DRAFT FOR LAWYER REVIEW. Not yet in force. Note for reviewer: confirm whether MONTALBO GROUP PTY LTD is covered by the Privacy Act. The small business exemption may not apply, for example because of health information collected for childcare or other business activities. Whatever the answer, we intend to follow the APPs. Also check the wording on AI tools, overseas disclosure and photos.

MONTALBO GROUP PTY LTD (ABN 88 689 532 198) provides home, concierge and commercial services in Brisbane. In this policy, “we”, “us” and “our” mean MONTALBO GROUP PTY LTD. We aim to handle personal information in line with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).

• Enquiries and quotes: your name, phone number, email, suburb, the services and frequency you're interested in, and anything you write in your message.
• Clients: your service address, access instructions (for example keys, gate or alarm codes), household preferences, billing details and service history.
• Nanny and babysitting clients: children's names and ages, routines, emergency contacts, approved adults for pick-up, and health information you choose to give us, such as allergies, medical needs or medication instructions. Health information is sensitive information. We only collect it with your consent and only when it's needed to care for your children safely.
• Business clients: contact names, work contact details, site details and site access arrangements.
• Job applicants and contractors: your resume, referees, work-rights details and check results (such as a National Police Check or Blue Card status). We collect check results with your consent.
• Website: our website doesn't use advertising or analytics cookies. Our hosting provider may keep standard technical logs, such as IP addresses.

Mostly directly from you: through our website forms, by email, phone or text, during in-home or site assessments, and when you sign up for a service. Sometimes we collect information from other people with your consent, for example referees or a property manager arranging a clean for you.

• to answer your enquiry, prepare quotes and arrange assessments
• to deliver, schedule, check and invoice our services
• to keep children, clients and our team safe, including handling incidents and emergencies
• to recruit and manage staff and contractors, and to meet our legal duties (for example tax, workplace safety and child-safety laws)
• to improve our services and, if you agree, to tell you about offers (see “Marketing” below)

After a visit we may take photos of the work areas (for example kitchens, bathrooms, gardens or pool readings) as a quality record. We do not deliberately photograph people, children, documents, valuables or anything that identifies your address. We never post client photos publicly without your written consent.

We share only what's needed, with:

• our team members and vetted subcontractors (for example gardening, handyman or pool partners) who carry out your service
• service providers who help us run the business, such as email and website form providers, booking and accounting software, and payment providers
• professional advisers (accountants, lawyers and insurers)
• emergency services, government agencies or others where the law requires or allows it, or where it's needed to prevent a serious threat to someone's life, health or safety

We use software tools, which may include AI-assisted tools, to help organise bookings and draft replies to enquiries. A person at MONTALBO GROUP PTY LTD stays responsible for decisions and for what we send. We don't use these tools to make decisions about you that have legal or similarly significant effects. LAWYER TO CONFIRM WORDING

Some of our software and email providers may store data on servers outside Australia, for example in the United States. Before using a provider we take reasonable steps to make sure it protects your information. TBC: list providers and countries once chosen

We'll only send you marketing emails or texts if you've agreed or if the law allows it, and each message will include an easy way to unsubscribe. You can opt out at any time by contacting us.

We take reasonable steps to protect personal information from misuse, loss and unauthorised access. These include access controls and multi-factor authentication on our accounts, and a key-custody procedure: keys and codes are coded and never labelled with your address. Team members can only see the information they need to do the job. We keep information only as long as we need it for the purposes above or as the law requires, then securely delete or de-identify it. If a data breach is likely to cause someone serious harm, we will assess it promptly and notify the people affected and the OAIC where required.

You can ask for a copy of the personal information we hold about you, or ask us to correct it, by contacting us using the details below. We'll respond within a reasonable time, usually within 30 days. If we refuse, we'll tell you why.

Please contact us first:
Privacy contact: Iris, Director, MONTALBO GROUP PTY LTD
Phone +61 416 809 670 · Email hello@montalbogroup.com.au TBC
We aim to respond within 30 days. If you're not satisfied, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

We may update this policy from time to time. The current version is always on this page.