Privacy Policy

1. GENERAL

(a) ST Media Group Pty Ltd ABN 65 665 346 672, trading as Saint Media (we, us or our) operates the www.saintmedia.com.au website and provides media, marketing, advertising, analytics, reporting and consulting services, together with any related software, tools, scripts, applications and integrations (together, Services).

(b) We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) and, where it applies to us, the General Data Protection Regulation (EU 2016/679) (GDPR) (collectively, Privacy Laws).

(c) We value your privacy and take our obligations seriously. We are careful about how and when your personal information is collected, processed, stored, used, shared and destroyed.

(d) By using, browsing or accessing our Services, or by authorising us to access your accounts or data, you confirm that you have read, understood and accept this Privacy Policy. Your use of our Services is conditional on your acceptance of this Privacy Policy.

(e) We do not seek to collect sensitive information (as defined under the Privacy Laws). If you provide sensitive information to us by mistake, please contact us using the details below.

(f) This Privacy Policy explains, in general terms, how we collect, process, store, use and disclose personal information, how you can access the personal information we hold, and how you can make a complaint about a suspected privacy breach.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect and use information or opinions about an identified individual, or an individual who is reasonably identifiable (Personal Information), from clients, users, authorised contacts, account holders and visitors to our Services. The type of Personal Information we collect depends on your dealings with us and may include:

(a) your name and job title;

(b) the name of the business or organisation you represent;

(d) information about the Services you have engaged or enquired about;

(e) the content of any enquiries, briefs or communications between us, including the names and email addresses of people you nominate to receive reports;

(f) billing information and method of payment;

(g) account identifiers, user permissions and access credentials for platforms you authorise us to access;

(h) marketing, advertising, audience, analytics, conversion and sales performance data held in platforms you connect or share with us;

(i) information collected automatically through cookies or similar technologies, such as IP address, device and browser information, location data and online identifiers; and

(j) any other Personal Information you provide to us, including when making an enquiry or engaging our Services.

3. COLLECTING YOUR PERSONAL INFORMATION

3.1 Collection from you

(a) We collect Personal Information in a number of ways, including:

- when you engage, use or enquire about our Services, and through our records of that engagement;

- when you visit our website, contact us, complete a form or agreement, attend a meeting, or take part in a survey or event;

- when you authorise us, or tools we operate, to access advertising, analytics, data, productivity or other platforms on your behalf;

- from third parties, including our related bodies corporate, business partners, media owners, other agencies and service providers; and

- from publicly available sources, including social media pages and professional networks.

(b) We only collect Personal Information that is reasonably necessary for one or more of our functions or activities, or for a purpose we have disclosed to you, and we do not use it for unrelated purposes.

3.2 Information about someone else

(a) If you provide us with Personal Information about another person (for example, a colleague or your customers), we rely on you to tell them that you are doing so and that they can contact us for further information.

(b) You must take reasonable steps to ensure that person is aware of, and where required consents to, the matters in this Privacy Policy, including the purposes of collection, the likely recipients, their right of access, and how to contact us.

4. LEGAL BASES FOR PROCESSING (EU RESIDENTS)

Where the GDPR applies, we rely on one or more of the following legal bases to collect, process, store, use and disclose Personal Information:

(a) Consent: where you have freely given your consent for a specific purpose. Providing Personal Information is voluntary, but if you do not, we may be unable to provide our Services. You may withdraw consent at any time by contacting us.

(b) Contract: where processing is necessary to perform a contract with you, or to take steps at your request before entering into one.

(c) Legitimate interests: including providing, operating and improving our Services; managing and developing our relationship with you; marketing our Services; and responding to your queries or complaints.

(d) Legal obligation: where we are required to process or disclose Personal Information by law, regulation or court order, or to protect our legal rights.

5. USE OF YOUR PERSONAL INFORMATION

(a) We use, process and disclose your Personal Information for the purposes for which it was collected.

(b) We may also use your Personal Information to:

- provide, deliver and manage our Services, including planning, buying, running, auditing and optimising campaigns;

- produce reports, dashboards, analysis and insights on marketing and business performance, and distribute them to nominated recipients (for example, by scheduled email in PDF or spreadsheet format);

- automate the retrieval, compilation and quality-checking of data;

- administer, maintain, test, develop and improve our Services and systems;

- communicate with you about your account, projects and our Services;

- invoice and bill you for our Services;

- inform you about offers, events or other matters we believe may be of interest to you;

- verify identity and prevent fraud; and

- comply with our legal, regulatory, tax and accounting obligations.

6. USE BY THIRD PARTIES

6.1 Disclosure to third parties

We may disclose your Personal Information to:

(a) our employees, contractors, related bodies corporate and related entities (as defined in the Corporations Act 2001 (Cth)), and business partners (Authorised Affiliates), for the purpose of delivering, providing and administering our Services;

(b) third-party service providers who process information on our behalf and only for that purpose, such as cloud hosting, software, productivity, data warehousing, analytics and reporting providers, technology developers, payment processors, communications providers and professional advisers such as accountants, auditors and lawyers (Service Providers);

(c) media owners, publishers, advertising platforms and other agencies, where needed to plan, buy or run campaigns or to deliver Services you have engaged us for; and

(d) people you or your authorised representatives nominate to receive reports, dashboards or other outputs of our Services,

(collectively, Third Parties).

6.2 Third-party disclosure to us

(a) Third Parties may provide us with Personal Information they have collected from you.

(b) Where you share Personal Information with a Third Party, we rely on you to have given that Third Party any consent required for us to collect, store, use, process or disclose it.

7. PLATFORM INTEGRATIONS AND REPORTING TOOLS

(a) This section sets out further detail on how we handle data from platforms you authorise us to access, and how we use automated reporting tools.

(b) Once you have given us access to your advertising, analytics, social media, e-commerce, CRM or other marketing platforms and data sources, we will use that access to manage your media and marketing activity and to report on its performance.

(c) To do this, we may use scripts, applications, APIs, connectors, spreadsheets, dashboards, data warehouses and other automated tools, whether built by us or provided by third parties (such as Google, Meta, Microsoft and cloud providers). These tools retrieve, compile and process data only within the permissions you grant.

(d) We only access the data and functions reasonably necessary to deliver the Services you have engaged us for. Where practical, we use aggregated or de-identified performance data and do not import Personal Information from your CRM or customer records.

(e) You can review or revoke our access at any time through the relevant platform's settings or by contacting us. Once access is revoked, our tools will stop retrieving data from that platform.

(f) Data obtained through these integrations will not be sold, used for unrelated advertising, shared with our Authorised Affiliates for their own purposes, or shared with your direct competitors, despite anything to the contrary in this Privacy Policy.

(g) Where our tools access information through Google APIs, our use and transfer of that information will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements. We do not use Google user data to develop, improve or train generalised artificial intelligence or machine learning models.

(h) Your use of each platform remains subject to that platform's own terms and privacy policy.

(i) Some of our reporting is automated. We may configure scripts and workflows within productivity and cloud platforms (for example, spreadsheets, cloud storage and email services) that run on a schedule or when triggered. These may retrieve data from connected platforms and other sources, compile and format it into reports, dashboards, spreadsheets or documents such as PDFs, and store it within those platforms.

(j) These workflows may send reports by email, or share them through cloud storage links, to you and to recipients you or your authorised representatives nominate. You are responsible for ensuring the recipient details you give us are accurate and up to date, and for telling us when someone should no longer receive reports.

(k) To operate these workflows, scripts may be granted permissions such as reading and editing spreadsheets and files, sending email on our behalf, and connecting to external services. These permissions are used only to deliver the Services and are reviewed periodically.

(l) Automated reporting is used to compile and present information. It is not used to make decisions that have legal or similarly significant effects on individuals.

8. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

8.1 Protecting your Personal Information

(a) Your Personal Information may be stored in hard copy or electronic form, in facilities or systems owned and operated by us or by our Service Providers, including cloud-based services.

(b) We use reasonable endeavours to keep your Personal Information secure and protect it from misuse, interference, loss, and unauthorised access, modification or disclosure. Measures include permission-based access controls, multi-factor authentication where available, and limiting access to the people and tools that need it.

(c) Our officers, employees, contractors and Service Providers are required to keep your Personal Information confidential.

8.2 No guarantee

Despite our reasonable endeavours, no transmission of information over the internet or method of storage is completely secure. We cannot guarantee the security of any Personal Information transmitted to us, and to the extent permitted by law, we are not liable for any unauthorised access to or disclosure of that information.

Reports and other information we send by email or share by link are delivered to the recipients you nominate. Once delivered, keeping that information secure is the responsibility of the recipient.

8.3 Retention and destruction

We keep Personal Information only for as long as it is needed for the purposes described in this Privacy Policy. We will take reasonable steps to destroy or de-identify it when it is no longer required, unless we must keep it under a law, or an order of a court or tribunal.

8.4 Suspected data security breach

(a) We have procedures in place to respond to any suspected data security breach.

(b) Where legally required, including under the Notifiable Data Breaches scheme, we will notify you and any relevant regulator or supervisory authority.

9. DISCLOSURE OF PERSONAL INFORMATION

9.1 Overseas disclosure

Some of our Service Providers and the platforms we use store or process data outside Australia, including in the United States, Europe and Asia. Where we disclose Personal Information overseas, we take reasonable steps to ensure it is handled in a manner consistent with the Privacy Laws.

9.2 Disclosure to law enforcement

We may disclose your Personal Information to law enforcement bodies, regulators or courts to assist with their functions, or as otherwise required or authorised by the Privacy Laws.

9.3 Merger and acquisition

If we merge with, are acquired by, or sell all or part of our business or assets to another entity, we may transfer your Personal Information as part of that transaction. Your Personal Information will remain subject to this Privacy Policy.

10. DIRECT MARKETING

10.1 Your consent

(a) We may ask for your consent to send you marketing or promotional material and other information about our Services.

(b) Where you have consented, or where otherwise permitted by the Privacy Laws, we may use your Personal Information to send you information about our Services, events, insights and other matters we consider relevant to you.

10.2 Communication channels

We may send this information by mail, email, SMS, phone or social media, or through the channels specified when you gave your consent.

10.3 Opting out

(a) You can opt out of receiving marketing material at any time by:

- emailing us at [privacy contact email]; or

- using the unsubscribe facility in our electronic messages.

(b) You may re-subscribe at any time.

11. LINKS TO OTHER SITES

(a) Our website and Services may contain links to external websites, platforms or advertising. Those sites are not covered by this Privacy Policy, and we recommend you read their privacy policies.

(b) We are not responsible for the privacy practices of third parties.

(c) This Privacy Policy only covers information we collect through our Services, our engagement processes, or as otherwise described here. Any use of your information by third parties is governed by their own privacy policies and is outside our control.

12. COOKIES AND IP ADDRESSES

(a) A cookie is a small piece of data stored on your device that helps a website remember information about your visit.

(b) Information collected through cookies and similar technologies may include statistical data, your approximate location, IP address, the date and time of your visit, pages viewed and links clicked.

- recognise you as a returning visitor;

- improve and personalise your experience of our website; and

- measure the performance of our own marketing.

(d) Most browsers accept cookies by default. You can set your browser to refuse cookies or to warn you before accepting them. If you do, you can still use our website, but some features may not work as intended.

(e) We may also use IP addresses to analyse trends, administer our website, track traffic patterns, gather aggregated demographic information, and help prevent fraud.

13. YOUR RIGHTS IN RELATION TO PRIVACY

13.1 Privacy rights (EU residents)

(a) Where the GDPR applies, you have a number of rights in relation to your Personal Information.

(b) Subject to certain exceptions, you have the right to:

- fair and transparent processing of your Personal Information;

- have inaccurate or incomplete Personal Information corrected;

- have your Personal Information erased in certain circumstances;

- receive a copy of your Personal Information in a commonly used electronic format, or have it sent to a third party;

- object to, or withdraw consent for, the processing of your Personal Information (including for direct marketing), although this does not affect processing we have another lawful basis for, or processing carried out before you withdrew consent;

- object to decisions made solely by automated means that have legal or similarly significant effects on you; and

- otherwise restrict our processing of your Personal Information in certain circumstances.

13.2 Access and correction

(a) We use reasonable endeavours to keep the Personal Information we hold accurate, up to date and complete.

(b) Subject to exceptions under law, you may request access to, or correction of, the Personal Information we hold about you. Requests must be made in writing, and we may ask for proof of identity.

(d) We will not charge you for making a request, but may charge a reasonable fee for the cost of providing access.

(e) We will aim to respond to requests within 30 days.

14. CHILDREN

(a) Our Services are intended for businesses and are not directed at children. We do not knowingly collect Personal Information from or about persons under 16 years of age (Child) without the consent of a parent or guardian.

(b) If we become aware that we hold Personal Information about a Child without that consent, we will use reasonable endeavours to delete it as soon as possible or, where deletion is not possible, ensure it is not used or disclosed further.

15. CONSENT

You acknowledge and agree that we, our Third Parties and each of their officers, employees, agents and contractors may collect, store, use and disclose your Personal Information as set out in this Privacy Policy and in accordance with the Privacy Laws.

16. CHANGES TO THIS PRIVACY POLICY

(a) We may amend this Privacy Policy from time to time. The current version will be published on our website, and a copy can be requested from our Privacy Officer.

(b) Your continued use of our Services after any amendment indicates your acceptance of the updated Privacy Policy, so please review it regularly.

17. HOW TO CONTACT US

For further information about the Personal Information we hold about you, or to opt out of marketing communications, please contact our Privacy Officer via our enquiry form

18. RESOLVING PRIVACY COMPLAINTS

(a) If you have a complaint about how we have handled your Personal Information, or a question about this Privacy Policy, please contact our Privacy Officer in writing at the email address in section 17.

(b) Please include full details of your complaint and any supporting documents.

- give an initial response within 15 business days; and

- investigate and attempt to resolve your complaint within 30 business days, or a longer period we notify you of.

(d) If you are not satisfied with the outcome, you may refer your complaint to:

- the Office of the Australian Information Commissioner at www.oaic.gov.au; or

- the relevant supervisory authority in your EU member state.

Saint Media (ST Media Group Pty Ltd, ABN 65 665 346 672)

Melbourne, Victoria, Australia, via our enquiry form

Last updated: September 2026

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