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.

This Privacy Policy sets out how the collection, disclosure, use and storage of ‘Personal Information’ (as defined in the Privacy Act 1988 (Cth) (Privacy Act) is handled by Smrtr Pty Ltd (ABN 77 137 152 599), a 100% owned subsidiary of Smrtr Holdings Pty Ltd (ABN 71 628 648 402).  

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


Why do we collect personal information and how do we use it?

Our business provides analytical, consumer insight and targeting data products and services to our clients to help them to understand consumers better and improve the marketing of their goods and services through targeted campaigns.

We may use and disclose personal information, in accordance with its permitted use, to enable the development and provision of these products and services. 

In addition to the above, we may also collect the personal information of employees, clients and suppliers for the purposes of conducting general business matters and individuals who wish to communicate with us through completing a form on the smrtr website.


What types of personal information do we collect?

We only collect personal information from, or about, individuals that is reasonably necessary for our business functions or activities.

This data may include personal information such as:

  • names
  • addresses 
  • telephone numbers 
  • email addresses
  • mobile device IDs 
  • age
  • geographical location
  • interests
  • opinions and needs


We do not collect sensitive data, as defined by the Privacy Act, such as, but not limited to, information relating to health, sexual orientation, racial or ethnic origin, political opinion/association, religious beliefs, membership of a trade or professional association and we do not collect banking or credit card information.

In conducting our business, we may also collect employee contact details such as name, address, phone number, email address, and emergency contact details. For visitor enquiries via our website, we may collect name, company, email and phone details and the business contact details of smrtr’s client and supplier representatives.

If you visit the smrtr website to read, browse or download information, our system may record the following information, which is provided by your browser:

  • the date and time of your visit;
  • the type of browser and operating system you are using;
  • your Internet Service Provider and top-level domain name (for example – .com, .gov, .au, .uk etc.);
  • the address of any referring website (for example – the previous website you visited); and
  • your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).


How do we collect personal information?

To provide our data analytics products and services we source compliant data from third party providers. We only collect personal information directly for HR operations and website and marketing analytics.

We always ensure that any information collected has been consented to by the individual and is only ever used for the purposes for which it was collected.

Where personal information is collected from third parties, we are careful to seek confirmation to ensure that it has been collected in compliance with the Privacy Act, that they are entitled to provide the information, and authorise the purposes for which it will be used.

By providing Personal Information to smrtr via the smrtr website, users consent to the processing of such data by smrtr for the purposes of:

  • Providing you with the information about smrtr products and services you have requested
  • Dealing with your requests and enquiries


So far as is reasonably possible we are happy to deal with you anonymously or under a pseudonym if you prefer. Generally, we can provide information about our products and services without requiring you to provide contact details. However, you should be aware that if you do elect to remain anonymous or use a pseudonym, it may impact our ability to provide full and detailed information, products, services or assistance to you.


To whom do we disclose the personal information?

Where the relevant consent has been provided, we may disclose the personal information to our clients, or their agents (including, but not limited to, advertising agencies, marketing agencies and mail houses) who purchase or subscribe to smrtr products or services.

Personal information is only used and disclosed under the following circumstances:

  • Consent for the use of the information has been obtained at the point of collection 
  • It is used for the purpose for which the information was collected 
  • We are required or authorised under  Australian law, or court or tribunal order 


We take reasonable steps to ensure that our data assets are only stored on Australian-located servers. However, should smrtr work 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 applies to smrtr’s use of personal information, we will take all steps reasonably required to comply with those applicable laws or regulations.


How do we maintain the security of personal information?

We recognise and acknowledge the importance of maintaining the security and protection of personal information held by smrtr to ensure against unauthorised access. We protect personal information through industry best practice measures, including secure servers with multi-factor authentication, data encryption and strict access control processes to ensure personal information is only accessed by those who need access to perform their roles. In recognition of the importance of the security of personal information, smrtr has attained ISO27001 Information Security certification. To maintain this certification, it is a requirement for all smrtr staff to complete information security training and to comply with our information security management system policies.

To the extent that we disclose any personal information to our clients, their agents or service providers, we take all reasonable steps to ensure that they implement appropriate safeguards with regard to the security of that information and comply with this Privacy Policy.

smrtr will notify you and the relevant authorities of any data security breaches involving your Personal Information which are ‘eligible data breaches’ under the Privacy Act.


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 on the smrtr website, these are outside our control. If they provide personal information to these 3rd parties, the privacy policies of those companies determine the uses to which that information is put and smrtr’s Privacy Policy will no longer apply.


How can you access, correct or remove the personal information we hold about you?

Data will not be kept for longer than is necessary and will be suppressed from our database at your request. If you wish smrtr to suppress your information from our database, you may request this via the opt-out form on this website.

If you would like us to update your personal information or believe that any of the information we hold is incorrect, please let us know via the contact us form or by emailing

Should you wish to gain access to the personal information that smrtr holds about you, you may contact us via the contact us form or by emailing We will require you to adequately identify yourself when requesting a copy of your personal information.

Generally, we are happy to provide details of the information we hold free of charge. However, to the extent permissible under law, we reserve the right to charge a nominal fee commensurate with our costs of extraction and collation of information where significant work is involved. 

Should you feel unsatisfied with the outcome of an enquiry or complaint regarding your personal information held by smrtr you can escalate the complaint by contacting the Office of the Australian Information Commissioner.


Changes to this Policy

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