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ATOM Digital

ATOM Digital Privacy & Confidentiality Policy

Privacy and confidentiality policy for ATOM Digital Pty Ltd.

ATOM Digital Privacy & Confidentiality Policy

Version: 2026-06-17

Effective Date: 17th of June 2026

1. Purpose

This Privacy & Confidentiality Policy describes how ATOM Digital Pty Ltd (“ATOM Digital”) handles Confidential Information and Personal Information received in connection with consulting, advisory, implementation, automation, artificial intelligence, systems integration, and related services.

This Policy forms part of the ATOM Digital Professional Services Terms and applies to all clients, suppliers, contractors, partners, and other parties who provide information to ATOM Digital.

2. Definitions

Confidential Information

Confidential Information means any information that:

  • is confidential by its nature;
  • is identified as confidential;
  • would reasonably be considered confidential in the circumstances; or
  • is disclosed in confidence.

Confidential Information includes, without limitation:

  • business plans;
  • pricing information;
  • financial information;
  • customer information;
  • supplier information;
  • contracts;
  • reports;
  • strategies;
  • intellectual property;
  • software configurations;
  • integrations;
  • technical documentation;
  • system architecture;
  • credentials;
  • security information;
  • commercial arrangements; and
  • information relating to employees, contractors, or stakeholders.

Confidential Information does not include information that:

  • is publicly available other than through a breach of confidence;
  • was already lawfully known to the receiving party;
  • is independently developed without reference to Confidential Information; or
  • must be disclosed by law.

Personal Information

Personal Information has the meaning given in the Privacy Act 1988 (Cth) and includes any information or opinion about an identified individual or an individual who is reasonably identifiable.

Examples may include:

  • names;
  • email addresses;
  • telephone numbers;
  • postal addresses;
  • customer records;
  • employee records;
  • financial information;
  • account information; and
  • any combination of information capable of identifying an individual.

3. Confidentiality Obligations

ATOM Digital will:

  • keep Confidential Information confidential;
  • use Confidential Information only for the purpose of delivering Services;
  • take reasonable measures to protect Confidential Information from unauthorised access, disclosure, loss, misuse, alteration, or destruction;
  • restrict access to Confidential Information to personnel and service providers who require access for legitimate business purposes; and
  • not disclose Confidential Information except as permitted by this Policy.

4. Permitted Disclosure

ATOM Digital may disclose Confidential Information:

  • with the client’s consent;
  • to employees, contractors, consultants, advisers, and service providers who require access to perform their duties;
  • where required by law;
  • where required by a court, regulator, insurer, auditor, or government authority;
  • to obtain legal, accounting, insurance, compliance, or professional advice.

Any person receiving Confidential Information on behalf of ATOM Digital must be subject to confidentiality obligations substantially equivalent to those contained in this Policy.

5. Handling of Personal Information

Where ATOM Digital receives, accesses, stores, processes, analyses, or otherwise handles Personal Information, ATOM Digital will:

  • use the information only for legitimate business purposes associated with the Services;
  • take reasonable technical, organisational, and administrative measures to protect the information;
  • limit access to authorised personnel and service providers;
  • avoid retaining Personal Information longer than reasonably necessary;
  • comply with applicable privacy laws where relevant to the Services being delivered.

6. Data Retention and Deletion

ATOM Digital seeks to minimise unnecessary retention of Personal Information.

Unless otherwise required by law, regulatory obligations, insurance requirements, or reasonable business record-keeping requirements, ATOM Digital will:

  • delete or securely destroy locally stored Personal Information within thirty (30) days of a written request from the client;
  • delete or securely destroy locally stored Personal Information within thirty (30) days of completion of the relevant work; and
  • delete or securely destroy locally stored Personal Information within thirty (30) days following termination of an engagement.

Where complete deletion is not immediately possible due to backup systems, archival systems, legal obligations, or technical constraints, ATOM Digital will take reasonable steps to ensure such information remains protected and inaccessible for operational use.

7. Security Measures

ATOM Digital implements reasonable measures designed to protect information from unauthorised access, disclosure, alteration, misuse, or loss.

Such measures may include:

  • access controls;
  • password management;
  • multi-factor authentication;
  • encrypted communications where appropriate;
  • secure cloud platforms;
  • restricted user permissions;
  • staff and contractor confidentiality obligations.

No system can be guaranteed to be completely secure and ATOM Digital does not warrant that security incidents will never occur.

8. Security Incident Notification

If ATOM Digital becomes aware of a known or reasonably suspected unauthorised disclosure, loss, or access involving client Confidential Information or Personal Information, ATOM Digital will notify the affected client as soon as reasonably practicable after becoming aware of the incident.

ATOM Digital will take reasonable steps to investigate and mitigate the impact of the incident.

9. Artificial Intelligence and Cloud Services

ATOM Digital may use commercially available software platforms, cloud services, automation tools, and artificial intelligence technologies in delivering Services.

These may include:

  • OpenAI products;
  • Microsoft services;
  • Google services;
  • Zapier;
  • Make;
  • PlatformOS;
  • Shopify;
  • Xero; and
  • other commercially available business software and technology platforms.

Where information is processed using such services, ATOM Digital will take reasonable steps to ensure those services are appropriate for business use and are used in accordance with their published privacy and security controls.

The client acknowledges that information may be processed, transmitted, or stored using cloud-based services located within Australia or other jurisdictions.

10. Service Providers and Delivery Partners

ATOM Digital may engage employees, contractors, specialist consultants, technology partners, strategic partners, or other appropriately qualified service providers to assist in delivering Services.

Where such parties require access to Confidential Information or Personal Information, ATOM Digital will take reasonable steps to ensure they are bound by confidentiality and privacy obligations substantially equivalent to those contained in this Policy.

11. Return or Destruction of Information

Upon written request from a client, and subject to any legal, insurance, regulatory, or business record-keeping obligations, ATOM Digital will take reasonable steps to:

  • return information supplied by the client; or
  • securely destroy information supplied by the client.

ATOM Digital may retain records reasonably required for:

  • legal compliance;
  • insurance purposes;
  • accounting records;
  • dispute resolution;
  • professional record keeping.

12. Duration of Confidentiality Obligations

The confidentiality obligations contained in this Policy continue for five (5) years following the completion or termination of the relevant engagement.

This clause does not limit any confidentiality obligations that may continue to apply under law or equity in relation to trade secrets or highly sensitive information.

13. Policy Updates

ATOM Digital may update this Policy from time to time.

The current version published on the ATOM Digital website applies from its stated effective date.

Material changes will apply prospectively and will not affect obligations already accrued.

14. Contact Details

Questions regarding this Policy may be directed to:

ATOM Digital Pty Ltd

Website: atomdigital.com.au