Privacy Policy

smrtr takes the confidentiality of personal data collected in the course of delivering its services seriously and wholly supports the protection of consumers’ privacy rights.


smrtr’s Privacy Policy sets out the ways in which we process the collection, disclosure, use and storage of ‘Personal Information’ (as defined in the Privacy Act 1988 (Cth)) (Privacy Act) handled by smrtr Pty Ltd (ACN 137 152 599) and its subsidiaries (smrtr). All Personal Information collected by or provided to smrtr is stored and used in accordance with the Privacy Act and the Privacy Amendment (Private Sector) Act 2000 (Cth).

We comply with the 13 Australian Privacy Principles (APPs), which regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal (

Where smrtr works with service providers, customers and commercial interests internationally, in each case, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of Personal Information. To the extent that any privacy legislation in other jurisdictions apply to smrtr’s use of your Personal Information, smrtr will take all steps reasonably required to comply with those applicable laws or regulations.


We use a wide range of resources to stay informed about developments in legislation and regulation. We provide ongoing education to our employees on this Privacy Policy, as well as on the privacy legislation and accepted practices under which smrtr operates. As changes in legislation or industry practices occur, special education is provided to update our employees. All new employees sign confidentiality agreements as a condition of employment with us.

Use of Personal Information

The nature of Personal Information collected by smrtr for smrtr‘s benefit may include an individual’s name, address, business/company name, role/position, business information, telephone/mobile number, fax number, email address, bank account details, credit history, Australian Business Number, driver’s licence number, photograph, signature, membership information, health information, testimonials and opinions.  

smrtr collects Personal Information for the purposes of conducting or promoting smrtr, direct marketing, providing and promoting smrtr’s services, responding to enquiries regarding smrtr’s services and facilitating smrtr’s relationship with you. We may also collect, hold and disclose Personal Information for other purposes explained at the time of collection, or where required or authorised by law, or for which you have provided your consent. smrtr does not collect Personal Information unless the information is necessary to enable smrtr to perform one or more of its functions and activities. We may contact you for the above purposes in a variety of ways, including by mail, email, SMS, telephone or social media (Facebook, Instagram and Twitter). If you choose not to provide Personal Information, smrtr may not be able to provide you with the services you require. 

smrtr will take reasonable precautions to destroy or permanently de-identify Personal Information when it is no longer required for such functions and activities, or otherwise if requested by you in writing. smrtr will generally collect Personal Information from you directly. However, smrtr may from time to time, collect Personal Information about you from third parties such as credit reporting agencies, list brokers, or publicly available sources of information, including but not limited to LinkedIn, Twitter and Facebook.

Where smrtr collects Personal Information either directly from you or from a third party, smrtr will take reasonable steps to provide you with certain details about that collection (such as the purpose for which the Personal Information has been collected and any other matters required by the APPs). We will generally include this information in a collection notice.  Collection notices provide more specific information than this Privacy Policy. The terms of this Privacy Policy are subject to any specific provisions contained in collection notices and in the terms and conditions of particular offers, products and services. We encourage you to read those provisions carefully.

Sensitive Information

Sensitive information is a subset of Personal Information that is generally afforded a higher level of privacy protection, such as health information. smrtr only collects sensitive information where it is reasonably necessary for our functions or activities and either:

  • you have consented; or
  • we are required or authorised by or under law (including applicable privacy laws) to do so.


By providing Personal Information to smrtr, users consent to the processing of such data by smrtr as described in this Privacy Policy. Users can alter their preferences as described below.

Anonymity and pseudonyms

Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below.

Data collection

In the provision and delivery of smrtr’s services, smrtr may collect your Personal Information for or on behalf of, or as a supplier to, its clients (including agency clients who are collecting personal information for and on behalf of their clients) (Consumer and Business Data). Such Consumer and Business Data will be collected and/or used for the benefit of the client, or where the client is an agency, the benefit of the agency’s client, and such person will be referred to as the ‘End User’ for the purposes of this Policy. The nature of Consumer and Business Data may include an individual’s name, address, business/company name, role/position, telephone/mobile number, fax number, email address, Australian Business Number, age, geographical location, income, interests, opinions and needs.

smrtr collects Consumer and Business Data for the purposes of providing its services. Such services include services to source and license Consumer and Business Data to End Users, to manage and /or enhance Consumer and Business Data, to provide campaign management services and/or provide data planning consultancy and strategy services (smrtr Services). If you do not provide Personal Information, smrtr may not be able to provide the smrtr services. smrtr does not collect Consumer and Business Data unless the Consumer and Business Data is necessary to enable smrtr to perform one or more of its functions and activities.

smrtr collects Personal Information from a wide number of sources, including, but not limited to:

  • directly from you
  • publicly available sources, such as Australia Post, Australian Electoral Commission, Telstra, Australian Communications and Media Authority and Australian Securities and Investment Commission
  • other organisations, including market research organisations, to whom you have provided consent to the collection, use and disclosure of your Personal Information for direct marketing by third parties.

smrtr will take all reasonable precautions to destroy or permanently de-identify Consumer and Business Data when it is no longer required for such functions and activities, or otherwise if requested by you in writing.

smrtr will generally collect Consumer and Business Data from third parties including but not limited to list brokers, data owners and data managers (Data Suppliers) and End Users. Where smrtr collects Consumer and Business Data from a third party, smrtr will take reasonable steps to provide you with certain details about that collection (such as the purpose of collection and any other matters required by the APPs) in a privacy collection notice.

Use of data including for direct marketing purposes

smrtr will use the Consumer and Business Data in order to provide smrtr’s Services. Such Consumer and Business Data may be used to allow End Users to conduct direct marketing campaigns to you, to manage and/or enhance Consumer and Business Data, for research to enhance the End User’s services, and for any other related purpose if the related purpose would be within your reasonable expectations or for any other purpose to which you give your express or implied consent and as otherwise provided in the Privacy Act.

In order to fulfil the purposes set out above, smrtr may disclose the Consumer and Business Data to the End User, the End Users’ agents (including but not limited to advertising agencies, marketing agencies and mail houses) and to external organisations. Such external organisations include smrtr’s professional advisors, service providers, government and regulatory authorities and other organisations as required by law, organisations involved in the transfer or sale of all or part of smrtr’s assets or business, smrtr’s related entities and businesses and outsourced service providers who manage or assist with smrtr’s Services including but not limited to online file sharing and managed file transfer services, technology services, data processing, broadcasting services, marketing services and market research services. Where such Personal Information is disclosed to End Users, their agents and external organisations, smrtr will take all reasonable steps to ensure that the recipients of your Personal Information comply with this Privacy Policy, the Privacy Act, and all applicable privacy laws. 

smrtr may, with your consent, use Personal Information (other than sensitive information, as defined in the Privacy Act) for the purpose of direct marketing, including but not limited to direct mail campaigns by post, email, telemarketing and social media. Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. If you do not wish to receive direct marketing information, you can opt out at any time, by:

  1. contacting smrtr (details below);
  2. advising smrtr if you receive a marketing call that you no longer wish to receive these calls
  3. using the unsubscribe facility that we include in our commercial electronic messages (such as email and SMS).

Links to 3rd party websites

This Privacy Policy does not apply to Personal Information provided via any other website. Website users should be aware that if they access other websites, using the links provided, these are outside our control. If they provide Personal Information to other companies, the privacy policies of those companies determine the uses to which that information is put and smrtr’s Privacy Policy will no longer apply.

Access, correction and removal

If you would like to:

  1. request access to your Personal Information held by smrtr;
  2. request an amendment or correction to your Personal Information; or
  3. ask smrtr to remove your personal information from our system,

smrtr will action any valid requests,  including requests from individuals to suppress their names or otherwise remove all Personal Information previously disclosed by you, from either its own or 3rd party databases and have robust systems in place to facilitate this. Please submit this request via the contact details below.


smrtr holds your Personal Information in accordance with security provisions relevant to Australian data protection legislation and ensures stringent measures are employed to ensure that your Personal Information (including your credit card details) is protected from unauthorised use at all times. smrtr will endeavour to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. 

While we strive to protect your Personal Information, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. smrtr will notify you of any data security breaches involving your Personal Information which are ‘eligible data breaches’ under the Privacy Act.

Changes to this Policy

smrtr may amend this Privacy Policy from time to time.  The current version will be posted on our website.

Contact us

Please contact us if you have any queries about the personal information that we hold about you or if you have any complaints about the way we handle that personal information. smrtr will acknowledge receipt of your request within a reasonable period and in any event within 10 working days and endeavour to respond to your request within 30 days. Our contact details are set out below. 

Mail:  C/O – Wheeler Accounting & Taxation Pty Ltd Suite 246 117 Old Pittwater Road BROOKVALE NSW 2100


Telephone: (02) 9560 0700 

Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at or by calling the OAIC’s enquiry line at 1300 363 992.