Privacy Policy

About this policy

This policy explains how Dan Castro and Lvin Canete, trading as Kaixcel (ABN application in progress) (Kaixcel, we, us, our) handle personal information.

We handle personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). “Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

This policy sits alongside our Terms of Use. Where we provide advertising or media buying services, a separate written agreement with the client also applies.

Two different roles — and why it matters

We handle personal information in two distinct capacities, and different parts of this policy apply to each.

• Our own contacts. People who enquire through our website, subscribe to our updates, or deal with us as clients and suppliers. We decide how that information is handled, and this policy governs it in full.
• Our clients' data. When we run advertising for a client, we may access or handle personal information belonging to that client — their customer records, CRM data, lead lists and advertising account data. In that role we act on the client's instructions under our agreement with them. The client is responsible for having the necessary consents and for its own privacy policy, and we handle the information only to deliver the services they have asked for.

If you are a customer of one of our clients and want to know how your information is handled, please contact that business directly. We will assist them in responding to you.

What personal information we collect

The kinds of personal information we usually collect and hold are:

• Contact and enquiry details — your name, email address, phone number, business website, and the monthly advertising spend range you select on our enquiry form.
• Marketing preferences — whether you have opted in to receive marketing from us, and any later opt-out.
• Technical and campaign information — your IP address, browser and device type, the pages you visit, the page you arrived on, the website that referred you, and campaign tracking parameters such as UTM tags and advertising click identifiers.
• Correspondence — records of your dealings with us, including emails, calls, meeting notes and proposals.
• Client and supplier records — for business contacts, the information needed to provide services, invoice and keep records.

We do not seek sensitive information (such as health, racial or ethnic origin, or political opinions) and ask that you do not send it to us. We do not collect government identifiers.

How we collect it

We collect personal information:

• directly from you, when you complete a form on our website, email or call us, or deal with us as a client or supplier;
• automatically, when you use our website, as described in the tracking section below; and
• occasionally from third parties, such as publicly available business sources, or a referral from someone who has recommended us — where we collect your information from someone else, we will take reasonable steps to let you know.

You do not have to give us your personal information, and you may deal with us anonymously or under a pseudonym where it is lawful and practicable. If you do not give us the details our enquiry form asks for, we may not be able to respond to you or provide services.

Why we collect, hold, use and disclose it

We use personal information to:

• respond to your enquiry and arrange a strategy call;
• prepare an audit, proposal or forecast for your business;
• provide, manage and improve our advertising and media buying services;
• plan, run, measure and optimise advertising campaigns;
• invoice, keep accounts, and maintain business records;
• send you marketing communications, where you have consented or where consent can properly be inferred; and
• meet our legal and regulatory obligations.

We only use personal information for the purpose we collected it for, a directly related purpose you would reasonably expect, or another purpose you have consented to or that the law permits or requires.

Cookies, tracking and campaign attribution

When you visit our website we record standard technical information such as your IP address, browser type, the pages you view and the site that referred you.

We also record the campaign details attached to the link you arrived on — for example UTM tags and advertising click identifiers from Meta, Google, TikTok or Microsoft. These are kept in your browser's session storage for the duration of your visit, so that if you submit an enquiry we can tell which campaign brought you to us. That information is cleared when you close your browser.

As at the date of this policy, our website does not load third-party analytics or advertising scripts, and does not set advertising cookies. If that changes we will update this policy. You can control cookies and site data through your browser settings; blocking them may affect how parts of the site work.

Advertising audiences and customer lists

Running paid advertising sometimes involves customer data. Where a client asks us to build an audience from their customer records — for example a Meta Custom Audience or a Google Customer Match list — the client remains responsible for that data and for having the consents and disclosures required to use it that way.

Before we upload or match any customer list on a client's behalf, we expect the client to confirm that they are permitted to do so and that their own privacy policy covers it. Advertising platforms apply their own terms to this kind of data, and those terms apply to the client's account and advertising.

We do not sell personal information, and we do not trade or rent contact lists.

Who we disclose personal information to

We may disclose personal information to:

• our team members, who access it only to do their job;
• service providers who help us operate — website hosting, email, workflow automation, spreadsheets and document storage, accounting, and customer communication tools;
• advertising platforms, where we run campaigns for a client and the client has instructed us to do so;
• our professional advisers, such as accountants and lawyers; and
• anyone else you have consented to, or where the law permits or requires disclosure.

We require our service providers to protect personal information and to use it only for the purpose we engaged them for.

Overseas disclosure

Some of the services we rely on are provided by organisations located outside Australia, or store data outside Australia. This means personal information we hold is likely to be disclosed to overseas recipients.

Those recipients are likely to be located principally in the United States, and may also be located in Ireland or Singapore, where our providers operate regional infrastructure. This includes our website hosting, our email and document storage, the automation service that receives our enquiry form submissions, and the advertising platforms we use on behalf of clients.

Before disclosing personal information overseas we take steps that are reasonable in the circumstances to ensure the recipient handles it consistently with the Australian Privacy Principles, including reviewing the provider's privacy and data-processing terms and preferring providers who commit to appropriate protections.

Marketing, and how to opt out

We may send you marketing about our services where you have consented — for example by ticking the optional box on our enquiry form — or where consent can properly be inferred from an existing relationship with you. We comply with the Spam Act 2003 (Cth), and every marketing message identifies us and includes a working unsubscribe facility.

If you give us your phone number and ask us to contact you, we will call or message you about your enquiry. Where we make marketing calls we comply with the Do Not Call Register Act 2006 (Cth). If you tell us you do not want to be contacted, we will stop.

You can opt out at any time by using the unsubscribe link in any message, or by emailing hello@kaixcel.com. We action opt-outs promptly. You may also ask us not to use or disclose your information for direct marketing, and to tell you where we obtained it.

How we keep information secure

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Those steps include access controls and multi-factor authentication on the accounts we use, limiting access to people who need it, using reputable providers, and reviewing the tools we rely on.

No method of transmission or storage is completely secure. If you send us information over the internet, you do so understanding that we cannot guarantee its security in transit.

If a data breach happens

If we suspect a data breach involving personal information we hold, we will assess it promptly. Where a breach is likely to result in serious harm to an affected individual and we cannot prevent that harm, we will notify the affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act.

How long we keep it

We keep personal information only as long as we need it for the purposes described in this policy, or as long as the law requires — business and tax records, for example, generally need to be kept for seven years.

When we no longer need information and we are not required to keep it, we take reasonable steps to destroy it or to de-identify it.

Automation and AI in what we do

Our services use automated tools, including advertising platform algorithms and AI systems, to analyse campaign performance, segment audiences, and recommend how budget should be allocated. These tools operate on campaign and performance data.

We do not use automated processing to make decisions that produce legal effects for you or that similarly significantly affect you. A person makes the decisions that matter, including whether we take on a client and what we recommend.

Accessing and correcting your information

You can ask us for a copy of the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Email hello@kaixcel.com and we will respond within a reasonable period — usually within 30 days.

We may need to verify your identity first. If we refuse a request, we will tell you why in writing and explain how to complain. There is no charge for making a request, though we may charge a reasonable cost for giving access in some circumstances.

Complaints

If you think we have mishandled your personal information or breached the Australian Privacy Principles, please tell us first. Email hello@kaixcel.com with the details and we will acknowledge your complaint, investigate it, and respond in writing — usually within 30 days.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner: oaic.gov.au, or by phone on 1300 363 992.

Changes to this policy

We may update this policy as our business, our tools or the law change. The version published here is the current one, and the “last updated” date above shows when it last changed. Where a change is significant, we will take reasonable steps to bring it to the attention of the people it affects.

Contact us

For any privacy question, request or complaint:

Dan Castro and Lvin Canete, trading as Kaixcel
ABN: application in progress
Business address: in process
Email: hello@kaixcel.com