Privacy Policy

1. Who we are

This website is operated by Dan Leman, trading as Polaris Performance Marketing (ABN [ABN]), of New South Wales, Australia ("Polaris", "we", "us" or "our").

We are the entity responsible for the personal information collected through this website. For the purposes of the EU and UK General Data Protection Regulation, we act as the "controller" of that information.

We handle personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth), and, where they apply to you, the GDPR and applicable United States state privacy laws.

You can reach us at any time at [email protected].

2. Scope of this policy

This policy applies to polarisperformancemarketing.com and to enquiries you make through it, including booking a call with us.

It does not cover the handling of data inside advertising accounts we manage for clients under a separate services agreement. Where we operate a client's advertising account, we do so as a service provider to that client, and the client's own privacy policy governs the personal information of that client's customers.

3. Information we collect

Information you give us

You do not have to give us any personal information to browse this website. If you choose to book a call or contact us, we may collect:

• your name;
• your email address and, if you provide it, your phone number;
• your business name, website and role;
• information you volunteer about your business — for example your current advertising spend, revenue range, offer, or the problem you want solved; and
• the content of any emails, messages or booking-form answers you send us.

Please do not send us sensitive information (such as health information, government identifiers, or financial account details) through this website. We do not ask for it and do not need it.

Information collected automatically

When you visit this website, we and our analytics and advertising providers may automatically collect:

• your IP address and approximate location derived from it (typically city or region level);
• your device type, operating system, browser type and screen size;
• the pages you view, the time and duration of your visit, and how you interact with the page (for example, scrolling or clicking a booking button);
• the website, ad or link that referred you to us; and
• cookie and device identifiers.

4. Cookies and tracking technologies

Cookies are small text files stored on your device. We also use similar technologies such as tracking pixels, tags, SDKs and local storage. We refer to all of these as "cookies" below.

We and third-party vendors, including Google and Meta, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as advertising cookies) together to inform, optimise and serve ads based on your past visits to this website, and to report how our ad impressions, other uses of ad services, and interactions with those ad impressions and ad services relate to visits to this site.

The categories of cookies used on this site are:

You can control cookies through your browser settings — most browsers let you delete existing cookies, block future ones, or warn you before one is set. Blocking cookies may affect how parts of this website work. Platform-specific opt-outs are listed in section 12.

5. Meta (Facebook and Instagram)

We use the Meta Pixel and may use the Meta Conversions API on this website. These are advertising and measurement tools provided by Meta Platforms, Inc. and Meta Platforms Ireland Limited.

When you visit this site, these tools may send Meta information including the pages you viewed, the actions you took (such as clicking to book a call), your IP address, browser and device information, and cookie identifiers. Where you have given us your email address, a version of it that has been hashed — converted into an irreversible string of characters — may also be sent so that Meta can measure whether an enquiry came from one of our ads.

Meta may match this information to a Facebook or Instagram account if you have one. We use it to:

• measure how our ads perform and how many enquiries they generate;
• show our ads to people who have visited this website (remarketing); and
• build audiences of people who resemble our existing enquirers.

We do not receive from Meta, and cannot see, your individual Facebook or Instagram profile through these tools. We see aggregated reporting.

Meta's handling of this data is governed by its own Privacy Policy. In respect of some of this processing, we and Meta act as joint controllers under the GDPR, on the terms of Meta's Controller Addendum. You can control the ads you see and how Meta uses data about you at facebook.com/adpreferences and Meta Accounts Center.

6. Google Analytics and Google Ads

Google Analytics 4

We use Google Analytics 4, provided by Google LLC, to understand how visitors use this website. Google Analytics sets cookies and collects information such as your IP address, pages viewed, session duration, approximate location, device and browser. This information is used to produce reports about site usage.

You can prevent Google Analytics from collecting your data by installing the Google Analytics Opt-out Browser Add-on.

Google Ads, remarketing and conversion tracking

We use Google Ads conversion tracking and remarketing tags. These let us measure which ads produce enquiries, and show our ads to you on Google Search, YouTube, and websites in the Google Display Network after you have visited this site.

Google's use of information collected on this site is described in How Google uses information from sites or apps that use our services and in the Google Privacy Policy.

You can opt out of personalised advertising from Google at Google Ads Settings, and control the data Google holds about you at myaccount.google.com.

This website also loads fonts from Google Fonts. When it does, your IP address is transmitted to Google in order to serve the font files.

7. Other service providers

Each of these providers handles your information under its own privacy policy. We only give them what they need to perform their function for us.

8. How we use your information

We use personal information to:

• respond to your enquiry and schedule, prepare for and conduct a call with you;
• assess whether we and your business are a fit to work together;
• provide, and where relevant invoice for, our services;
• measure and improve the performance of our advertising, including attributing enquiries to the ad, campaign or channel that produced them;
• show our advertising to people who have visited this website, and to audiences that resemble our enquirers;
• understand how this website is used and improve it;
• maintain the security and integrity of the website and prevent fraud and abuse; and
• comply with our legal and record-keeping obligations.

We do not sell your personal information for money. We do not share your enquiry details with unrelated third parties for their own marketing.

9. Legal bases (EEA and UK)

If you are in the European Economic Area or the United Kingdom, we rely on the following legal bases:

• Consent — for analytics and advertising cookies, and for marketing emails. You may withdraw consent at any time.
• Performance of a contract, or steps taken at your request before entering into one — to respond to your enquiry, conduct a call and deliver services.
• Legitimate interests — to operate and secure the website, to understand and improve our marketing, and to grow our business, where those interests are not overridden by your rights.
• Legal obligation — to keep records we are required to keep.

10. Who we disclose information to

We may disclose personal information to:

• the service providers listed in section 7, to perform functions on our behalf;
• our professional advisers, such as accountants and lawyers, where reasonably required;
• a purchaser or successor, if our business is sold or restructured, subject to this policy continuing to apply; and
• a court, regulator or law enforcement body, where we are required or authorised by law to do so.

11. Overseas disclosure

Several of our providers are located outside Australia, principally in the United States and Ireland. When you use this website or contact us, your personal information will be disclosed to, stored in, or accessed from those countries.

Privacy laws in those countries may not provide the same level of protection as Australian law. Where required, we rely on contractual protections such as the European Commission's Standard Contractual Clauses, and we take reasonable steps to ensure overseas recipients handle your information consistently with the Australian Privacy Principles.

12. Your advertising choices

You can limit or turn off interest-based advertising through the following:

• Google Ads Settings — control personalised ads from Google
• Google Analytics Opt-out Browser Add-on — stop Google Analytics collection
• Meta Ad Preferences — control the ads you see on Facebook and Instagram
• YourAdChoices (DAA) — multi-company opt-out, United States
• NAI Opt-out — Network Advertising Initiative members
• YourAdChoices Australia — Australian opt-out portal
• Your Online Choices — European opt-out portal

These opt-outs are stored in a cookie, so you will need to apply them again if you clear cookies, change browsers or change devices. Opting out does not stop you seeing ads — it stops them being tailored to you.

13. Your privacy rights

Australia

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us at [email protected] and we will respond within a reasonable period, ordinarily within 30 days. We may need to verify your identity first. If we refuse a request, we will tell you why in writing.

EEA and UK

If the GDPR applies to you, you have the right to access, rectify, erase, restrict processing of, and port your personal data, to object to processing based on legitimate interests or to direct marketing, and to withdraw consent at any time without affecting processing already carried out. You also have the right to lodge a complaint with your local supervisory authority.

14. US state privacy rights

If you are a resident of California or another US state with a comprehensive privacy law, you may have the right to know what personal information we collect and how we use it, to request deletion or correction, to obtain a portable copy, and to opt out of "sales" and of "sharing" for cross-context behavioural advertising, without being discriminated against for exercising those rights.

We do not sell personal information for money. However, our use of advertising cookies described in sections 5 and 6 may be treated as a "sale" or "share" under some of these laws. You can opt out using the links in section 12, by enabling a Global Privacy Control signal in your browser, or by emailing us.

15. Do Not Track and Global Privacy Control

Browsers may send a "Do Not Track" signal. There is no common industry standard for how sites should respond to it, and this website does not currently respond to Do Not Track signals. Where required by law, we treat a Global Privacy Control signal as a valid request to opt out of the sale or sharing of personal information.

16. How long we keep information

We keep enquiry and client correspondence for as long as needed for the purpose it was collected and then for as long as we are required to keep business records — generally seven years for records connected to a commercial engagement. Analytics and advertising data is retained according to the retention settings of the relevant platform, typically between 2 and 26 months. When information is no longer needed, we delete it or de-identify it.

17. Security

This website is served over HTTPS. We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure, including access controls, reputable providers and limiting the information we collect in the first place. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

18. Children

Our services are directed to business owners and are not intended for children. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.

19. Third-party links

This website links to third-party sites and services, including our booking calendar and social platforms. We are not responsible for their content or privacy practices. Read their privacy policies before giving them your information.

20. Changes to this policy

We may update this policy from time to time to reflect changes to our practices, technology or legal obligations. The current version is always available at this address, and the "last updated" date at the top shows when it was last changed. Material changes will be made prominent on this page.

21. Contact and complaints

For any privacy question, request or complaint, contact us:

We will acknowledge your complaint, investigate it and respond in writing, ordinarily within 30 days. If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner at oaic.gov.au or by phone on 1300 363 992. If you are in the EEA or UK, you may complain to your local data protection supervisory authority.