Engagent Privacy Policy

This policy explains how Engagent collects, uses, stores and discloses personal information. We follow the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth), and it applies to engagent.au, its subdomains and every service we provide.

1. Who we are and what this policy covers

Engagent is a registered business name of The Trustee for Browne Family Trust (ABN 27 583 091 455), which also trades as Fugleman Group. In this policy, "Engagent", "we", "us" and "our" mean that entity. We are based on the Central Coast of New South Wales.

We hold personal information in two capacities.

1. For ourselves. We handle information about people who visit our websites, fill in our forms, book a call, buy our services or receive our marketing. This policy governs that information directly.

2. For our clients. We set up and run lead capture, missed call text back, AI booking, follow up, review request and reporting systems for Australian businesses. When we do this, we handle information about our clients' customers and enquirers on the client's behalf and under written agreement with them. The client decides why that information is collected, and it remains responsible for giving its own customers a privacy notice. We only use that information to provide the service to the client, and we never use it for our own marketing or sell it.

If you are a customer of one of our clients, you can raise a privacy question with that business or with us, and we will help direct it to the right place.

We apply the APPs to all personal information we handle, whether or not a small business exemption might otherwise apply to us

We only collect what we need for the purpose it is collected for. Depending on how you deal with us, that may include:

2. What we collect and how

Kind of Information

Example

How we collect it

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Name, business name, phone, email, business address, website

Forms on our sites, booking calendars, email, phone, in person

Enquiry and job details

What you need, when, where, and any notes you give us

Forms, SMS, live chats, calls and our aI Assistant

Call information

Caller number, time and length of call, voicemail, and call recording where you have been told the call is being recorded.

Our phone system

Messages

SMS, email, web chat and social messages sent to us or to a client through our platform

Our messaging platform

Billing details

Invoices, payment status and the last four digits of a card

Our payment providers. We never store full card numbers

Website and advertising data

IP address, device and browser type, pages viewed, refering sites, and ad clicks.

Cookies and similar tools, including Google Tag Manager, Google Analytics, Meta Pixel and Cloudflare

Feedback

Survey answers and review responses

Our feedback and review request tools

We do not ask for sensitive information such as health, racial or ethnic origin, or religious beliefs. If you give it to us unprompted in a message or call, we will only keep it where it is needed to deal with your enquiry.

We usually collect information directly from you. Sometimes it comes from a third party, such as a client passing on an enquiry, a business directory or a publicly listed business profile you have asked us to look at (for example when you request a free marketing report).

You can deal with us without giving your name when you are only asking a general question. We will need contact details before we can quote, book or provide a service.

Cookies. You can block or delete cookies in your browser settings and opt out of personalised ads through your Google and Meta ad settings. The site will still work, but booking calendars and forms may not.

3. How we use your information

We use personal information to:

  • respond to enquiries, book calls and provide quotes

  • set up, run, support and report on the services our clients buy

  • bill for our services and manage our accounts

  • improve our websites, services and training material

  • end marketing where the law allows (see below)

  • meet our legal, tax and insurance obligations.

We do not, and will not, ever sell personal information.

AI assistant. Some of our services use an AI assistant to reply to messages and missed calls, answer common questions, qualify enquiries and offer booking times. The assistant tells people it is an automated assistant and gives them a way to reach a person. It uses the information in the conversation, the business's calendar availability and its service area and service rules.

Automated decisions. Our systems make some decisions automatically, such as which follow up message to send, whether an enquiry fits a business's service area or job type, and which appointment times to offer. They use contact details, enquiry details, location, message history and calendar availability. None of these decisions deny anyone a legal right, and a person at the business can review or override any of them. You can ask us, or the business you contacted, to have a person look at your enquiry.

Call recording. Some calls handled through our platform are recorded for quality, training and to confirm the details of a booking. If a call is recorded, you are told at the start and can ask for it not to be recorded or hang up. Recordings are only available to the business involved and to us when we support that business.

Marketing messages. We only send commercial emails and SMS where you have agreed to receive them or where consent can reasonably be inferred from an existing business relationship, as the Spam Act 2003 (Cth) allows. Every message identifies us and includes a working unsubscribe option, and we act on unsubscribe requests within five working days. We do not make telemarketing calls to numbers on the Do Not Call Register unless you have agreed to them.

AI tools we use internally. We sometimes use AI tools to draft content, summarise calls and analyse performance. We do not put client customer data into AI tools that use it to train their public models.

4. Who we share it with

We share personal information only with the people and providers who need it to deliver the service, and only for that purpose:

  • The business you contacted, when we handle an enquiry on a client's behalf.

  • Our platform and service providers, including our CRM and marketing automation platform, telephony and SMS carriers, email delivery, AI model providers, payment processors, video conferencing, cloud storage and our accounting software.

  • Professional advisers, such as our accountant, lawyer and insurer, under a duty of confidentiality.

  • Regulators, courts or police, where the law requires or authorises it.

Our providers must protect personal information and may only use it to provide their service to us.

Overseas disclosure. Our core platform, telephony, SMS, email delivery and AI providers store or process information outside Australia, mainly in the United States. Some providers may also use facilities in the European Union, Canada or other countries where they run data centres. Before we use an overseas provider, we take reasonable steps under APP 8 to make sure it handles personal information in a way that is consistent with the APPs, including through its contract terms and security certifications.

5. Security, data breaches and retention

We protect personal information with controls that match the risk. These include multi factor authentication on every account with access to personal information, role based access so staff and contractors see only what their job needs, encryption in transit and at rest through our providers, activity logging, and regular review of who has access.

If we have a data breach that is likely to cause serious harm, we will contain it, assess it and notify the people affected and the Office of the Australian Information Commissioner (OAIC) as the Notifiable Data Breaches scheme requires. Where the breach involves a client's customer data, we will also tell that client promptly so it can meet its own obligations.

We keep personal information only as long as we need it:

Record

How long we keep it

Enquiries that do not become clients

24 months after last contact

Client account and service records

For the life of the contract, then return or delete within 90 days unless the law requires us to retain them.

Call recordings

12 months, unless needed to resolve a dispute

Invoices and financial records

At least 5 years, up to 7 years, as taxation law requires

After that we delete the information or de-identify it.

6. Access, correction and complaints

You can ask for access to the personal information we hold about you, or ask us to correct it. We will respond within 30 days. We do not charge for a request, though we may charge a reasonable fee to provide a large volume of records, and we will tell you before any fee applies. If we refuse a request, we will tell you why in writing and how to complain.

If you think we have mishandled your personal information, contact our Privacy Officer using the details below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

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

Website: oaic.gov.au

Phone: 1300 363 992

7. contact us and changes to this policy

Privacy Officer: David Browne

Email: [email protected] (subject line "Privacy")

Phone: +61 489 265 860

Location: Central Coast, NSW. Australia

We review this policy at least once a year and whenever our services or the law change. The current version is always at engagent.au/privacy-policy, with the date it was last updated.

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