Privacy Policy
Jane Fewings Media Pty Ltd (Trading as Pivotus)
ACN 19061483716
1/60 Edward Street, Brisbane QLD 4000
Phone: 07 3063 0227
Email: privacy@pivotus.com.au
Last updated: November 2025
1. Introduction
Jane Fewings Media Pty Ltd (trading as Pivotus) (we, our, us) respects your privacy and is committed to protecting personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the Office of the Australian Information Commissioner (OAIC) guidance (including 2024–25 tracking pixel guidance), and recognised good-practice privacy standards.
This Privacy Policy explains how we collect, use, store and disclose personal information through our website, products and services, including our Marketing Intelligence product (Services).
By using our Services, you agree to the terms of this Privacy Policy.
2. Who We Are
Pivotus is an independent media agency providing advertising services, data analytics and marketing intelligence and services.
Pivotus processes personal information for both our own business operations and for our Clients.
Client Data – When we handle personal information on behalf of a Client, the Client determines why and how the information is used. Pivotus processes this data strictly in line with the Client’s instructions.
Pivotus Data – When we collect personal information through our own website, platforms or business operations, Pivotus determines how and why that information is used.
3. Types of Personal Information We Collect
We may collect the following categories of personal information:
Personal information provided to us directly
- Name
- Email address
- Phone number
- Organisation and role
- Account and billing details
- Service-related communications and preferences
Personal information we process on behalf of our Clients
This may include:
- Lead data and form submissions
- Campaign performance data
- Website usage data captured through pixels, tags or analytics tools
- CRM-connected customer interactions
- Advertising attribution data
Pivotus does not intentionally collect sensitive information, and we take steps to ensure tracking technologies do not capture or infer sensitive categories such as health information, political views, religious beliefs, sexual orientation or information about minors.
Website and analytics data
- IP address and approximate location
- Browser type and device information
- Pages visited, session duration and interactions
- Referral source
- Cookie identifiers and advertising IDs
4. How We Collect Personal Information
We collect personal information for our Services through:
- Website forms, lead generation pages and contact submissions
- Marketing Intelligence integrations (for example, platforms used for lead capture, data transfer and workflow automation)
- Analytics tools and tracking technologies
- Advertising platforms
- Client CRM systems (only when authorised and instructed)
- Email and meeting interactions
- Applicant submissions for prospective employees
Where Pivotus uses third-party tools to transfer data as part of our Services, we follow the Client’s instructions and only retain the data required.
5. How We Use Personal Information
We use personal information for the following purposes:
Client-related processing
- Delivering the Marketing Intelligence product
- Structuring of data for analysis and visualisation of results through approved third-party platforms
- Lead delivery and transfer to client systems
- Campaign optimisation, measurement and attribution
- Troubleshooting, support, and operational improvements
Pivotus’ own business purposes
- Providing our website and digital platforms
- Responding to enquiries
- Managing accounts and billing
- Sending service and administrative communications
- Improving our website performance
- Conducting internal analytics and reporting
- Recruiting and assessing job applicants
- Complying with legal obligations
- Protecting Pivotus’ systems from fraud or misuse
6. Cookies, Tracking Pixels and Similar Technologies
Pivotus uses cookies, tags, pixels and similar technologies to support analytics, advertising measurement, optimisation and website functionality. These technologies may collect device identifiers, browser characteristics, usage metrics and interaction data.
We use the following categories of technologies on our website:
- Analytics technologies to understand site usage and improve performance
- Advertising and measurement technologies to measure campaign effectiveness and support reporting
- Conversion and attribution technologies to understand how users engage with our marketing activity
- Functional and performance technologies to support website operations
- Security and fraud-prevention technologies to maintain the integrity of our website
You can manage, restrict or disable cookies through your browser settings however this may affect the functionality of our website.
Pivotus does not trade in personal information. We do not exchange personal information for monetary or non-monetary benefit. Any personal information we process is used solely to deliver our Services and, where we act on behalf of our Clients, in accordance with their instructions.
7. Disclosure of Personal Information
We may disclose personal information to:
- Advertising technology providers
- Analytics and optimisation vendors
- Cloud hosting platforms
- CRM and automation platforms
- Dashboarding and reporting tools
- Reseller partners
- Professional advisers
- Regulators where legally required
Pivotus does not permit unauthorised third-party access to personal information, and we only disclose information where reasonably necessary for service delivery or compliance.
8. Cross-Border Disclosure
When providing our Services, personal information may be processed or stored outside Australia, including:
- United States
- European Union
- Singapore
- India
- Philippines
When our third-party providers process personal information overseas, we have processes in place to review their privacy and security practices and to confirm they apply appropriate protections to personal information.
We assess how our overseas service providers safeguard personal information so that their practices are consistent with the protections required under Australian privacy law.
9. Data Security
We take steps to protect personal information from loss, misuse, unauthorised access, modification or disclosure. Measures include:
- Access controls
- Encryption in transit and at rest where supported
- Secure data transfer mechanisms
- Two-factor authentication on core platforms
- Activity monitoring
- Staff confidentiality obligations
- Regular review of vendors and settings
Despite these measures, information transmitted to or from our Services over the internet cannot be guaranteed as completely secure. We do our best to protect personal information, but any transmission is at your own risk.
10. Retention and Deletion
We keep personal information for as long as needed to provide our Services, to fulfill the purposes in this Privacy Policy, or as required by law, whichever lasts longer.
We take steps to ensure that personal information is not kept longer than necessary for the purposes for which it was collected.
When Personal Information is no longer needed, our processes include steps to destroy, delete, or permanently de-identify it.
Retention Periods
- Client data
- 24 months after completion of the Services
- Unless data is captured as part of a Lead Generation Campaign, in which case it will be deleted upon completion of the Client Agreement.
- Pivotus data
- Commercial data – 7 years for business, audit and compliance purposes
- Recruitment data – (Prospective employees) – will be deleted when no longer required
11. Data Breaches
If we become aware of an actual or suspected data breach affecting personal information we hold, we will promptly investigate and, where the breach is likely to cause serious harm, notify the OAIC, affected Clients and individuals (where appropriate) in line with the Notifiable Data Breaches scheme.
Our process includes steps to::
- Contain the breach
- Assess the nature and scope of the breach
- Notify affected Clients and the OAIC (if applicable)
- Support Clients in notifying individuals where we process information on their behalf
- Review the incident and record the steps taken to prevent further breaches
If you believe your information has been compromised, please contact privacy@pivotus.com.au.
12. Access and Correction
You may request access to, or correction of, personal information we hold about you by contacting us at privacy@pivotus.com.au.
We may need to verify your identity before releasing information.
Please note that we cannot provide access to personal information that we process on behalf of our Clients. For requests relating to Client information, we recommend contacting the relevant company directly.
13. Complaints
If you have concerns about how Pivotus handles personal information, please contact us at privacy@pivotus.com.au.
If you are not satisfied with our response, you may lodge a complaint with the OAIC:
Office of the Australian Information Commissioner
oaic.gov.au
Phone: 1300 363 992
14. Updates to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website. Continued use of our website indicates acceptance of any updated policy.