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Privacy Policy

Last Updated: 9 June 2026

1. Introduction
5. Overseas Disclosure

This Privacy Policy explains how Whirl Word ("Whirl Word", "we", "our", "us") collects, uses, shares, and protects your personal information when you use our review automation service (the "Service") or visit whirlword.com.au. We are committed to handling your personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Spam Act 2003 (Cth), and the Do Not Call Register Act 2006 (Cth). Whirl Word ABN: 69 733 430 830 Perth, Western Australia Email: bryce@eleuteri.net Phone: 0472 566 699. For any privacy enquiry, write to bryce@eleuteri.net and we will respond within a reasonable time.

Recipients may be located outside Australia (e.g. US). We ensure compliance with Australian Privacy Principle 8.

6. Data Retention
  • Account data: 90 days after closure.
  • Billing records: 7 years.
  • Support records: 3 years.
  • Customer contact data: for the duration of your account.
2. Personal Information We Collect
  • Account data: name, email, phone, business name.
  • Billing data: address, payment details tokens.
  • Business config: website, CRM credentials, customer lists.
  • Automatic usage data: IP, device info, session metrics.
  • Third party data: CRM integrations, Google Business reviews.
  • Customer data: names, emails, mobile numbers provided by you.
7. Cookies
  • Strictly necessary for security and session management.
  • Functional for user preferences.
  • Analytics for site performance measurement.
  • Marketing for ad attribution.
3. How We Use Personal Information
  • Account maintenance and Service delivery.
  • Triggering automation from CRM events.
  • Sending review requests and managed follow-ups.
  • Processing payments and accounting.
  • Analysing patterns to improve features and platforms.
  • Sending service announcements and security notices.
8. Security

Industry standard encryption (TLS), secure authentication, and monitoring. Breach notification handled via OAIC guidelines.

9. Your Rights
4. How We Share Personal Information

Right to access, edit, and correct information. Complaints about APP breaches can be submitted to bryce@eleuteri.net.

We do not sell personal data. Shared only with: service providers (hosting, SMS, payments), integration partners (Zapier, Google), or when required by law or during business transfers.

11. SMS & Email

Messages clearly identify sender and provide functional unsubscribe mechanisms per Australian law.

13. Contact

Whirl Word ABN: 69 733 430 830 Perth, Western Australia. bryce@eleuteri.net | 0472 566 699 | whirlword.com.au

10. Complaints

If you believe we have handled your personal information in a way that does not comply with the Privacy Act or the Australian Privacy Principles, you can lodge a complaint with us at:

bryce@eleuteri.net

We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

  • Website: www.oaic.gov.au

  • Phone: 1300 363 992

  • GPO Box 5218, Sydney NSW 2001

12. Changes to This
Privacy Policy

We may update this Privacy Policy from time to time. If a change is material, we will notify you by email before it takes effect. Minor changes (clarifications, corrections, contact details) take effect when posted. The "Last updated" date at the top of this page reflects the most recent revision.

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