PRIVACY POLICY

Last updated: 29 July 2026

Three Faces Consulting Pty Ltd trading as Xpromo Australia ("Xpromo", "we", "us" or "our") respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how we collect, hold, use and disclose personal information when you:

• visit our website;
• submit an enquiry or request a quotation;
• place an online order;
• purchase products or services from us;
• supply artwork or other files;
• communicate with us; or
• otherwise interact with Xpromo.

This Privacy Policy applies to individuals and to personal information provided by representatives, employees and contacts of businesses and organisations.

1. Who We Are

Business name: Xpromo Australia Legal entity: Three Faces Consulting Pty Ltd ABN: 39 671 474 141 Email: info@xpromo.com.au Phone: 02 8014 3214

2. Personal Information We Collect

The personal information we collect depends on how you interact with us.

It may include:

• your name;
• business or organisation name;
• job title;
• email address;
• phone number;
• billing and delivery addresses;
• order, quotation and invoice information;
• product preferences and order requirements;
• artwork, logos, images and other files you provide;
• correspondence and communications with us;
• payment status and transaction information;
• information relating to refunds, disputes or chargebacks;
• website usage information;
• IP address;
• device and browser information;
• approximate location based on IP address;
• pages visited and actions taken on our website;
• marketing preferences; and
• any other information you voluntarily provide.

We do not generally require sensitive information. Please do not provide sensitive personal information unless it is reasonably necessary and we have requested it.

3. Payment Information

Online payments are processed through Stripe.

When you submit an online order, Stripe may collect and process information such as:

• cardholder name;
• billing information;
• card details;
• transaction amount;
• device and browser information;
• IP address; and
• fraud-prevention and security information.

Xpromo does not ordinarily receive or store your complete card number or card security code.

For eligible online orders, Stripe may place an authorisation hold on your payment method while Xpromo manually reviews the order. We receive information about the payment authorisation, payment status and transaction, but Stripe processes the underlying card details.

Stripe handles your information under its own privacy policy, terms and security practices.

Payments made against invoices may also be processed through Xero or another disclosed payment provider.

4. How We Collect Personal Information

We may collect personal information directly from you when you:

• complete a website form;
• request a quotation;
• place an online order;
• contact us by email, telephone or another communication method;
• approve artwork;
• make a payment;
• create or manage an order;
• subscribe to marketing communications;
• provide feedback or a review; or
• communicate with us about a delivery, complaint or refund.

We may also collect information from:

• your employer, colleague or authorised representative;
• publicly available business sources;
• payment processors;
• suppliers and production partners;
• freight and courier providers;
• analytics and website technology providers;
• marketing platforms;
• accounting and customer-management systems; and
• other service providers involved in processing your enquiry or order.

5. Why We Collect and Use Personal Information

We may collect, hold and use personal information to:

• respond to enquiries;
• prepare and provide quotations;
• review and accept online orders;
• confirm product availability;
• process payment authorisations and payments;
• prepare artwork proofs;
• manufacture, decorate and supply products;
• arrange delivery and track shipments;
• communicate about an order;
• issue invoices, refunds and credits;
• maintain accounting and business records;
• provide customer service;
• investigate faults, shortages, delivery issues and disputes;
• prevent fraud and unauthorised transactions;
• improve our website, products and services;
• analyse website performance and visitor behaviour;
• maintain website and information security;
• comply with legal and regulatory obligations;
• enforce our Terms and Conditions;
• manage business relationships; and
• send marketing communications where permitted.

We aim to collect only information reasonably necessary for our business activities.

6. Artwork and Files

When you provide logos, artwork, photographs, names, contact details or other files, those materials may contain personal information.

We may disclose those files to relevant suppliers, decorators, manufacturers and production partners where necessary to:

• prepare artwork;
• create product mock-ups;
• produce samples;
• manufacture products;
• apply decoration; or
• complete your order.

You are responsible for ensuring that you are authorised to provide us with personal information contained in artwork or files relating to another person.

We will not use customer artwork for unrelated purposes without permission, except where required or permitted by law.

7. Disclosure of Personal Information

We may disclose personal information to third parties where reasonably necessary to operate our business or fulfil an order.

These third parties may include:

• Stripe and other payment processors;
• Xero and accounting service providers;
• customer relationship management and email service providers;
• product suppliers;
• manufacturers;
• printers, embroiderers and decorators;
• artwork and graphic-design providers;
• freight, courier and logistics providers;
• information technology and website hosting providers;
• website analytics providers;
• marketing and advertising platforms;
• professional advisers, including accountants and lawyers;
• debt-recovery providers;
• fraud-prevention and security providers;
• government agencies, regulators or law-enforcement authorities where required; and
• another party involved in a proposed or completed sale, transfer or restructuring of our business.

We do not sell personal information.

Service providers are only given the information reasonably required to perform their services.

8. Overseas Disclosure

Some of our suppliers, manufacturers and technology providers may be located outside Australia.

Personal information may therefore be accessed, processed or stored in countries including:

• New Zealand;
• the United States;
• countries in Asia;
• countries in Europe; and
• other countries in which our service providers, suppliers or their infrastructure operate.

For offshore-manufactured orders, we may provide relevant order details, artwork and delivery information to an overseas manufacturer or supplier.

The privacy laws and protections in another country may differ from those in Australia or New Zealand.

We take reasonable steps appropriate to the circumstances when selecting and working with providers that handle personal information.

9. Website Analytics and Tracking Technologies

Our website may use cookies, pixels, tags, session-recording tools and similar technologies.

These technologies may collect information such as:

• IP address;
• device type;
• browser type;
• operating system;
• referring website;
• approximate location;
• pages visited;
• time spent on pages;
• links and buttons selected;
• scrolling and navigation behaviour;
• website errors; and
• whether an enquiry or order was submitted.

We may use services including:

• Google Analytics;
• Google Tag Manager;
• Microsoft Clarity;
• advertising and conversion-measurement platforms; and
• similar website-performance tools.

We use this information to understand how visitors use the website, improve performance, identify technical issues, measure advertising and improve our products and services.

Session-recording or analytics tools are intended to record interactions with the website and not complete payment-card details. Payment information is entered through the relevant payment provider.

You can restrict or block cookies using your browser settings. Blocking certain cookies may affect how parts of the website operate.

10. Marketing Communications

We may send marketing communications where:

• you have consented;
• you have requested information about our products or services;
• we have an existing business relationship with you; or
• the communication is otherwise permitted by law.

Marketing communications may include information about:

• promotional products;
• apparel;
• special offers;
• new products;
• services;
• useful content; and
• Xpromo business updates.

You can unsubscribe using the unsubscribe option contained in the message or by contacting info@xpromo.com.au.

Unsubscribing from marketing will not prevent us from sending necessary messages relating to quotations, orders, payments, artwork, delivery, security or customer service.

Australian commercial electronic messages generally require consent, sender identification and a functional unsubscribe method. Unsubscribe requests must generally be actioned within five working days.

11. Storage and Security

We may store personal information electronically and, where applicable, in physical records.

Information may be stored in:

• email systems;
• accounting software;
• customer relationship management systems;
• payment systems;
• cloud-storage platforms;
• supplier systems;
• website databases; and
• business records.

We take reasonable administrative, technical and organisational measures to protect personal information against:

• loss;
• unauthorised access;
• misuse;
• interference;
• modification;
• disclosure; and
• destruction.

However, no internet transmission or electronic-storage method is completely secure, and we cannot guarantee absolute security.

You should contact us promptly if you believe information provided to Xpromo has been accessed or used without authorisation.

12. Data Breaches

Where we become aware of a privacy or data-security incident, we will investigate it and take reasonable steps to contain and address the incident.

Where required by applicable law, we will notify affected individuals and the relevant privacy regulator.

New Zealand organisations must notify the New Zealand Privacy Commissioner and affected people where a privacy breach has caused or is likely to cause serious harm.

13. Retention of Personal Information

We retain personal information for as long as reasonably necessary to:

• process and fulfil orders;
• maintain business and customer records;
• meet taxation, accounting and legal requirements;
• handle warranty, complaint or dispute matters;
• prevent fraud;
• enforce agreements; and
• support legitimate business operations.

The retention period may vary depending on the type of information and the reason it was collected.

When information is no longer reasonably required, we may securely delete, destroy or de-identify it, subject to legal and operational record-keeping requirements.

14. Accessing or Correcting Your Information

You may contact us to request access to personal information we hold about you or ask us to correct information that is inaccurate, incomplete or out of date.

Please send requests to:

info@xpromo.com.au

We may need to verify your identity before processing the request.

In some circumstances, applicable law may permit or require us to refuse access. Where required, we will explain the reason for the refusal.

15. Privacy Complaints

Questions or complaints regarding privacy may be sent to:

Privacy Contact Xpromo Australia Three Faces Consulting Pty Ltd Email: info@xpromo.com.au Phone: 02 8014 3214

Please include sufficient information for us to understand and investigate your concern.

We will acknowledge and investigate the complaint and aim to respond within a reasonable period.

Where you are not satisfied with our response, you may be entitled to contact:

• the Office of the Australian Information Commissioner; or
• the Office of the Privacy Commissioner in New Zealand.

16. Third-Party Websites

Our website may include links to websites operated by third parties.

Xpromo is not responsible for the privacy, content or security practices of third-party websites. You should review the relevant third party's privacy policy before providing personal information.

17. Children's Privacy

Our website and services are not specifically directed towards children.

Where a person under 18 places an order, we may require confirmation or involvement from a parent, guardian or authorised adult before accepting the order.

18. Changes to This Privacy Policy

We may update this Privacy Policy when our business practices, website, service providers or legal obligations change.

The current version will be published on our website with the date it was last updated.

Material changes may be communicated through the website or another appropriate method.

19. Contact Us

For questions, requests or complaints relating to privacy, contact:

Xpromo Australia Three Faces Consulting Pty Ltd ABN: 39 671 474 141 Email: info@xpromo.com.au Phone: 02 8014 3214