Yep — I can rewrite it into a stronger “Meta Lead Ads + SaaS” privacy policy that reads cleanly, covers direct marketing opt-out and data breach expectations, and adds a proper complaints/OAIC pathway (all common gaps in your current version  ).

Below is a ready-to-paste replacement.

Updated Privacy Policy (copy/paste)

Privacy Policy

Effective date: 14/01/2026

Pellucid Waters Pty Ltd (ABN 73659219431) (“we”, “us”, “our”) operates AskLuci.io (“AskLuci”, “Website”, “Services”). We respect your privacy and are committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), which require organisations to manage personal information in an open and transparent way. 

1) What this policy covers

This policy explains how we collect, use, store and disclose personal information when you:

visit our Website

submit forms (including waitlists and audits)

interact with our ads (including Meta/Facebook/Instagram Lead Ads)

use our software and related support services.

2) The personal information we collect

We may collect personal information such as:

Contact details: name, email address, phone number

Business/clinic details: clinic name, role, basic practice information you provide

Account and support information: messages, support tickets, preferences, and other information you provide via forms, chat, email or surveys

Technical and usage data: IP address, device/browser information, pages viewed, session activity, and approximate location (derived from IP)

Integration-related data (where enabled): information required to connect to third-party platforms (for example, to deliver the features you choose).

We do not intentionally collect sensitive information (e.g., health information) through marketing forms. Please do not submit sensitive health details via ad forms or general website enquiries.

3) How we collect personal information

We collect personal information:

when you submit forms on our Website

when you register interest through advertising platforms (e.g., Meta Lead Ads)

when you create an account or use our Services

when you contact us (email, chat, phone)

automatically via cookies and similar technologies (see section 8).

4) Why we collect, use and disclose personal information

We use personal information to:

provide, operate and improve our Services

respond to enquiries and provide support

set up and manage accounts and onboarding

communicate product updates, important notices, or information you request

monitor performance, security, and prevent misuse

comply with legal obligations and protect our legal rights.

5) Direct marketing and opting out

Where permitted, we may use your personal information to send you marketing communications about AskLuci, webinars, waitlists, training, and related products/services.

You can opt out at any time by:

using the unsubscribe link in an email (where provided), or

replying STOP to SMS (where provided), or

emailing us at [email protected].

Under APP 7, organisations must provide a way to opt out of direct marketing and honour opt-out requests. 

6) Who we share personal information with

We may disclose personal information to:

service providers who help us operate the Website and Services (e.g., hosting, analytics, communication tools, customer support tools)

professional advisers (e.g., legal, accounting) where necessary

regulators/law enforcement where required by law or to protect rights and safety

third-party integrations you enable, to deliver the features you choose.

We do not sell personal information.

7) Overseas disclosure

Some suppliers (such as cloud and analytics providers) may store or process information outside Australia. Where this happens, we take reasonable steps to ensure overseas handling is consistent with the APPs.

8) Cookies, analytics, and advertising pixels

We use cookies and similar technologies to:

remember preferences

understand how visitors use our Website

improve performance and user experience

measure the effectiveness of advertising (including campaigns on platforms like Meta).

You can control cookies through your browser settings. Disabling cookies may affect some site functionality.

9) Data security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure. However, no method of transmission over the internet is completely secure.

10) Data retention

We keep personal information only for as long as needed to:

provide the Services

meet legal and accounting requirements

resolve disputes and enforce agreements

After that, we take reasonable steps to delete or de-identify information.

11) Access and correction

You may request access to the personal information we hold about you and request corrections if it’s inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details in section 13.

12) Data breaches

If we experience an eligible data breach that is likely to result in serious harm, we will notify affected individuals and the OAIC as required under the Notifiable Data Breaches scheme. 

13) Complaints

If you have a complaint about how we handle your personal information, please contact us and we will respond as soon as reasonably possible.

If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC). 

14) Contact us

Pellucid Waters Pty Ltd

25 Philip Street, South Gladstone QLD 4680, Australia

Email: team @ pellucidwaters.com.au

15) Changes to this policy

We may update this policy from time to time. The latest version will be posted on our Website with an updated effective date.