Privacy policy

Privacy Policy

Davie Group Trading (Australia) Pty Ltd (ABN 84 629 766 703), Davie Group Holdings Pty Ltd (CAN 646 762 370) and any subsidiary (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our website, in person, or through other means.

For individuals located in the European Economic Area (EEA), United Kingdom or Switzerland: Additional rights and protections apply to you under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (UK GDPR). Please refer to Appendix 1 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with GDPR and UK GDPR requirements.

For individuals located in California, please see our section on additional rights for Californian residents.

For individuals located in Canada, please see our section on dispute resolution for Canadian residents, including residents of Quebec.

Our Direct Marketing Program terms, Messaging Terms, Messaging Privacy Policy and any other terms available on our website will provide additional information (including details) on how we may use your Personal Information. In the event of inconsistency between this Privacy Policy and any other terms, this Privacy Policy shall prevail.

Quick Overview

We collect information you provide to us and information we gather when we interact with you
We use this information to provide our services and improve your experience
We protect your information using secure systems and processes
You have rights regarding your personal information, including access and correction rights

Information We Collect

Identity and Contact Details

Name, address, email address and phone number

Professional Details

Service related information

Payment and Transaction Details

Payment and transaction details for products and services you've purchased from us or enquiries about our products, your preferences for our services and your marketing preferences, and feedback and survey responses.

Digital Information

IP address and general location information derived from your IP address
Search and browsing behaviour
Website usage patterns
Cookie preferences

Recordings

Call recordings and message transcriptions
Records of meetings or message histories (including when you interact with any of our AI agents)
Records of our decisions in relation to any of your customer support requests

Professional Information (for Job Applicants and Workers)

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Information about your right to work in the relevant jurisdiction

How We Collect Personal Information

Directly from you when you: interact with us, contact us, or fill out forms.
Automatically when you: visit our website, use our technologies, or interact with our online services.
From third parties: service providers, business partners, public sources, government organisations, and organisations or people authorised by you.
From publicly available sources: such as ASIC and other regulatory bodies and professional networking sites such as LinkedIn.

Why We Collect, Hold, Use and Disclose Personal Information

We collect and use your personal information to run our business and provide our services as set out below.

Business Operations

To manage our relationship with you as a customer or supplier
To process and deliver our products and services
To handle your inquiries, support requests, and communications
To maintain accurate records for billing and administration
To verify your identity when required or permitted by law

Communication and Support

To respond to your questions and support requests
To communicate important updates about our products
To handle inquiries made through our website or platforms
To manage your participation in surveys, feedback sessions, or events

Service Improvement

To conduct analytics and market research
To improve our business operations
To develop and enhance our platform and sales channels
To understand how our products are used

Marketing and Promotions

To send you promotional information about our products and events
To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions, and special offers
To provide additional benefits to our customers

Employment Purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment records

Legal and Compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business records
To fulfill regulatory requirements or reporting obligations
To protect our legal rights and interests or as authorised by law

Our Disclosures of Personal Information to Third Parties

We may disclose personal information to:

Service providers such as IT service providers, data storage providers, web hosting and server providers, payment processors, marketing and advertising providers and analytics providers. This includes but is not limited to:

Shopify, which powers our online store – you can read more about how Shopify uses your personal information here.
Klaviyo, which manages our email marketing and tracks email engagement
Gorgias and Narvar, which process our customer data when provided directly through our customer portals

Professional advisers such as Bankers, Auditors, Insurers and insurance brokers, and legal advisers

Business partners including our existing and potential business partners or contractors

Legal and regulatory bodies such as courts and tribunals, regulatory authorities as required for regulatory purposes, and law enforcement officers

Corporate transactions: If we merge with or are acquired by another company, or sell our business assets, your information may be disclosed to our advisers, potential purchaser's advisers and may be included in transferred assets.

Other parties such as third parties you have authorised, emergency services when necessary, and any other parties as required or permitted by law

Overseas Disclosure

Storage and Access

We store your personal information in Australia. However, your information may be accessed from or transferred to locations outside Australia in these circumstances:

When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions
Where you are a customer based in the United Kingdom, we may store your data in the United Kingdom, but our third parties and head office may store, transfer or access personal data outside of the United Kingdom. Please see Appendix 1 for our full disclosure to members of the UK GDPR.

Our Approach to Overseas Disclosure

Before disclosing your personal information in jurisdictions other than Australia and the United Kingdom, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards, and by monitoring how recipients handle your information.

Your Privacy Rights and Choices

Providing Information

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don't want to provide information and we will let you know when information is required versus optional.

Minors

We do not participate in the active collection of information of individuals under the age of 14, though we may inadvertently come into possession of such Personal Information. If you are the parent or legal guardian of a person under the age of 14 and believe that we have collected Personal Information of that minor and wish to request deletion or amendment of such information, please contact us.

Access to Your Information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction Rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing Communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

How to Contact Us About Your Rights or to Make a Complaint

Step 1: Contact Our Privacy Officer

Email: help@theoodie.com
Post: Davie Group, 39 Orsmond Street, Hindmarsh, SA, 5007, Australia

What to include: Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.

Step 2: Our Response

We will:

Verify your identity before processing your request
Investigate thoroughly (for complaints) or process your request (for rights)
Respond to you in writing within reasonable timeframes and as required by law
Explain what actions we will take and keep you updated on progress
Not charge you for making a request (except for reasonable access fees if applicable)
Help you understand and exercise your rights

Step 3: If You're Not Satisfied (Complaints Only)

If you're not satisfied with our response to your complaint, you can ask for a review by our senior management, or contact external bodies:

Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)
New Zealand residents: Office of the New Zealand Privacy Commissioner
UK residents: Information Commissioner's Office (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, helpline: 0303 123 1113, website: ico.org.uk/make-a-complaint)

You don't have to contact us first before going to the ICO, but we'd appreciate the opportunity to try to resolve your concerns directly with you.

This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.

Additional Rights for Californian Residents

If you are a California resident, you have additional rights under California Civil Code Section 1798.83. You may request information about our disclosure of Personal Information to third parties for their direct marketing purposes.

To make such a request, please contact us using our contact form. We will respond to your request within the timeframes required by California law.

Please note we do not sell your Personal Information to third parties. For the avoidance of doubt, we do not consider a sale of the business or any single subsidiary of the business and its relevant assets (including contact lists) as the sale of your Personal Information unless such sale is solely for the purpose of the purchaser acquiring Personal Information of our customers.

Additional Rights for Canadian Residents

Except for residents of Canada, we generally do not rely on consent as a legal basis for processing your Personal Information, although we will obtain your consent where your consent is required under applicable law. If you are a resident of Canada, we will rely on your consent as the legal basis for processing your Personal Information and you may withdraw consent at any time by contacting us.

Protecting Your Information

We use multiple layers of security to protect your information.

Technical Safeguards

Enterprise-grade encryption for data storage and transmission
Regular security testing and monitoring
Automated threat detection systems

Operational Security

Staff training on security and privacy
Strict access controls based on job requirements
Regular security audits and incident response procedures testing

Physical Security

Secure premises with controlled access
Secure disposal of physical documents
Equipment security protocols

Public Information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

How Long We Keep Your Information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law. When we no longer need it, we securely destroy or de-identify it.

Cookies and Analytics

What We Use

We use cookies, tracking pixels, and similar technologies on our website and in our emails to improve your experience and our services. You can view details on all our cookies at any time on our Cookie Declaration Page.

Cookies

Small text files stored on your device
Help remember your preferences
Enable certain website functions
Make your interactions with our website more efficient

Tracking Pixels

Tiny, invisible images in web pages and emails
Help us understand how you interact with our content
Allow us to measure email engagement
Enable more relevant content delivery

How We Use These Technologies

Essential Functions

Remember your login status
Maintain your session security
Store your preferences
Enable core website features

Analytics and Performance

Understand how our website is used
Measure page views and traffic
Analyse user navigation patterns
Identify areas for improvement

Personalisation

Remember your preferences
Tailor content to your interests
Improve your browsing experience
Provide relevant recommendations

Your Control

You can manage these technologies by:

Adjusting your browser settings to block or delete cookies
Using privacy-focused browser extensions
Configuring your email client to block images
Using our cookie preference settings

Note: Blocking all cookies may affect website functionality and your user experience. Our Website responds to Do Not Track requests from our cookie consent manager, which appears when you first visit our site. You can manage your tracking preferences through this tool at any time.

Google Analytics

We use Google Analytics to understand how people use our website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta Advertising Tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our website or app. You can manage whether we connect information from our website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

When You Sign In with Another Account (like Facebook or Google)

What We Collect

When you use single sign-on to connect with us, we'll receive personal information from that provider based on your privacy settings with them. This may include your name, username, profile picture, and other details you've chosen to share.

How We Use It

We use this information to create your profile on our platform and give you access to our services.

Your Rights

If you connected through Facebook, you can ask us to delete the personal information we received from Facebook. To do this, email us at our contact address below and tell us what information you'd like deleted. If we can't delete certain information, we'll explain why.

Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How We Use AI

We may use AI technologies to:

Conduct analysis and data processing
Generate and modify content
Improve and optimise our services and operations
Automate routine tasks and communications, including our AI Chatbot for simple customer enquiries
Personalise your experience with our services
Support quality assurance processes
Assist with customer support and queries

Our use of AI technology does not extend to any automated decision making processes.

Data Protection and Security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your Rights and Our Commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

We'll inform you if AI is used to make decisions that may significantly affect you, though we do not engage with AI decision making tools at this time
We maintain human oversight and review of our AI processes
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

Amendments

We may update this policy at any time by posting the revised version on our website. We recommend that you review our website regularly to stay current with any policy changes.

Last Amendment: 01 April 2026.

Appendix 1: Additional Rights and Information for Individuals Located in the EU or UK

Under the General Data Protection Regulation (EU) 2016/679 (GDPR) and, for UK residents, the UK General Data Protection Regulation (as incorporated into UK law) and the Data Protection Act 2018 (together, the European Data Protection Laws), individuals located in the EU and UK have additional rights which apply to their personal information. Personal information under these Data Protection Laws is often referred to as personal data and is defined as information relating to an identified or identifiable natural person. This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as the lawful basis on how we process the personal information of individuals located in the EU and UK.

Legal Bases for Processing Personal Information

European Data Protection Law requires us to have proper legal reasons for using your personal data. We can only use your information when we have one or more of these legal bases:

Consent – You have clearly agreed to us using your personal data for a specific purpose.
Performance of a contract – We need to use your information to fulfil a contract with you, or because you've asked us to do something before entering into a contract.
Legal duty – We must use your information to comply with the law.
Vital interests – We need to use your information to protect someone's life.
Public interest – We need to use your information to perform a task in the public interest or carry out official functions that have a clear legal basis.
Legitimate interests – We have a genuine business reason to use your information, or a third party does, but only if this doesn't unfairly override your rights and interests. Where we rely on legitimate interests as our legal basis, we have conducted balancing tests to ensure our interests do not override your fundamental rights and freedoms. These assessments consider: the nature of our legitimate interest; the impact on you; any safeguards we can implement; your reasonable expectations; and the broader context of our relationship.

Note that we may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal basis we are relying on to process your personal data.

The full purposes of processing are set out above under "Why we collect, hold, use and disclose personal information." The legal basis for this processing is set out below.

Purpose: Business operations
Legal basis: Performance of a Contract; Legal Duty (for billing and record-keeping requirements); Legitimate interests
Types of information: Identity and contact details; Service related information; Digital information

Purpose: Communication and support
Legal basis: Legitimate interests
Types of information: Identity and Contact Data; Digital Information

Purpose: Service improvement
Legal basis: Legitimate interests
Types of information: Digital Information

Purpose: Marketing and promotions
Legal basis: Legitimate interests
Types of information: Identity and Contact Data; Digital Information

Purpose: Employment purposes
Legal basis: Legitimate interests; Legal Duty; Consent; Performance of a Contract
Types of information: Identity and Contact Data; Professional Data

Purpose: Legal and compliance
Legal basis: Legal Duty
Types of information: All relevant personal information

Overseas Transfers

Your information may be transferred to locations outside the EU or United Kingdom in these circumstances:

When required as part of providing our services
When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions
When required by law or legal proceedings

Our approach to overseas transfers: When we transfer your personal data outside the EU or United Kingdom, we ensure it receives appropriate protection by:

Only transferring your information to countries that European Data Protection Laws recognise as providing adequate protection for personal information
Putting in place a contract with the third party that means they must protect personal data to the same standards as the EU or UK
Transferring personal data to organisations that are part of specific agreements on cross-border data transfers with the EU or UK

Data Retention

How long we keep your information

We only keep your personal data for as long as we need it to:

Provide our services to you
Meet our legal, tax, accounting or regulatory obligations
Handle any complaints or legal issues that may arise

We may keep your information for longer periods if:

You make a complaint that we need to investigate or respond to
We reasonably believe legal action involving our relationship with you might occur
The law requires us to keep it for specific timeframes

How we decide retention periods

When determining how long to keep your information, we consider:

How much information we have and how sensitive it is
The risk of harm if the information was accessed without permission
Whether we can achieve our purposes in other ways
What legal, regulatory, tax or accounting rules require
The nature of our relationship with you and the services we provide

What happens when we no longer need your information

Once we no longer need your personal data, we will securely delete or destroy it in accordance with our data retention policies and legal requirements. You can request information about retention periods for your data and ask for early deletion where legally possible.

Rights in Relation to Personal Data

In addition to the rights set out in our policy above, you also have the following rights.

Right to Erasure
You can request deletion of your personal data in certain limited circumstances as set out in European Data Protection Law, such as where the data is no longer necessary or has been unlawfully processed. This right is not absolute and we may be required or entitled to retain your data for legal, regulatory or legitimate business reasons.

Right to Restrict Processing
You can ask us to suspend processing where:

You contest the accuracy of the data
Processing is unlawful but you don't want erasure
We no longer need the data but you need it for legal claims
You've objected to processing pending verification of our legitimate grounds

Right to Data Portability
Where technically feasible, you can receive your personal data in a structured, commonly used format or have it transmitted to another controller where:

Processing is based on consent or contract
Processing is automated

Right to Object
You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds.

Right to Withdraw Consent
Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.

Contact Details for GDPR Matters

For any questions about how we process your personal information under GDPR, please contact us at:

Email: help@theoodie.com

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