Privacy Policy

October 1, 2026

Think Grow Pty Ltd (ABN 34 605 404 448) and each of its related group companies, including but not limited to Think & Grow (UK) Ltd (Company Number 10554839) (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. It applies to each member of the Group, and a reference to "we", "us" or "our" is a reference to the member of the Group that handles your personal information.

Last updated: 2 October 2026

Our website may contain links to third-party sites and services. Those sites and services have their own privacy policies, and we encourage you to review them. We have no control over, and cannot accept responsibility or liability for, the content or privacy practices of any third-party sites or services. This policy does not apply to your activities on any third-party site after you leave our website.

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, United States: additional rights apply to you under the California Consumer Privacy Act (CCPA) and California Civil Code Section 1798.83. Please refer to Appendix 2 at the end of this policy for information specific to your additional rights and how we process your personal information in accordance with these laws.

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, date of birth, address, email address and phone number
Professional details
Social media profile

Service related information

Payment and transaction details for products and services you have purchased from us, or enquiries about our products and services
Your preferences for our services and your marketing preferences
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
Device type and operating system
Unique device identifiers
Device settings

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

Sensitive information

We handle sensitive information with extra care and protection, and we only collect this information with your consent or when legally permitted. This includes:

Racial or ethnic origin
Biometric information

We will not collect sensitive information about you without first obtaining your consent, and we will only use or disclose your sensitive information as permitted, required, or authorised by law.

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.
From members of our Group: other members of our Group, where necessary for the purposes set out in this policy.

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 enquiries, support requests, and communications
To maintain accurate records for billing and administration

Client onboarding and verification

To assess whether to take you on as a new client or provide services to you, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks when required or permitted by law
To retain records of verification checks as required by law

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle enquiries 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 and services
To develop and enhance our applications and platforms
To understand how our services are used

Marketing and promotions

To send you promotional information about our services 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 fulfil regulatory requirements or reporting obligations
To protect our legal rights and interests, or as authorised by law

Combining information

To combine information you provide to us, and information we collect automatically, with general information or research data we receive from other trusted sources
To combine data and insights from our marketing and market research activities with information about how visitors use our website, to improve our website and your experience of it

Group operations

To share information between members of our Group (in accordance with applicable laws) so that we can manage our relationship with you, provide our services and operate our website
To manage and administer our Group's business, including for internal reporting, compliance and risk management

Our disclosures of personal information to third parties

We may disclose personal information to:

Service providers

IT service providers
Data storage providers
Web hosting and server providers
Payment processors
Marketing and advertising providers (Google AdSense, HubSpot Inc.)
Analytics providers (Google Analytics)
Identity verification and compliance screening service providers
Recruitment and applicant-tracking providers (RecruitCRM)

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers

Business partners

Our existing or potential agents
Our business partners or contractors
Our parent, subsidiary or affiliated companies, including but not limited to members of our Group
Our employees, contractors and related entities, where necessary for them to perform their roles

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
Your information may be disclosed to the potential purchaser's advisers
Your information may be included in the transferred assets

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities, including as required for reporting obligations
Law enforcement officers
Credit reporting agencies, in the event you fail to pay for goods or services we have provided to you

Other parties

Third parties you have authorised
Emergency services when necessary
Any other parties as required or permitted by law

Overseas disclosure

Storage and access

We are a global business and some of our Group may be based outside of Australia or the United Kingdom. We may store your personal information in Australia and the United Kingdom. However, your information may be accessed from or transferred to locations outside Australia or the United Kingdom, including the United States, Germany and Singapore, 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
When personal information is shared between members of our Group

Our approach to overseas disclosure

Before disclosing your personal information overseas, 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 do not provide certain information, we may not be able to provide some services. Let us know if you do not want to provide information and we will let you know when information is required versus optional.

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. 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.

Deletion of your information

If you ask us to delete your account, we will delete your personal information within 60 days of the deletion of your account, except where we are required or entitled to retain it for legal, regulatory or legitimate business reasons.

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.

Notification of data breaches

We will comply with all laws applicable to us in respect of any data breach, including notifying affected individuals and relevant regulators where required by law.

Non-discrimination

We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service (for example, providing user support), we will not deny you goods or services, charge you different prices or rates, or provide you with a different level or quality of goods or services because you have exercised your privacy rights.

How to contact us about your rights or to make a complaint

Step 1: Contact our privacy officer

Email: humans@thinkandgrowinc.com
Post: Level 3, 88 Jolimont Street, East Melbourne, VIC 3002, 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 are not satisfied (complaints only)

If you are 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)
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 do not have to contact us first before going to the ICO, but we would 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.

Children's privacy

We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal information from children under 13.

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 procedure 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.

Cookies

Cookies are small text files stored on your device that help us recognise your browser, remember your preferences, and make your interactions with our website more efficient. We use the following categories of cookies:

Essential cookies: crucial to your experience of our website, enabling core features such as logins, account management and payment processing.
Performance cookies: track how you use our website during your visit, helping us understand usage patterns and diagnose problems. This information is typically anonymous and aggregated.
Functionality cookies: collect information about your device and settings (such as language and time zone) so we can provide customised content.
Targeting and advertising cookies: help determine what promotional content is relevant to you, and may be used to deliver targeted advertising and measure the effectiveness of our campaigns.

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

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.

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.

Google AdSense and HubSpot

We use Google AdSense to display advertisements on our website, and HubSpot Inc. to manage our marketing communications and customer relationship data. These tools may use cookies to collect information about your browsing activity.

Use of location services data

We collect your approximate location, derived from your IP address, when you visit our website, for the following purposes:

To understand where our users are located, for analytics and market research purposes
To improve our website and services
To detect and prevent fraud
As permitted by law

We collect this information automatically when you visit our website. If you do not want us to collect this information, you can adjust your browser or device settings to limit location sharing.

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 and coding
Improve and optimise our services and operations
Automate routine tasks and communications
Personalise your experience with our services
Support quality assurance processes
Assist with customer support and queries

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 will inform you when AI is used to make decisions that may significantly affect you
We maintain human oversight and review of significant AI-generated decisions
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.

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.

The GDPR distinguishes between organisations that process personal information for their own purposes (data controllers) and organisations that process personal information on behalf of other organisations (data processors). We, Think Grow Pty Ltd, are a data controller and, in some circumstances, a data processor, with respect to the personal information you provide to us.

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 have 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 does not 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. We have listed the reasons we process your data and the legal basis below. 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 in the policy above under "Why we collect, hold, use and disclose personal information" and 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 we use: identity and contact details; service related information; digital information.

Purpose: Client onboarding and verification. Legal basis: performance of a contract; legal duty; public interest; legitimate interests. Types of information we use: identity and contact details; financial information.

Purpose: Communication and support. Legal basis: legitimate interests. Types of information we use: identity and contact details; digital information.

Purpose: Service improvement. Legal basis: legitimate interests. Types of information we use: digital information.

Purpose: Marketing and promotions. Legal basis: legitimate interests. Types of information we use: identity and contact details; digital information.

Purpose: Employment purposes. Legal basis: legitimate interests; legal duty; consent; performance of a contract. Types of information we use: identity and contact details; professional data.

Purpose: Legal and compliance. Legal basis: legal duty. Types of information we use: 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
When we share personal data between members of our Group, including where personal data is transferred from the United Kingdom to Australia

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, or
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 you have in our policy above, you also have the below 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 do not want erasure
We no longer need the data but you need it for legal claims
You have 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

We have appointed a Head of Privacy for you to contact if you have any questions or concerns regarding your privacy, or our policies or practices in relation to GDPR.

For any questions about how we process your personal information under GDPR, please contact our Head of Privacy at humans@thinkandgrowinc.com.

Appendix 2: Additional disclosures for California Consumer Privacy Act (CCPA) compliance (US)

This Appendix 2 applies to individuals who are California residents. Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organisations for their marketing purposes. To make such a request, please contact us using the details provided in this privacy policy with "Request for California privacy information" in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do not track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser "Do Not Track" signals. We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently and with legitimate, legal reasons for doing so.

CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California notice of collection

In the past 12 months, we have collected the following categories of personal information:

Identifiers, such as name, email address, phone number, account name, IP address, and an ID or number assigned to your account
Demographics, such as age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
Internet activity, such as your interactions with our services
Geolocation data
Employment and education data, such as data you provide when applying for a job with us
Inferences, such as information about your interests, preferences and favourites

We collect and use these categories of personal information for the business purposes described in this policy, including to provide and manage our services.

Right to know and delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

The categories of personal information we have collected about you
The categories of sources from which the personal information was collected
The categories of personal information about you we disclosed for a business purpose or sold
The categories of third parties to whom the personal information was disclosed for a business purpose or sold
The business or commercial purpose for collecting or selling the personal information
The specific pieces of personal information we have collected about you

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California's "Shine the Light" law, with third parties and affiliates for their own direct marketing purposes. To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state, and ZIP code.

To exercise any of these rights, please contact us at humans@thinkandgrowinc.com.

Appendix 3: Privacy collection notice

Where this notice applies

This Privacy Collection Notice forms part of our Privacy Policy. It is displayed with our enquiry, contact and permission forms, and describes how Think Grow Pty Ltd (ABN 34 605 404 448) (we, us or our) collects and handles your personal information in those situations.

Privacy collection notice

This Privacy Collection Notice describes how Think Grow Pty Ltd (ABN 34 605 404 448) (we, us or our) collects and handles your personal information when you make an enquiry with us, when you give us permission to contact you, or when a member of our team records permission that you have given.

We collect personal information from you, and from our own team members recording a conversation they have had with you, so that we can respond to your enquiry or follow up on what you asked for, and for related purposes set out in our Privacy Policy.

We may disclose this personal information to third parties, including our personnel, related entities, any third parties engaged by us and acting on our behalf, and as otherwise set out in our Privacy Policy.

We store personal information in Australia and the United Kingdom. Your information may be accessed from or transferred to locations outside Australia or the United Kingdom, including the United States, Germany and Singapore, where our service providers, business partners or cloud-based services are located, or when personal information is shared between members of our Group.

If you do not provide your personal information to us, it may affect our ability to do business with you.

You can unsubscribe from our emails at any time using the link included in every message, or by contacting us.

Please see our Privacy Policy for more information about how we collect, store, use and disclose your personal information, including details about overseas disclosure, access, correction, how you can make a privacy-related complaint and our complaint-handling process.

If you have questions about our privacy practices, please contact us by email at humans@thinkandgrowinc.com. By providing your personal information to us, or by a member of our team recording permission that you have given, you agree to the collection, use, storage and disclosure of that information as described in this Privacy Collection Notice.

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