privacy

Privacy

Privacy Policy

Circles Agency AU Pty Ltd
ABN 27 658 541 265
Trading as "Circles Agency", "Circles", "we", "us" or "our"

Palm Beach, Gold Coast, QLD 4221, Australia

Last updated: 19 September 2026

This policy explains how we collect, use, disclose and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

It covers:
Part A — Our website and agency services: circlesagency.com and our performance marketing services for clients.Part B — Our software: Internal and client-facing tools we build and operate, including our Meta/Facebook advertising tools such as Viktor Ad Launch.By using our website, engaging our services or using our software, you agree to this policy.
Part A — Website and Agency Services

1. Information We Collect

We may collect:
Contact and enquiry details you provide: Your name, business name, email address, phone number, website and the content of your enquiry, submitted through our contact forms, Typeform intake forms, email or calls.Client and account information needed to deliver our services: Billing details, contact information, brand assets, access to advertising and analytics accounts, and business performance data you share with us.Technical and usage data collected when you visit our website: Your IP address, browser and device type, pages viewed, referring URL and approximate location, collected through cookies and analytics tools.Marketing engagement data: Information about whether you open or click our emails and how you interact with our advertisements.We do not seek to collect sensitive information, such as information about your health, racial or ethnic origin, political or religious beliefs, sexual orientation or criminal record. Please do not send this information to us.

2. How We Collect Information

We collect information:
Directly from you through forms, emails, calls and onboarding documents.Automatically through cookies and analytics tools on our website.From third-party platforms you authorise us to access on your behalf, such as Meta Ads Manager, Google Ads, Shopify, Klaviyo and Google Analytics.3. Why We Use Information

We may use your information:
To respond to enquiries and provide quotes and proposals.To deliver, manage and report on our marketing services, including campaign management, creative production, analytics and reporting.To administer accounts, invoicing and payments.To improve our website, services and internal processes.To send you marketing communications about our services where you have opted in or where it is otherwise permitted. You can unsubscribe at any time using the link in our emails or by contacting us.To meet our legal, accounting and record-keeping obligations.4. Advertising, Cookies and Analytics

Our website and the campaigns we run may use cookies, pixels and similar technologies, including the Meta Pixel and Google Analytics, to measure performance and display relevant advertising.

These tools may set cookies, collect device and browsing information, and allow the relevant platform to match activity to an existing account it holds.

You can control cookies through your browser settings and opt out of personalised advertising through:
Meta: facebook.com/settings?tab=adsGoogle: adssettings.google.comBlocking cookies may affect how parts of our website work.

5. Who We Disclose Information To

We disclose personal information only as needed to operate our business, including to:
Our clients, where we act as their marketing partner and the information relates to their campaigns.Service providers and platforms we use to operate, including Meta Platforms, Google, TikTok, Shopify, Klaviyo, Asana, Google Workspace (Drive and Sheets), Miro, Typeform, AgencyAnalytics, Motion, Xero, Slack, and our cloud hosting and AI tooling providers.Professional advisers, including accountants, lawyers and insurers.Regulators or law enforcement agencies where required or authorised by law.We do not sell personal information.

6. Overseas Disclosure

Some of our providers store or process data outside Australia, including in the United States and the European Union.

Where we disclose personal information overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles.

7. Security and Retention

We use reasonable technical and organisational measures to protect personal information, including:
Access controls.Encrypted connections.Restricted credential storage.Least-privilege access to client advertising accounts.No system is perfectly secure.

We retain personal information only for as long as it is needed for the purposes described in this policy or as required by law. Financial records are generally retained for at least seven years. When information is no longer required, we destroy or de-identify it.

8. Access, Correction and Complaints

You can request access to the personal information we hold about you or ask us to correct it by emailing [email protected].

We will respond within a reasonable period, usually within 30 days. If we need to refuse a request, we will explain why.

If you believe we have breached the Australian Privacy Principles, please contact us at the same email address. We will investigate your complaint and respond.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner:
Website: oaic.gov.auPhone: 1300 363 992Part B — Our Software and Advertising Tools

This part applies to software Circles Agency builds and operates, including Viktor Ad Launch, an internal tool used by Circles Agency staff to create and publish advertising campaigns in our clients' Meta (Facebook and Instagram) advertising accounts, and any similar internal automation, reporting or proofing tools we operate.

9. Who Can Use the Software

Our software is not a consumer product.

It is available only to authorised Circles Agency personnel and, where agreed, named client contacts. It is not intended for use by anyone under 18 years of age.

10. What the Software Processes

Our software may process:
User account data: Your name, work email address and access role, used to authenticate you and log activity.Advertising account data accessed through platform APIs: Primarily through the Meta Marketing API and, where relevant, Google and TikTok APIs. This may include advertising account, page, Instagram account, pixel, campaign, ad set, advertisement, creative and audience configurations, as well as aggregated performance and spend metrics.Creative assets and copy: Images, videos and advertising text supplied by Circles Agency or our clients and uploaded to the relevant advertising platform.Operational logs: Actions taken within the tool, such as publishing a campaign or encountering a failure and its associated error message. These actions may be timestamped and attributed to the user who performed them.The software reads aggregated, non-identifying advertising performance data.

It does not:
Build audience profiles.Collect personal information about consumers or our clients' end customers.Process customer lists, email addresses or phone numbers for audience matching unless a client specifically instructs us to do so in writing.Where a client provides such an instruction, the data is uploaded directly to the relevant platform and is not retained by us.

11. Access Tokens and Platform Data

The software authenticates with advertising platforms using access tokens issued to Circles Agency.

These tokens:
Are stored as encrypted server-side secrets.Are never exposed to browsers or third parties.Can be revoked by Circles Agency or the relevant platform at any time.We use platform data only to provide, operate and improve our advertising services for the account that granted access.

We do not:
Sell platform data.Transfer platform data to data brokers.Use platform data for advertising unrelated to the account that granted access.Combine platform data with data from other clients.Our handling of Meta Platform data also complies with Meta's Platform Terms and Developer Policies.

12. Retention and Deletion for the Software

Configuration and log data is retained while the tool is in active use and for up to 24 months afterwards for auditing and troubleshooting. It is then deleted.

Access tokens are deleted or revoked when the relevant integration is disconnected or an authorised user leaves.

To request the deletion of data held in our software or the removal of your account, email [email protected] with the subject line "Data deletion request."

We will confirm and action verified requests within 30 days, except where we are required to retain information by law.

13. Third Parties Used by the Software

The software runs on commercial cloud infrastructure and uses the advertising platform APIs listed above.

It also uses:
Google Workspace for campaign input sheets and asset storage.Slack for notifications and advertising proofs.These providers process data on our behalf under their own terms and may store data outside Australia.

14. Changes to This Policy

We may update this policy from time to time.

The current version will always be published at this URL with the "Last updated" date shown above. Material changes will be communicated directly to affected clients.

15. Contact Us

Privacy Officer
Circles Agency AU Pty Ltd
Palm Beach, Gold Coast, QLD 4221, Australia
Email: [email protected]