Privacy Policy

Privacy Policy

SE2 Pty Ltd (ACN 631 168 673), trading as ThinkFusion                                                                        

Version 2.0  ·  Effective 24 September 2026

 

This Privacy Policy explains how we collect, hold, use and disclose personal information when you visit www.thinkfusion.au (the Website) or engage our Consultancy Services and Managed Services.

In this policy, when we say you or your, we mean you and any entity you are authorised to represent. When we say we, us or our, we mean SE2 Pty Ltd (ACN 631 168 673, ABN 59 631 168 673), trading as ThinkFusion.

Personal information has the meaning given in the Privacy Act 1988 (Cth) (Privacy Act). The Australian Privacy Principles set out in Schedule 1 of the Privacy Act are referred to as the APPs.

For any privacy query, please email: privacy@thinkfusion.au.

IMPORTANT NOTICES

We draw your attention to the fact that:

• we handle personal information in accordance with the APPs whether or not the Privacy Act applies to us by reason of our turnover, under clause 2.2;

• where we host or administer a system for you, the personal information in that system remains yours and we handle it on your instructions, under clause 6;

• we do not make decisions about you by automated means, under clause 11; and

• you can ask for access to, or correction of, the personal information we hold about you, and you can make a complaint, under clauses 18 and 22.

1   Introduction

1.1  We respect your privacy and are committed to protecting the personal information we hold.

1.2  This policy explains what we collect, why we collect it, who we share it with, how we protect it, and how you can access, correct or complain about it.

1.3  By using the Website or engaging our services, you acknowledge that we collect and handle personal information as described in this policy.

2   Who We Are and How This Policy Applies

2.1  SE2 Pty Ltd (ACN 631 168 673, ABN 59 631 168 673) trades as ThinkFusion. We are based in New South Wales, Australia.

2.2  We handle personal information in accordance with the Privacy Act and the APPs, and we apply this policy whether or not the Privacy Act applies to us by reason of our annual turnover. Where we deliver services to a client who is itself bound by the Privacy Act, we handle personal information to the standard that client’s own obligations require.

2.3  This policy sits alongside our Terms of Use and our Terms and Conditions, both published on the Website. Where you engage us for services, clause 3 of our Terms of Use explains which documents govern that engagement.

3   Scope of this Policy

3.1  This policy applies to personal information we collect through:

(a)  the Website, including online forms and downloadable materials;

(b)  email, telephone and other correspondence;

(c)  the platforms and systems we use to deliver Managed Services;

(d)  business consulting and advisory engagements; and

(e)  third party systems and integrations we use to deliver our services.

3.2  It applies to clients, prospective clients, Website visitors, suppliers, contractors and any other individual whose personal information we handle.

4   Information We Collect

4.1  Personal information we may collect includes your full name, job title and business name, your contact details, business or company registration details, billing and payment details, and identification details where these are needed to set up or verify an account.

4.2  When you visit the Website or use a system we administer, we may automatically collect technical information including your IP address and device identifiers, browser type, version and operating system, pages visited and session duration, and information collected through cookies and similar technologies described in clause 12.

4.3  We collect only the personal information that is reasonably necessary for our business functions and activities.

5   Sensitive Information

5.1  Sensitive information has the meaning given in the Privacy Act. It includes health information, biometric information, and information about a person’s racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record or membership of a professional or trade association or union.

5.2  We collect sensitive information only where you have consented to the collection, or where the collection is required or authorised by law.

5.3  We do not use or disclose sensitive information for direct marketing.

5.4  Where an engagement involves us accessing systems that contain sensitive information about other individuals, clause 6 applies to that information.

6   Client Data We Handle on Your Behalf

6.1  In delivering Consultancy Services and Managed Services we may access, host or administer systems that contain personal information about your staff, your customers, your clients or other individuals (Client Data).

6.2  For Client Data, you are the entity that decides what is collected, why it is held and who may access it. We handle Client Data on your instructions, and only for the purpose of delivering the services set out in the Quote.

6.3  We will not use Client Data for our own purposes, will not disclose it other than as clause 10 permits, and will not retain it after an engagement ends except as clause 14 provides.

6.4  If an individual asks us to give access to, correct or delete Client Data, we will refer that request to you rather than action it ourselves, unless you have instructed us otherwise in writing.

6.5  If we become aware of a data breach affecting Client Data, we will notify you without undue delay so that you can meet your own obligations. Clause 20 sets out what we do about a breach affecting information we hold in our own right.

6.6  Nothing in this clause makes us responsible for your compliance with the Privacy Act, or for any other obligation you owe in relation to Client Data.

7   How We Collect Information

7.1  We collect personal information:

(a)  directly from you when you contact us, complete a form, or engage us;

(b)  automatically through Website analytics tools;

(c)  from third party service providers, including software vendors and IT partners;

(d)  from publicly available business sources and professional platforms; and

(e)  during service delivery, where system access is required to deliver Consultancy Services or Managed Services.

7.2  Where it is reasonable and practicable, we collect personal information directly from you. If we collect it from someone else, we will take reasonable steps to tell you.

8   Anonymity and Pseudonymity

8.1  You may deal with us anonymously or under a pseudonym where it is lawful and practicable to do so, for example when making a general enquiry.

8.2  We will usually need your name and contact details to provide services, issue a valid tax invoice, or administer a system on your behalf.

9   Why We Collect Information

9.1  We collect personal information to:

(a)  provide and manage our Consultancy Services and Managed Services;

(b)  process payments, invoices and client accounts;

(c)  communicate with you, respond to enquiries and provide support;

(d)  analyse and improve our services;

(e)  meet our contractual, legal and regulatory obligations; and

(f)  send you service updates and information relevant to your business, subject to clause 19.

9.2  If you do not provide the personal information we ask for, we may be unable to provide our services, administer your account, issue a valid tax invoice, or respond to your enquiry.

10   Use and Disclosure of Personal Information

10.1  We use and disclose personal information for the purposes set out in clause 9, for related purposes you would reasonably expect, and where the Privacy Act otherwise permits.

10.2  We may disclose personal information to:

(a)  our employees, contractors and subcontractors assisting with service delivery;

(b)  IT infrastructure, hosting and cloud service providers;

(c)  payment processors and accounting platforms;

(d)  legal, regulatory or compliance authorities where required or authorised by law;

(e)  our professional advisers, including legal and accounting advisers; and

(f)  a provider you nominate to take over services from us, in connection with a transition or handover under clause 13 of our Terms and Conditions. We may require that provider to give a written confidentiality undertaking first.

10.3  Where we disclose personal information to a service provider, we require that provider to handle it consistently with this policy.

10.4  We do not sell, rent or trade personal information.

11   Automated Decision Making

11.1  From 10 December 2026, APP 1.8 requires a privacy policy to disclose where personal information is used in computer programs that make, or substantially assist in making, decisions that could reasonably be expected to significantly affect an individual’s rights or interests.

11.2  We do not make decisions of that kind by automated means. No decision that significantly affects your rights or interests is made solely by a computer program, or substantially assisted by one.

11.3  We use automation and artificial intelligence tools to assist with drafting, analysis, scheduling and routine administration. A person reviews the output before it is acted on, and those tools are not used to make decisions about you.

11.4  If this changes, we will update this policy to state the kinds of personal information used, the kinds of decisions made solely by automated means, and the kinds of decisions substantially assisted by automated means.

12   Cookies and Analytics

12.1  The Website uses cookies and similar technologies. These include essential cookies required for basic site functionality, analytics cookies that help us understand how the Website is used, and performance cookies that improve speed and responsiveness.

12.2  We use analytics tools to collect aggregated and de-identified usage data for performance monitoring and marketing insight.

12.3  You can disable cookies through your browser settings. Some parts of the Website may not work properly if you do.

13   Data Storage and Security

13.1  We take reasonable administrative, physical and technical steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

13.2  Those steps include encrypted communications, role based access controls, secure cloud storage, multi factor authentication where available, and regular updates, backups and vulnerability testing.

13.3  No method of transmission or storage is entirely secure. While we take reasonable steps, we cannot guarantee the security of information transmitted to us over the internet.

14   Data Retention

14.1  We keep personal information only for as long as it is needed for the purpose it was collected, to meet our legal and record keeping obligations, or to establish or defend a legal claim.

14.2  As a guide, we retain:

(a)  enquiry and contact records for two years from the date of last contact;

(b)  client engagement records, contracts and related correspondence for seven years after the engagement ends;

(c)  financial and billing records for seven years, as Australian tax and corporations law requires; and

(d)  Client Data held in systems we administer, in accordance with clause 13 of our Terms and Conditions, which provides for deletion 60 days after handover is complete.

14.3  When personal information is no longer needed, we securely destroy it or de-identify it.

15   Overseas Disclosure

15.1  Some of the platforms we use to deliver our services store or process information outside Australia, including in the United States, the European Union, the United Kingdom, Singapore and New Zealand.

15.2  Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure that the recipient handles it in a way consistent with the APPs, as APP 8 requires.

15.3  Where you instruct us to use a particular platform, or where a platform you already use stores data overseas, we act on that instruction and the arrangements of that platform apply.

15.4  We will tell you on request which platforms hold information relevant to your engagement, and where they store it.

16   Government Identifiers

16.1  We do not adopt a government related identifier, such as a tax file number, Medicare number or driver licence number, as our own identifier for you. We use or disclose a government related identifier only where the Privacy Act permits.

17   Third Party Links and Services

17.1  The Website may link to external websites or integrate with third party tools. We are not responsible for the privacy practices or content of those sites and tools.

17.2  We encourage you to review the privacy policy of any third party before providing personal information to it.

18   Access and Correction

18.1  You may ask us for 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. Requests go to privacy@thinkfusion.au.

18.2  We will respond within 30 days of receiving your request.

18.3  There is no charge for making a request. We may charge a reasonable, non-excessive fee for giving access, and we will tell you the amount before we proceed.

18.4  If we refuse access or correction, we will give you written reasons and tell you how to complain under clause 22. We may refuse only on a ground set out in the Privacy Act.

18.5  For Client Data, clause 6.4 applies.

19   Direct Marketing

19.1  We may send you marketing or service communications we believe are relevant to your business, consistent with the Privacy Act and the Spam Act 2003 (Cth).

19.2  You may opt out at any time by using the unsubscribe link in any email, or by contacting privacy@thinkfusion.au. We will action your request within a reasonable time and at no cost to you.

19.3  You may also ask us to tell you the source of information we used to contact you.

19.4  We do not use sensitive information for direct marketing, and we do not provide personal information to other organisations for their own marketing.

20   Data Breach Notification

20.1  If we suspect a data breach that may result in serious harm, we will take immediate steps to contain it and will complete an assessment within 30 days of becoming aware of it.

20.2  Where the breach is an eligible data breach, we will notify the affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

20.3  Where the breach affects Client Data, clause 6.5 applies and we will notify you so that you can meet your own notification obligations.

21   Children and Young People

21.1  The Website and our services are intended for business and professional use, and are not directed at individuals under 18.

21.2  We do not knowingly collect personal information from an individual under 18. If we become aware that we have, we will delete it promptly.

22   Complaints

22.1  If you believe we have breached the APPs or this policy, please contact our Privacy Officer at privacy@thinkfusion.au, setting out the details of your concern.

22.2  We will acknowledge your complaint within five business days and give you a written response within 30 days.

22.3  If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at www.oaic.gov.au, by telephone on 1300 363 992, or by writing to GPO Box 5288, Sydney NSW 2001.

23   Changes to this Policy

23.1  We may update this policy from time to time. The current version, with its version number and effective date, is published at www.thinkfusion.au/privacy. We retain superseded versions and will provide a copy on request.

23.2  A change applies from the date the updated version is published. A change does not alter how we handle personal information already collected, where that would be inconsistent with the version of this policy in force when it was collected.

23.3  Where a change materially affects how we handle your personal information, we will take reasonable steps to tell you.

24   Contact Us

For any privacy enquiry, access request or complaint, please contact:

Privacy Officer

SE2 Pty Ltd (ACN 631 168 673, ABN 59 631 168 673), trading as ThinkFusion

Email: privacy@thinkfusion.au

Website: www.thinkfusion.au

Registered in New South Wales, Australia

25   Governing Law

25.1  This policy is governed by the laws of New South Wales, Australia.

25.2  Any dispute arising from or related to this policy is subject to the exclusive jurisdiction of the courts of New South Wales.