PRIVACY POLICY

Genesys Digital Pty Ltd

ABN 12 683 461 663

267 Miller St, North Sydney NSW 2060

Effective Date: January 7th 2026

1. INTRODUCTION

1.1 Genesys Digital Pty Ltd (ABN 12 683 461 663) trading as Genesys Leads ("Genesys Leads", "we", "us", or "our") is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

1.2 This Privacy Policy explains how we collect, use, disclose, and store personal information about:

Mortgage brokers and brokerages who use our services ("Clients")

Individuals who submit enquiries through our lead generation campaigns ("Leads")

Visitors to our website

1.3 By using our services or submitting information to us, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

2. WHAT INFORMATION WE COLLECT

2.1 Information We Collect From Clients (Mortgage Brokers)

When you register for or use our services, we may collect:

Full name

Email address

Phone number

Business name and ABN

Payment information (credit card details, billing address)

Communication preferences

Any other information you provide to us during the course of our relationship

2.2 Information We Collect From Leads (Prospective Borrowers)

When individuals submit enquiries through our lead generation campaigns, we collect:

Full name

Email address

Phone number

Contact information

Financial situation details (such as deposit amount, loan balance, employment status, income)

Property preferences and goals

Timeline and readiness to proceed

Other information relevant to their mortgage needs

The specific information collected varies depending on the type of lead (First Home Buyer, Refinance, or Investment Property).

2.3 Information Collected Automatically

When you visit our website, we may automatically collect:

IP address

Browser type and version

Device information

Pages visited and time spent on our site

Referral source

Cookies and similar tracking technologies

We use cookies and analytics tools (including Google Analytics and similar platforms) to understand how our website is used and to improve user experience.

3. HOW WE COLLECT INFORMATION

3.1 We collect personal information directly from you when you:

Register for our services

Purchase leads from us

Submit an enquiry through our lead generation campaigns

Contact us via email, phone, or our website

Subscribe to our marketing communications

3.2 We may also collect information through:

Cookies and tracking pixels on our website

Third-party advertising platforms (such as Google, Facebook, LinkedIn, YouTube, TikTok)

Analytics and measurement tools

4. HOW WE USE YOUR INFORMATION

4.1 Client Information

We use information collected from Clients to:

Provide our lead generation services

Process payments and issue invoices

Communicate with you about your account and our services

Respond to enquiries and provide customer support

Send marketing communications about our services (you may opt out at any time)

Improve our services and develop new offerings

Comply with legal obligations

4.2 Lead Information

We use information collected from Leads to:

Deliver leads to the Client who has purchased them

Validate contact information (via SMS verification)

Optimise our marketing campaigns

Improve lead quality and pre-qualification processes

Comply with legal obligations

4.3 Website Visitor Information

We use information collected from website visitors to:

Analyse website traffic and user behaviour

Improve website functionality and user experience

Deliver targeted advertising

Measure the effectiveness of our marketing campaigns

5. HOW WE SHARE YOUR INFORMATION

5.1 Sharing Lead Information With Clients

When a Lead submits an enquiry through our campaigns, we share their personal information exclusively with the Client (mortgage broker) who has purchased that lead. Leads are never shared with multiple brokers or resold.

5.2 Third-Party Service Providers

We may share personal information with trusted third-party service providers who assist us in operating our business, including:

Payment processors (for processing payments)

Email service providers (for sending communications)

CRM platforms (Go High Level, for managing client and lead data)

Advertising platforms (Google, Facebook, LinkedIn, YouTube, TikTok, for running marketing campaigns)

Analytics providers (Google Analytics and similar tools)

Cloud storage providers (for data storage)

These service providers are only authorised to use your personal information as necessary to provide services to us and are required to protect your information.

5.3 Sub-Contractors

We may engage sub-contractors or service providers in the future who may have access to personal information in the course of providing services to us. Any such sub-contractors will be bound by confidentiality obligations.

5.4 Legal Requirements

We may disclose personal information if required to do so by law, or if we believe in good faith that such disclosure is necessary to:

Comply with legal obligations or court orders

Protect our rights, property, or safety

Prevent fraud or other illegal activity

Enforce our Terms and Conditions

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred to the acquiring entity.

6. DATA STORAGE AND SECURITY

6.1 Personal information is stored on secure cloud servers in Australia, primarily through our CRM platform, Go High Level.

6.2 We implement appropriate technical and organisational measures to protect personal information from unauthorised access, disclosure, alteration, or destruction.

6.3 While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security.

6.4 You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account.

7. DATA RETENTION

7.1 Client Data: We retain personal information about Clients for 30 days after they cease using our services, unless required to retain it longer for legal, dispute resolution, or compliance purposes.

7.2 Lead Data: We retain personal information about Leads for as long as necessary to fulfil our business purposes, including service delivery, dispute resolution, and campaign optimisation. Lead data may be retained indefinitely in our systems.

7.3 Website Data: Information collected through cookies and analytics tools is retained in accordance with the retention policies of the relevant third-party platforms (e.g., Google Analytics).

7.4 When personal information is no longer required, we will take reasonable steps to destroy or de-identify it.

8. YOUR RIGHTS

8.1 Access to Your Information

You have the right to request access to the personal information we hold about you. To request access, please contact us at [email protected]

8.2 Correction of Your Information

If you believe that any personal information we hold about you is inaccurate, incomplete, or out of date, you may request that we correct it. Please contact us at [email protected]

8.3 Deletion of Your Information

You may request that we delete your personal information in certain circumstances. Please contact us at [email protected] to make a deletion request.

Please note that we may not be able to delete all of your information if we are required to retain it for legal, dispute resolution, or compliance purposes.

8.4 Opting Out of Marketing Communications

If you no longer wish to receive marketing communications from us, you may opt out by:

Clicking the "unsubscribe" link in any marketing email we send you

Contacting us at [email protected]

Please note that even if you opt out of marketing communications, we may still send you service-related communications (such as invoices or account notifications).

8.5 Complaints

If you have a complaint about how we handle your personal information, please contact us at [email protected]. We will investigate your complaint and respond within a reasonable timeframe.

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

Email: [email protected]

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 Our website uses cookies and similar tracking technologies to collect information about your browsing activity.

9.2 Cookies are small text files stored on your device that allow us to recognise you and remember your preferences.

9.3 We use the following types of cookies:

Essential cookies: Required for the website to function properly

Analytics cookies: Help us understand how visitors use our website (e.g., Google Analytics)

Advertising cookies: Used to deliver targeted advertising and measure campaign effectiveness

9.4 You can control or delete cookies through your browser settings. However, disabling cookies may affect the functionality of our website.

9.5 We may also use tracking pixels and similar technologies in our advertising campaigns to measure performance and retarget website visitors.

10. THIRD-PARTY WEBSITES

10.1 Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites.

10.2 We encourage you to review the privacy policies of any third-party websites you visit.

11. CHILDREN'S PRIVACY

11.1 Our services are not intended for individuals under the age of 18.

11.2 We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete that information.

12. INTERNATIONAL DATA TRANSFERS

12.1 Your personal information is primarily stored on servers located in Australia.

12.2 Some of our third-party service providers (such as advertising platforms and analytics tools) may store or process data on servers located overseas, including in the United States and other countries.

12.3 By using our services, you consent to the transfer of your personal information to these overseas locations.

12.4 We take reasonable steps to ensure that any overseas recipients handle your personal information in accordance with Australian privacy standards.

13. CHANGES TO THIS PRIVACY POLICY

13.1 We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements.

13.2 Any changes will be effective immediately upon posting the updated Privacy Policy on our website.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13.4 Your continued use of our services after changes are posted constitutes acceptance of the updated Privacy Policy.

14. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

Genesys Digital Pty Ltd

Email: [email protected]

Phone: [Insert Phone Number]

Address: Miller St, North Sydney NSW 2060

For data access, correction, or deletion requests, please email [email protected]

with the subject line "Privacy Request".

Last Updated: January 7th 2026