OVERVIEW 

APPROACH TO PRIVACY

Fullcrm (“the Company”) is committed to protecting the privacy of its customers and meeting all privacy obligations as set out in the Privacy Act 1988 (Cth) (‘the Privacy Act’). The Company collects personal information in order to conduct its business, provide services to customers, and comply with a range of legislative requirements.

The purpose of this policy is to explain how the Company handles personal information of its customers and prospective customers.

PERSONAL INFORMATION

Personal information is information relating to an individual which personally identifies an individual or makes the person’s identity reasonably apparent.

Personal information may also include ‘sensitive information’. Sensitive information is information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences, criminal record, health and biometric information or similar such information.

The Company does not intentionally collect sensitive information from customers. If sensitive information is inadvertently provided to the Company, it will be handled in accordance with this policy and the Privacy Act.

All information collected will be used and disclosed by the Company only in accordance with this policy and the law. The Company will take reasonable steps to ensure that all personal information is held securely.

COLLECTION OF PERSONAL INFORMATION

The Company will only collect personal information from customers if it is reasonably necessary for the Company’s functions or activities.

INFORMATION PROVIDED BY A CUSTOMER

It is the Company’s usual practice to collect personal information directly from customers. For example, when a customer engages the Company’s services, the Company may obtain information such as:

• Contact details, including name, business name, address, email address and phone number
• Job title and role within the customer’s organisation
• Business contact information of authorised representatives
• Billing and payment information including invoicing contact details
• Information about the customer’s business requirements and technical environment
• Communications between the customer and the Company regarding services

INFORMATION PROVIDED BY A THIRD-PARTY

The Company may receive customer information from third parties in limited circumstances, such as:

• Information provided by authorised representatives of the customer organisation
• Business contact information obtained through professional networking platforms such as LinkedIn
• Publicly available business information

INFORMATION COLLECTED DURING THE COURSE OF SERVICE DELIVERY

The Company may also collect information about customers over the course of delivering services. Such information may include:

• Details of service agreements including scope of work, timelines, and deliverables
• Records of communications regarding project requirements and specifications
• Documentation related to service delivery and project management
• Records of meetings, consultations, and support requests
• Information necessary to provide Salesforce implementation, monday.com implementation, integration services, and related consulting services

The Company may also collect other personal information if required or authorised to do so by law.

USE OF PERSONAL INFORMATION

The purposes for which the Company may collect, use, and disclose personal information include (but are not limited to):

• To establish, maintain and manage customer relationships
• To provide quotes, proposals, and service offerings
• To deliver contracted services including Salesforce implementation and consulting, monday.com implementation, integration services across multiple platforms, and related technology services
• To invoice customers and process payments
• To communicate with customers about services, projects, and support matters
• To respond to customer enquiries and requests
• To improve service delivery and customer experience
• To comply with legal and regulatory obligations
• To maintain business records and documentation
• To protect the Company’s legal rights and interests
• To prevent and detect fraud or other unlawful activities
• Otherwise as permitted or required by law
• Otherwise with the customer’s consent

USE OF CUSTOMER INFORMATION FOR MARKETING AND BUSINESS PURPOSES

The Company may use customer business information (such as company name, industry sector, and general project descriptions) as case studies or references in marketing materials, subject to any confidentiality obligations. The Company will seek customer consent before using specific project details or identifying information in public-facing materials.

DISCLOSURE OF PERSONAL INFORMATION

The Company may disclose customer personal information to third parties including:

• Other companies within the Company’s group
• Employees and contractors working for the Company, to the extent necessary to deliver services
• Subcontractors who work under strict confidentiality agreements
• Professional service providers such as legal, accounting, and insurance advisers
• Payment processing and banking service providers
• Government agencies as required by law
• Other third parties as authorised by law or with customer consent

The Company does not directly disclose personal information to technology service providers, but uses their platforms to securely store and manage customer information as detailed in the Data Storage and Security section below.

All third-party service providers and subcontractors are required to handle personal information in accordance with this policy.

DATA STORAGE AND SECURITY

The Company takes the security of customer information seriously and has implemented the following measures:

• No Local Storage: Customer data is not stored on local drives. All customer information resides securely in designated customer folders within Google Drive with appropriate access controls.
• Password Management: All system passwords are stored exclusively in 1Password, a secure password management system.
• CRM Storage: Contact information is stored in Salesforce, our customer relationship management system. The Company does not store sensitive personal data in Salesforce beyond standard business contact information.
• Accounting System: Customer names and email addresses for billing contacts are stored in Xero, our accounting software, solely for invoicing purposes.
• Meeting Records: The Company uses Fireflies and Google Meet to record meeting transcripts. These recordings and transcripts are stored securely and used solely for the purpose of accurately capturing project requirements, action items, and maintaining records of communications related to service delivery.
• AI-Assisted Services: The Company uses named licences for AI tools including Claude. Meeting transcripts and data stored in Google Drive may be processed through these AI tools to assist with performing services such as summarising project requirements, preparing documentation, and improving service delivery efficiency. No customer data is used to train public AI models.
• Access Controls: Access to customer information is restricted to authorised personnel who require it to perform their roles.
• Secure Communications: The Company uses encrypted communications and secure file transfer methods when handling customer information.

The Company uses third-party technology platforms including Salesforce, Google Workspace, Xero, Fireflies, and AI service providers for storing and processing customer information. These platforms are industry-leading cloud services that maintain robust security measures and comply with international data protection standards. The Company does not directly disclose customer personal information to these technology service providers beyond what is necessary for the platforms to provide their services.

The Company will retain customer personal information only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements.

ACCURACY OF PERSONAL INFORMATION

The Company endeavours to maintain accurate records of all customer personal information. Customers should ensure that all personal information provided to the Company is accurate and up-to-date, and should notify the Company promptly of any changes to their contact information or other personal details.

ACCESS TO PERSONAL INFORMATION

Customers may request access to their personal information held by the Company by contacting us using the details provided below. If the personal information is incorrect, customers may request that the Company amend its records and the Company will take reasonable steps to do so.

The Company may make reasonable charges for access to personal information and may refuse to provide access to, or delete, information where this is required or authorised by the Privacy Act or another law.

DATA BREACHES

In the event of a data breach involving customer personal information, the Company will comply with all notification obligations under the Privacy Act and will take immediate steps to contain and remediate the breach.

OVERSEAS DISCLOSURE

Customer information may be disclosed to subcontractors located overseas for the purpose of delivering contracted services. All subcontractors are bound by strict confidentiality agreements and are required to handle personal information in accordance with this privacy policy and applicable privacy laws.

Additionally, customer information stored on third-party technology platforms (Salesforce, Google Workspace, Xero, Fireflies, and AI service providers) may be processed or stored on servers located overseas. These platforms maintain data centres in multiple jurisdictions and comply with applicable data protection regulations.

Contact Us

If you have any questions, concerns, or complaints about how we handle your personal information, or if you wish to access or correct your personal information, please contact us:

Fullcrm ABN 59 600 648 235 Level 6, 15 Castlereagh Street Sydney NSW 2000 Email: hello@fullcrm.com Phone: +61 2 8057 8250

CHANGES TO THIS POLICY

The Company may update this privacy policy from time to time.

Last Updated: January 2026