Last updated: 25/11/2025

1. Introduction
   Modular Pathways Pty Ltd (ACN 690 230 918), trading as Modular Pathways (“we”, “our”, “us”) is committed to protecting your personal information and being transparent about how we collect, hold, use and disclose it. This Privacy Policy applies to our website https://modularpathways.com.au (the “Site”), and any other services we provide (unless a separate privacy policy applies).

We adhere to the Australian Privacy Principles (APPs) under the Privacy Act 1988. 

2. What is personal information?
   “Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable. It may include your name, contact details, IP address, or other identifiers.

3. What kinds of personal information we collect
   We may collect the following personal information:

• Your name, job title, company name, email address, telephone number.

• Details of your business or organisation (if you engage with us in a business capacity).

• Billing and payment information, if you purchase services from us.

• Usage information and analytics when you visit our Site (for example IP address, browser type, pages visited, referral source).

• Any other information you voluntarily provide to us (such as via contact forms, email, phone or in-person discussions).

4. How we collect personal information
   We collect personal information in a variety of ways, including:

• Directly from you when you register with us, subscribe, contact us, purchase services, or engage with us.

• Automatically when you visit our Site (via cookies and analytics tools).

• From third parties (for example payments/finance providers, marketing tools, as permitted or required).

We will only collect personal information that is reasonably necessary for our functions or services, and we try to collect it by lawful and fair means. 

5. Use of cookies and similar technologies
   When you use our Site, we may use cookies or similar technologies to collect information about your activity on the Site and to improve your experience. You may disable cookies through your browser settings, but this may affect how the Site functions for you.

6. Purposes for which we use your personal information
   We may use your personal information for the following purposes:

• To provide you with services, respond to your enquiries, process transactions, and manage our relationship with you.

• To administer and improve our Site and services (including analytics, marketing, technical support).

• To send you marketing or promotional materials (where you have consented or it is otherwise lawful).

• To comply with our legal obligations, resolve disputes, enforce our terms and policies, and protect our rights.

7. Disclosure of personal information
   We may disclose your personal information to:

• Our service providers and contractors who assist us with our operations (e.g., payment processors, hosting providers, CRM/marketing platforms).

• Third parties in connection with a restructure, merger, asset sale or business transfer.

• Where required or permitted by law (for example to comply with a court order or regulatory requirement).

• With your consent.

If personal information is disclosed to third parties, we will take reasonable steps to ensure that those recipients handle your personal information consistently with this Policy.

8. Cross-border disclosure
   Some of our service providers may operate outside Australia. Where we disclose personal information to overseas recipients, we will take reasonable steps to ensure the overseas recipients are subject to privacy obligations equivalent to the APPs, or you consent to the disclosure.

9. Data security
   We are committed to ensuring your personal information is kept secure. We implement technical and organisational measures to protect your personal information from unauthorised access, misuse, alteration or disclosure. This includes encryption, access controls, secure servers and ongoing monitoring of our systems.

While we strive to protect your personal information, no system of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Access and correction
    You may request access to the personal information we hold about you and request the correction of any error or omission in that information. If we refuse your request we will give you reasons (unless permitted by law).

To make a request, please contact us using the details below. We may require verification of your identity before granting access or making corrections.

11. Data breach notification
    If we become aware of a data breach involving your personal information that is likely to result in serious harm, we will comply with our obligations under the Notifiable Data Breaches scheme and notify you and the OAIC as required.

12. Retention of personal information
    We will only retain your personal information for as long as is reasonably necessary for the purposes for which it was collected or as required by law. After that, we will destroy or de-identify it in a secure manner.

13. Anonymity and pseudonymity
    Where practicable, you may interact with us anonymously or under a pseudonym (for example when browsing our Site). However, for some of our services you may not be able to remain anonymous if personal information is required.

14. Sensitive information
    We will not collect “sensitive information” (such as racial or ethnic origin, health information or criminal history) unless you consent and it is reasonably necessary for our functions or services, or an exception under the Privacy Act applies.

15. Marketing and opt-out
    From time to time we may send you marketing communications about our services, events or special offers. If you no longer wish to receive such marketing communications, you may opt‐out by:

• Following the unsubscribe instructions included in the email; or

• Contacting us at the details below.

16. Changes to this Privacy Policy
    We may update this Privacy Policy from time to time (for example, to reflect changes in law, technology or our services). We will post an updated version on our Site and revise the “Last updated” date. Your continued use of our Site and services after such change constitutes acceptance of the updated policy.

17. Complaints and contact information
    If you have any questions about this Privacy Policy or our handling of your personal information, please contact us:

Modular Pathway Pty Ltd
Email: info@modularpathways.com.au
Phone: 0412 241 523