Lejacie Pty Ltd
ACN 692 946 302 | ABN 92 692 946 302

1. INTRODUCTION AND COMMITMENT

1.1 Lejacie Pty Ltd ("Lejacie", "we", "our", "us") is committed to protecting your personal information in accordance with:

• Privacy Act 1988 (Cth)

• Australian Privacy Principles (APPs)

• Privacy and Data Protection Act 2014 (Vic)

• Health Records Act 2001 (Vic) where applicable

• General Data Protection Regulation (GDPR) for EU residents

1.2 This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information.

1.3 By engaging our services or using our website, you consent to the collection and use of your information as described in this policy.

2. DEFINITIONS

2.1 "Personal Information" means information or opinion about an identified individual or reasonably identifiable individual, whether true or not, and whether recorded in material form or not.

2.2 "Sensitive Information" includes information about racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal records, health information, or biometric information.

3. INFORMATION WE COLLECT

3.1 Personal Information Collected Directly
We may collect:

• Full name and professional title

• Contact details (email, phone, postal address)

• Organisation/employer details

• Professional background and experience

• Educational qualifications

• LinkedIn profile and professional social media

• Content of communications with us

• Session notes and strategic documents

• Professional goals and challenges discussed

• Billing and payment information

• Australian Business Number (ABN) if applicable

3.2 Sensitive Information
We do not actively collect sensitive information unless:

• You voluntarily provide it

• It's necessary for service delivery

• We have your explicit consent

• Collection is required or authorized by law

When collected, sensitive information receives additional protection under APPs.

3.3 Information Collected Automatically
When you visit our website:

• IP address and device information

• Browser type and version

• Pages visited and time spent

• Referring website

• Click-through data

• Location data (country/state level only)

3.4 Cookies and Tracking Technologies
We use:

• Essential cookies (website functionality)

• Analytics cookies (Google Analytics)

• No third-party advertising cookies

• No cross-site tracking

You can disable cookies through browser settings, though this may affect functionality.

4. HOW WE COLLECT INFORMATION

4.1 We collect information through:

• Direct provision when you contact us

• Service agreements and intake forms

• Consultation and strategy sessions

• Workshop attendance records

• Website contact forms

• Email and phone communications

• Social media interactions

• Payment processing systems

• Professional referrals (with consent)

5. PURPOSE OF COLLECTION AND USE

5.1 Primary Purposes
We use your information to:

• Provide professional development and consulting services

• Develop customized strategies and materials

• Schedule and manage appointments

• Process payments and maintain accounts

• Communicate about service delivery

• Provide CPD documentation

• Maintain professional service records

5.2 Secondary Purposes
With consent, we may use information to:

• Send relevant professional resources

• Notify you of new services

• Request feedback and testimonials

• Improve service quality

• Conduct business analysis

5.3 We will NOT use your information for:

• Sale to third parties

• Unrelated marketing

• Purposes beyond reasonable expectations

• Any purpose without lawful basis

6. DISCLOSURE OF INFORMATION

6.1 We may disclose information to:

• Employees and contractors bound by confidentiality

• Professional advisors (accountants, lawyers)

• Payment processors (Stripe, PayPal)

• Cloud storage providers (with security agreements)

• Government agencies when legally required

6.2 Legal Disclosure Requirements
We may disclose without consent where:

• Required by law or court order

• Authorized under Privacy Act exceptions

• Necessary to prevent serious threat to safety

• Required for law enforcement

6.3 International Transfers
Some service providers operate overseas. We ensure:

• Compliance with APP 8 (cross-border disclosure)

• Providers meet Australian privacy standards

• Contractual privacy protections are in place

• You're informed of transfer locations

Primary locations: United States (cloud storage), European Union (some tools)

7. DATA SECURITY

7.1 Security Measures Include:

• SSL encryption for data transmission

• Encrypted cloud storage (AES-256)

• Two-factor authentication on accounts

• Regular security updates and patches

• Limited access controls

• Secure disposal procedures

• Incident response procedures

• Regular security audits

7.2 Data Breach Response
In case of eligible data breach:

• Assessment within 72 hours

• Notification to affected individuals if required

• Notification to OAIC if criteria met

• Remediation measures implemented

• Documentation per Notifiable Data Breaches scheme

8. DATA RETENTION AND DISPOSAL

8.1 Retention Periods:

• Client records: 7 years from last service (tax/legal requirements)

• Financial records: 7 years (ATO requirements)

• Session materials: 3 years or per client agreement

• Marketing contacts: Until consent withdrawn

• Website analytics: 26 months

8.2 Secure Disposal:

• Electronic files: Permanent deletion from all systems

• Physical documents: Cross-cut shredding

• Backup systems: Secure overwriting

9. YOUR RIGHTS UNDER AUSTRALIAN PRIVACY LAW

9.1 You have the right to:

• Access personal information we hold

• Request correction of inaccurate information

• Request deletion (subject to legal requirements)

• Withdraw consent for optional uses

• Complain about privacy breaches

• Request information about overseas disclosures

• Opt-out of direct marketing

• Request anonymity/pseudonymity where lawful

9.2 Access Requests
To request access:

• Submit written request to info@lejacie.com

• Include identity verification

• Specify information sought

• We respond within 30 days

• No charge for simple requests

• Complex requests may incur reasonable fees

9.3 Correction Requests
If information is inaccurate, incomplete, or outdated:

• Submit correction request with evidence

• We investigate within 30 days

• If refused, you may request notation of claim

10. SPECIFIC PROFESSIONAL OBLIGATIONS

10.1 Session Confidentiality
All consultation content is confidential except:

• With your written consent

• Where legally required

• To prevent serious harm

• For professional supervision (de-identified)

10.2 Professional Standards
We maintain confidentiality per:

• Professional consulting standards

• Contractual obligations

• Ethical guidelines for business consultants

11. DIRECT MARKETING

11.1 We only send marketing with consent
11.2 All marketing includes unsubscribe option
11.3 Opt-out requests processed within 5 business days
11.4 We don't sell/rent contact lists

12. VULNERABLE PERSONS

12.1 Additional protections apply for:

• Persons under 18 (parental consent required)

• Persons with diminished capacity

• Vulnerable professional situations

13. COMPLAINTS AND DISPUTES

13.1 Internal Complaints
Step 1: Contact our Privacy Officer at info@lejacie.com
Step 2: Written response within 14 days
Step 3: Internal review if unsatisfied

13.2 External Complaints
You may complain to:

• Office of the Australian Information Commissioner (OAIC)
  Phone: 1300 363 992
  Website: www.oaic.gov.au

• Consumer Affairs Victoria
  Phone: 1300 55 81 81

14. PRIVACY OFFICER CONTACT

Privacy Officer
Lejacie Pty Ltd
Email: info@lejacie.com
Phone: [Your phone if you want to include]
Mail: [Your postal address if applicable]
Victoria, Australia

Response timeframe: 5-7 business days

15. CHANGES TO THIS POLICY

15.1 We may update this policy to reflect:

• Legal requirements

• Technology changes

• Business practices

• Feedback

15.2 Material changes notified via email
15.3 Continued use constitutes acceptance

16. GOVERNING LAW

This policy is governed by laws of Victoria, Australia, and federal Australian privacy legislation.

17. ACCESSIBILITY

This policy is available in alternative formats upon request for persons with disabilities.

Document Version: 1.0
Next Review Date: January 2026