PRIVACY POLICY
Effective date: 30 June 2026 (replaces all prior versions)
Creative Ground (“Creative Ground“, “we“, “us“, “our“) is committed to providing quality services to you, and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (“APPs“) contained in the Privacy Act 1988 (Cth) (the “Privacy Act“), as amended (including by the Privacy and Other Legislation Amendment Act 2024). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of the Office of the Australian Information Commissioner (“OAIC“) at www.oaic.gov.au.
This policy applies to our website https://creativeground.com.au, and to all services we provide, including web design, SEO, Google Ads, hosting, graphic design, and printing.
What is Personal Information and why do we collect it?
Personal Information is information or an opinion that identifies an individual, or from which an individual is reasonably identifiable. Examples of Personal Information we collect include: names, addresses, email addresses, phone and fax numbers, business details, billing information, and information you provide when you contact us or use our services.
This Personal Information is obtained in many ways, including through correspondence, by telephone, by email, via our website, from your website, from cookies and analytics tools, and from third parties. We don’t guarantee the website links or privacy practices of authorised third parties.
We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients, processing payments, and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing and marketing lists at any time by contacting us in writing or by using the unsubscribe link in our communications.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
Cookies and website analytics
Our website uses cookies and similar technologies to help the site function, to remember your preferences, and to understand how visitors use the site. We may use third-party analytics and advertising tools (for example Google Analytics and the Google Ads / Meta advertising platforms) that set cookies and collect information such as your IP address, device and browser type, pages visited, and referring URLs. This information is generally used in aggregated or de-identified form.
You can control or disable cookies through your browser settings. Disabling cookies may affect the functionality of parts of our website.
Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record, health information, and biometric information.
Sensitive information will be used by us only:
- For the primary purpose for which it was obtained;
- For a secondary purpose that is directly related to the primary purpose;
- With your consent; or
- Where required or authorised by law.
How we use Artificial Intelligence (AI)
We use artificial intelligence and machine-learning tools to help deliver our services efficiently — for example, AI-assisted design, content drafting, SEO research, code assistance, image generation, customer support, and website security monitoring (including the AI Machine Learning Assistant referred to in our Terms and Conditions).
When we use these tools, we apply the following safeguards:
- We do not input your sensitive information, or confidential personal information about you or your customers, into publicly available generative AI tools (such as public chatbots) unless we have a lawful basis and, where required, your consent.
- Where AI tools generate or infer information about an identifiable individual, we treat that output as Personal Information and handle it in accordance with the APPs.
- We take reasonable steps to check the accuracy of AI-assisted outputs before they are relied upon or delivered, and we apply human review. AI outputs can contain errors (“hallucinations”) and should not be treated as a substitute for professional verification.
- We select AI service providers that offer appropriate privacy, security, and data-handling terms, and we do not knowingly permit your Personal Information to be used to train third-party AI models without a lawful basis.
This approach is consistent with the OAIC’s Guidance on privacy and the use of commercially available AI products (October 2024).
Automated decision-making
From 10 December 2026, the Privacy Act requires organisations to disclose where they use computer programs to make, or to substantially assist in making, decisions that could reasonably be expected to significantly affect an individual’s rights or interests.
Creative Ground does not use automated decision-making or AI to make decisions that produce legal or similarly significant effects about you (such as decisions about pricing eligibility, credit, or whether to accept or refuse you as a client). Any such decisions are made by our staff. If this changes, we will update this policy to describe the kinds of Personal Information used and the kinds of decisions involved, as required by APP 1.
Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
We engage trusted third-party service providers to help us deliver our services — for example, hosting and infrastructure providers (such as Google Cloud Platform and Digital Pacific), email and marketing platforms, payment processors, analytics and advertising providers, and AI service providers. These providers may handle your Personal Information only for the purpose of providing services to us, and are required to protect it.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances, including the following:
- To third-party service providers who assist us in operating our business and delivering our services;
- Third parties where you consent to the use or disclosure; and
- Where required or authorised by law.
Overseas disclosure
Some of our third-party service providers (including hosting, AI, email, and analytics providers) may store or process data on servers located outside Australia, or may be located overseas. Where we disclose Personal Information to an overseas recipient, we take reasonable steps to ensure the recipient handles it consistently with the APPs, except to the extent permitted under APP 8.
Security of Personal Information
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most Personal Information is or will be stored in client files, which will be kept by us for a minimum of 7 years.
Data breaches
We have processes in place to identify and respond to data breaches. If we become aware of a data breach that is likely to result in serious harm to any individual whose Personal Information is involved, we will notify the affected individuals and the OAIC in accordance with the Notifiable Data Breaches scheme under the Privacy Act.
Access to your Personal Information
You may access the Personal Information we hold about you and ask us to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Creative Ground will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information, we may require identification from you before releasing the requested information.
Maintaining the quality of your Personal Information
It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and continue to provide quality services to you.
Policy updates
This policy may change from time to time and the current version is available on our website. The “Effective date” at the top of this policy indicates when it was last updated.
Privacy Policy complaints and enquiries
If you have any queries or complaints about our Privacy Policy, or about how we have handled your Personal Information, please contact us at:
Creative Ground 30 Galeen Drive, Burleigh Waters, QLD 4220, Australia [email protected] 0449 679 519
We will respond to your complaint within a reasonable time. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling 1300 363 992.