Effective Date:05/09/2025

Prepared by: Halo Virtual Agency Pty Ltd (“Halo Virtual Agency”)

1. Purpose

Halo Virtual Agency is committed to protecting the privacy, confidentiality, and intellectual property of our clients, contractors, employees, and business partners. This policy outlines how we collect, use, store, and protect personal, business, and confidential information, and how our team members are required to uphold privacy and confidentiality standards.

2. Scope

This policy applies to:

• All employees, contractors, subcontractors, interns, and volunteers engaged by Halo Virtual Agency.

• All client information, whether received verbally, in writing, electronically, or via third-party systems.

• All intellectual property created by or for Halo Virtual Agency.

3. Definitions

• Personal Information: Any information that identifies or could identify an individual, as defined under the Privacy Act 1988 (Cth).

• Confidential Information: Non-public business, operational, or personal information belonging to Halo Virtual Agency, its clients, or partners.

• Intellectual Property (IP): Any content, systems, processes, templates, documents, training materials, brand assets, or other works created by Halo Virtual Agency or its employees/contractors in the course of business.

4. Collection of Information

We collect personal and business information necessary to provide our services, including but not limited to:

• Contact details of clients, staff, and contractors.

• Business systems and operational information.

• Appointment, scheduling, and communication records.

• Sensitive commercial or medical-related information, where relevant to client operations.

Information is collected fairly, lawfully, and directly from clients or with their consent.

5. Use of Information

We use collected information solely for the purpose of:

• Delivering services to clients.

• Managing internal operations.

• Fulfilling legal and regulatory obligations.

• Developing internal tools, training resources, and operational improvements.

We will never sell, rent, or disclose client information to third parties without consent, except as required by law.

6. Storage & Security

• All data is stored securely in password-protected systems and cloud platforms approved by Halo Virtual Agency.

• Access to sensitive information is restricted to authorised team members only.

• Contractors and employees are required to use strong passwords, secure devices, and follow Halo Virtual Agency’s data security protocols.

7. Confidentiality Obligations

All employees and contractors must:

• Treat all client and Halo Virtual Agency information as strictly confidential.

• Not disclose, copy, or reproduce confidential information without prior written approval.

• Continue to maintain confidentiality even after their engagement ends.

This obligation is reinforced through confidentiality clauses in all employment and contractor agreements.

8. Intellectual Property (IP)

• Any IP created by employees, contractors, or subcontractors in the course of their engagement with Halo Virtual Agency (including but not limited to SOPs, templates, marketing collateral, systems, and training materials) remains the property of Halo Virtual Agency unless otherwise agreed in writing.

• Employees and contractors must not use Halo Virtual Agency’s IP for personal or external purposes without express written permission.

• Clients retain ownership of their own brand materials and business-specific IP. Halo Virtual Agency will only use client IP for the purposes of fulfilling contracted services.

9. Contractors & Employee Agreements

• All employees and contractors of Halo Virtual Agency are required to sign a Privacy & Confidentiality Statementas part of their contracts.

• All employees and contractors are required to sign an Intellectual Property Assignment & Non-Disclosure Agreement (NDA).

• Breach of these obligations may result in termination of contract, legal action, and/or financial liability.

10. Client Rights

Clients have the right to:

• Request access to the personal information we hold about them.

• Request corrections to their personal information.

• Request deletion of their data, subject to legal obligations.

Requests can be made in writing to hello@halovirtualagency.com.au

11. Data Breach Management

In the event of a data breach:

• Halo Virtual Agency will take immediate steps to contain and investigate the breach.

• Affected clients will be notified in accordance with the Notifiable Data Breaches Scheme under the Privacy Act 1988 (Cth).

• Preventative measures will be implemented to avoid recurrence.

12. Policy Review

This policy will be reviewed annually, or sooner if legislative or operational changes require.

13. Contact

For questions regarding this Privacy Policy, please contact:

Halo Virtual Agency

Email: hello@halovirtualagency.com.au

Phone: 03 5929 1999