

We take reasonable steps to protect personal information from unauthorised access, misuse, interference, loss, modification or disclosure.

• Security measures may include:
• Secure cloud-based systems
• Password-protected platforms
• Access controls
• Encryption where appropriate
• Staff training and security procedures

While we take reasonable precautions, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Focal Glow is subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth).

In the event of an eligible data breach — that is, a breach that is likely to result in serious harm to one or more individuals whose personal information is involved — we will:

• Notify affected individuals as soon as practicable;
• Notify the Office of the Australian Information Commissioner (OAIC); and
• Take immediate steps to contain the breach and prevent further harm.

Notifications will include a description of the breach, the kinds of information involved, and the steps we recommend individuals take in response.

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including for legal, accounting, regulatory or reporting obligations.

As a general guide:

• Client project records and associated personal information are generally retained for a minimum of seven (7) years from project completion, in accordance with our legal and contractual obligations;
• Marketing and newsletter subscriber records are retained until you unsubscribe or request deletion; and
• Website analytics data is retained in accordance with the retention settings of the relevant platform (e.g. Google Analytics 4).

When personal information is no longer required, we will take reasonable steps to destroy or permanently de-identify it in accordance with APP 11.2.

You may request access to personal information we hold about you. You may also request correction of information that is inaccurate, incomplete or out of date.

You may also request that we delete or de-identify personal information we hold about you where we are no longer required to retain it under law or for a legitimate business purpose. We will consider all such requests in accordance with our obligations under the Privacy Act 1988 (Cth) and respond within a reasonable timeframe.

Requests should be made using the contact details provided below. We may require verification of your identity before actioning any request.

If you believe we have breached applicable privacy laws, please contact us in writing using the details below.

We will:

• Investigate your complaint;
• Respond within a reasonable timeframe; and
• Work to resolve the matter where appropriate.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.

Our website may contain links to external websites. We are not responsible for the privacy practices of those websites and encourage users to review their privacy policies separately.

We may update this Privacy Policy from time to time. The latest version will always be available on our website and will include the revision date.

Your continued use of our website following publication of an updated Privacy Policy constitutes acceptance of those changes. Where changes to this Privacy Policy are material, we will take reasonable steps to notify affected individuals, which may include prominent notice on our website or direct communication by email where contact details are held.

For any privacy-related enquiries, requests or complaints, please contact:

FOCAL GLOW PTY LTD (ABN 12 687 446 064)
Phone: (07) 4801 6337
Email: hello@focalglow.co
Website: focalglow.co

Brisbane Office & Showroom: 1 | 72 McLachlan St, Fortitude Valley QLD 4006
Noosa Office & Showroom: 12 | 28 Lionel Donovan Dr, Noosaville QLD 4566