Privacy Policy

Spark Factory AI Pty Limited (ACN 697 526 079)
Last updated: 1 October 2026

1. About this policy

This policy explains how Spark Factory AI Pty Limited ("Spark Factory", "we", "us") collects, uses, holds and discloses personal information. We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).

This policy covers our website, our LinkedIn advertising and lead forms, our assessment calls, our sales and marketing activity, and our dealings with clients, suppliers and job applicants. Section 10 explains how we handle personal information we process for clients when we build or run AI workflows for them.

2. The personal information we collect

We collect only what we need for our business. Depending on how you deal with us, this may include:

  • your name, job title, employer and company size
  • contact details, such as work email, phone number and business address
  • your answers to questions on our forms, such as where your team loses the most hours
  • recordings, transcripts and summaries of calls with us, including calls with Felix, our AI analyst
  • records of your emails, calls and meetings with us
  • your marketing preferences and consent records, including when you gave or withdrew consent
  • where we got your details, if we did not get them from you
  • information about how you use our website, such as pages visited, device and browser type, and your approximate location from your IP address
  • for clients and suppliers: billing, payment and contract details
  • for job applicants: your CV, work history and referee details

We do not intend to collect sensitive information, such as health information or information about your racial or ethnic origin, political opinions or religious beliefs. If you give it to us unprompted, for example during a call, we will delete it or de-identify it as soon as practicable, unless the law allows us to keep it and you have consented.

3. How we collect it

We collect personal information:

  • from you directly: when you fill in a form, request an assessment, call or email us, book a meeting, speak with Felix or our team, or become a client or supplier
  • from LinkedIn: when you submit a LinkedIn Lead Gen Form, LinkedIn passes your form details to us
  • from commercial data providers and public sources: we get business contact details, such as your name, title, employer, work email and business phone number, from B2B data providers (including Apollo.io) and from public sources such as company websites and LinkedIn profiles. We use this to find businesses that fit our services and contact the right people in them
  • from our website: through cookies and similar technologies (see section 8)
  • from people you work with: for example, when a colleague refers you to us

If we collect personal information about you from someone other than you, we will take reasonable steps to tell you that we hold it and where we got it, at the time or as soon as practicable afterwards. If we contact you using details from a data provider or public source, we will tell you where we got them in our first contact.

4. Enquiries through LinkedIn and our website

When you request an assessment through a LinkedIn Lead Gen Form or our website, we collect your name, work email, company, job title, company size, your phone number if you provide it, and your answers to our questions. LinkedIn passes this information to us when you submit the form. We store it in our customer relationship system (HubSpot) and use it to contact you about the assessment you requested. We send marketing emails only if you tick the marketing consent box. Every email includes an unsubscribe link, and we act on unsubscribe requests within 5 business days.

5. Assessment calls with Felix, our AI analyst

Our assessment calls are run by Felix, an AI voice agent. At the start of every call, Felix tells you that it is an AI and that the call is being recorded and transcribed. We record and transcribe calls so we can prepare your assessment report. You can ask to speak to a person at any time and a member of our team will call you instead. We keep recordings and transcripts for 12 months and then delete them, or sooner if you ask.

6. How we use your information

We use personal information to:

  • respond to your enquiry and deliver the assessment or service you asked for
  • prepare assessment reports, proposals and quotes
  • contact you by phone, email or LinkedIn about our services
  • run, manage and improve our business, services and website
  • measure and improve our advertising, including building LinkedIn audiences from company lists
  • manage our relationships with clients and suppliers, including billing and payment
  • assess job applications
  • meet our legal obligations and protect our legal rights

We use your information only for the purpose we collected it for, a related purpose you would reasonably expect, or another purpose the law allows.

7. Automated decisions and AI

We use software, including AI, to summarise calls, assess enquiries against our customer criteria and prioritise follow-up. A person reviews every assessment before we send it.

The kinds of personal information our software uses for this are your form answers, your job title, your company's size and industry, and call transcripts. It uses them to score how closely an enquiry fits our services and to decide the order our team follows up in.

We do not use software to make, or to do anything substantially and directly related to making, a decision that could reasonably be expected to significantly affect your rights or interests.

8. Cookies, website analytics and advertising

Our website uses cookies and similar technologies, including the HubSpot tracking code and the LinkedIn Insight Tag. They tell us how visitors use the site, let us measure how our advertising performs, and let us show our ads on LinkedIn to people who have visited our website. If you have submitted a form on our website or clicked a link in one of our emails, the HubSpot tracking code links your later visits to your contact record.

You can block or delete cookies in your browser settings. Some parts of the site may not work properly if you do. You can control how LinkedIn uses your data for ads in your LinkedIn advertising preferences.

9. Direct marketing

We send marketing emails only with your consent, or where the Spam Act 2003 (Cth) otherwise allows it. We do not add contacts from data providers to our marketing email lists.

Every marketing email identifies us as the sender, includes our contact details and has an unsubscribe link. We act on unsubscribe requests within 5 business days.

We may call you about our services. Before calling a number sourced from a data provider, we check it against the Do Not Call Register. We call only within permitted hours.

If we got your details from a data provider or another third party, every marketing communication we send you will tell you that you can ask us to stop. You can ask us to stop contacting you at any time, and we will do so within 5 business days. You can also ask us where we got your details, and we will tell you unless that is impracticable or unreasonable.

10. Information we handle for clients

When we build or run AI workflows for a client, we may process personal information held by that client, such as details of their customers or staff. We handle that information under our contract with the client, following the client's instructions and our confidentiality and security obligations, and we use it only to provide services to that client.

We comply with the APPs for that information while we hold it, including keeping it secure and notifying eligible data breaches. The client's privacy policy explains why the client collects that information and how the client uses it. If you have a question about it, contact the client first. We will work with the client to respond.

11. Service providers and overseas disclosure

We use service providers to run these activities, including LinkedIn (lead forms and advertising), HubSpot (customer records and email), VAPI (voice calls), Pinecone (knowledge base) and AI model providers (call analysis).

We also disclose personal information to:

  • other providers who help us run the business, including website hosting (Webflow), email and productivity tools, workflow automation, data providers, cloud hosting, and professional advisers such as lawyers and accountants
  • our related bodies corporate, where needed to run the business
  • anyone you ask us to disclose it to
  • regulators, courts and law enforcement bodies, where the law requires or allows it

Some of our providers store or process personal information outside Australia, mainly in the United States. Some providers also use sub-processors in other countries. You can ask us for a current list of countries. Before we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs.

We do not sell personal information.

12. How we hold and protect your information

We store personal information electronically in secure systems run by us and our service providers. We protect it with access controls, encryption where available, multi-factor authentication and staff confidentiality obligations. Staff can see personal information only when their role needs it.

When we no longer need personal information for any purpose the law allows, we take reasonable steps to destroy or de-identify it.

If we have a data breach that is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme.

13. Dealing with us anonymously or using a pseudonym

You can browse our website without telling us who you are. You can also ask general questions without giving your name, or by using a pseudonym. To deliver an assessment or a service, we need your name and contact details.

14. Access and correction

You can ask for the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. We will confirm your identity before acting on a request, and we will respond within 30 days. We do not charge for requests.

If we refuse a request, we will tell you why in writing and how you can complain. If we refuse to correct your information, you can ask us to attach a statement to it saying you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

15. Complaints

Contact privacy@sparkfactory.ai to access or correct your information, or to make a complaint. We acknowledge complaints within 5 business days and aim to resolve them within 30 days.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner:

  • online: oaic.gov.au
  • phone: 1300 363 992
  • post: GPO Box 5288, Sydney NSW 2001

16. Contact us

Privacy Officer
Spark Factory AI Pty Limited
Level 14, 5 Martin Place, Sydney NSW 2000
Email: privacy@sparkfactory.ai

17. Changes to this policy

We update this policy when our practices change. The current version is always at sparkfactory.ai/privacy, with the date it was last updated.