Privacy Policy (Australia & New Zealand)

Who We Are

When referring to Sure Harvest, “us” or “we”, we are referring to Sure Harvest Pty Ltd (ABN 37 136 891 195 ), an Australian company based in New South Wales.

We are committed to protecting personal privacy. Accordingly, we comply with the Australian Privacy Principles (as amended or replaced from time to time) set out in the Privacy Act 1988 (Cth) (the “Act”).

Some information you provide us, or we collect from you, as part of your dealings with us is “Personal Information” under the Act. The what, how and why of Personal Information collection is explained by this Policy, as well as how we may handle, store, use and disclose Personal Information and data.

This Policy applies to you unless you give us explicit consent to act otherwise. We encourage you to read this Policy carefully so that you understand our information handling practices. By visiting, accessing or browsing our Website:, registering with us, using any of our Services, uploading any data via any of our Services or by obtaining information, products or services provided via our Website or any of our Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. Who You Are

Who You Are

When referring to “you”, we are referring to users of our Website and Services. Registered users of our Services may also be described as a “Member”.

What We Do

We provide a platform that allows you to create and send emails, and gather engagement and behavioural intelligence (data) based on interaction between your contact list(s) and your emails.

We operate these platforms via the Website:

In certain circumstances, we may also have provided email content preparation services on behalf of you.

Personal Information We May Collect

When you register with us, use our Website or Services, communicate with us via social media or direct email, phone or blogging, fill in forms on our Website, provide payment details, or you report a problem with our Website or Services, we may collect “Personal Information” including some or all of the following information:

Names (including customer names, property owner names and property tenant names), gender, age, occupation, postal, street or contact address, email address, phone number, geo-location, property details, property images, credit card details, information required for payment for products or services provided or facilitated by us, metadata including social media content (including tags, handles and other social media profile information), real estate licence details, Internet protocol (IP) address used to connect your computer, tablet, mobile or other device (each being a “Device”) to the Internet, login information (including registration passwords and usernames) and other user IDs (including for systems and third party services integrated with our Services).

By giving us access to Personal Information (including the above information), you are consenting to us collecting, storing, using and disclosing such information in line with our Terms & Conditions And Terms of Use (“Terms”) and this Privacy Policy.

Through your use of the Services or access to our Website, we may also collect technical data and attributes such as time of use/visit, duration of time spent on the Services, time zone setting, date, actions performed whilst on the Services, operating system, name and version of browser and/or hardware platform used to access the Services

Sure Harvest may use cookies and other technologies such as web beacons and JavaScript on third party websites. This allows us to collect information about your use of our Services (including your computer’s IP address). The use of these technologies allows us to deliver customised evaluation of users’ use of our Services and other websites.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your Device. Cookies contain information that is transferred to your Device’s hard drive or Device to help distinguish you from other users of our Website.

When you register with our Services, our system will place a cookie on your computer that helps manage the data flow and collection. We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

By your continued browsing of our Website and usage of our Services, you are agreeing to our use of cookies.

If you do not wish cookies to be stored on your Device, you can block them by activating the relevant setting on your browser which can usually be found in the “help” section. More information on how to do this is available here: or However please note that, if you use your browser settings to block cookies (including essential cookies) you may not be able to access all or parts of our Website. Your usage of the Website without changing your browser cookies settings will indicate your consent to usage of cookies in accordance with this section of this Policy. You can change your cookie settings at any time.

When we send emails to our Members, the email will contain pixels within the body of the email that allows us to capture data regarding who has opened the email, who has clicked on various content within the email, who has forwarded the email and other similar ‘action-based’ activity.

Similarly, we collect the same information when you send emails via our Services to the list(s) within your account. This information flows through to the reporting that you have available within the Services.

We may receive information about you if you use any other websites that we operate or may operate from time to time or other services we provide.

What We Will and Won’t Do With the Personal Information We Collect

We Will Use Personal Information:

1.To carry out our obligations arising from any contracts entered into between you and us including to register you to use the Services and the provision to you with information, products and Services that you request from us from time to time, online content and dealing with your requests and enquiries.

2.To invoice, bill and/or collect from you regarding your use of the Services. If you have contracted with the Services where credit card is the means of transacting, then we will send billing information to the relevant third party in order to process your payment. We use trusted third party credit card transactional security providers in such an instance.

3.To send you service announcements regarding upgrades/downtime etc. regarding the Services.

4.To promote our services to you and/or keep you informed of new services and/or new features and functionalities that the Services may have.

5.To comply with any applicable law, regulation, court order or other legal requirements, including supplying such information to third parties where the law so duly compels us.

6.To ensure compliance with our Terms or any other agreement between you and us and/or to enforce such compliance if necessary.

7.To respond to direct requests from you for support, and more generally, to improve and support the Services offered to you.

8.To protect our rights, our property and the rights of our customers, clients, Affiliates, Members and third parties.

9.To aggregate, analyse and improve our Services and our Website. This may include monitoring of your usage of our Services and our Website to better understand your needs and to monitor our Services usage generally to help us to develop and implement initiatives to improve our Services, our marketing or the way we do business.

10.To assist us in developing or enhancing our existing Services and our Website as well as creating new products and services.

11.To manage our Services (including your account as applicable), administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

12.To ensure that content from our Website is presented in the most effective manner for you and on your Device.

13.To allow you to participate in interactive features of our Services, when you choose to do so.

14.To act as required where the safety of ourselves, yourselves, other Members and/or third parties is at risk.

15.To facilitate interactions between you and approved third parties which provide products or services integrated with our Services.

16.To monitor interactions between you and other users of our Services for quality control purposes.

17.If necessary, to verify your identity or age (i.e. over 18).

18.To transfer information (including Personal Information) to a third party as a result of a, or a prospective, sale, merger, consolidation of us or investment in us, provided that the third party has, as a minimum, agreed to comply with all privacy laws applicable to it and adhere to terms similar to this Policy.

19.To communicate with you on the basis that it is in line with the Services and/or any specific third party promotional information or communications that you have opted-in to receive.

20.To share amongst our “Affiliates”, which means our subsidiaries, our ultimate holding company and its subsidiaries to deliver our Services to you (in accordance with our data transfer policies set out below).

21.To share with third party service providers (including, for example, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies) that we work with in order to provide the Website or Services or as may be reasonably required to manage information that you provide from time to time.

22.To share amongst our business and commercial partners, agents and service providers that we engage to perform the functions listed above on our behalf, or as may be reasonably necessary to share with them in order for us to provide products or services to you, improve our Services and develop and provide you with information about new products or services that may be of interest to you.

We Won’t Use Personal Information

We will never supply, sell or in any other knowing way, make available your Personal Information to other parties other than in the circumstances outlined above, unless you authorise us to do so.

What About Your Email Lists?

We will never knowingly supply, sell or make available the names and email addresses in your contact list(s) to other parties other than in the circumstances or for the purposes outlined above, unless you authorise us to do so.

As per our Terms, we recommend that you take regular back-ups of your contact list(s) (even though we have tight controls in this area).

What You Send To Your Lists

Even though we send emails in an extremely high security environment (please further see our Terms for additional information relating to our security standards), content is available for inspection throughout the journey – as such it is highly recommended that any material of a sensitive or confidential nature is not sent via the Services.

We reserve the right at all times to inspect or review your content to ensure that it complies with your obligations under our Terms.

What happens if you don’t provide us with information

If you don’t provide us with certain information, we may be unable to provide you the information, products or services you wish to receive.

If you wish to remain anonymous or to use a pseudonym when dealing with us, we may be able to provide you with limited information or services. However, in many cases it will not be possible for us to assist you with your specific needs if you wish to remain anonymous or use a pseudonym given the nature of the products and services we offer.

Information that is not Personal Information (De-Identified Data)

You acknowledge that we may use or modify data and information (including Personal Information) that you provide us or we collect from you, including by aggregation and other de-identifying techniques, to produce or derive a compilation of data which has Personal Information removed from it such that the identity of any individual person cannot be reasonably ascertained from the data (De-Identified Data). You agree that we own all rights, title and interest in and to the De-Identified Data and consequently we may use such De-Identified Data for our own commercial purposes. De-Identified Data is not Personal Information because the De-Identified Data does not directly or indirectly reveal the identity of a person. However, if we combine or connect De-Identified Data with other data so that the identity of a person can be reasonably ascertained, we will treat the combined or connected data as Personal Information which may only be used, disclosed, stored and transmitted in accordance with this Privacy Policy and the sections of our Terms that apply to Personal Information.

Other Sources of Information Collection

Our Website and/or the Services may have links to other websites, social media platforms, blogs and/or other similar-type sites, platforms or third party products (“Third Party Sites”). We may also work with third party service providers (including, for example, sub-contractors in technical, payment and delivery services, analytics providers, search information providers, credit reference agencies), including to manage information that you provide from time to time (“Third Party Service Providers”).

When we use Third Party Service Providers, we use reasonable efforts to share with them Personal Information only to the extent permitted by the Act and to make sure they are as careful with your Personal Information as we are. We may disclose or transfer Personal Information to Third Party Service Providers and our Hosting Service Provider to be stored overseas (see “Hosting and Transfer of Information we collect” below).

We may receive information about you from Third Party Sites and Third Party Service Providers. Generally speaking we have no control over what information you may pass over to Third Party Sites or Third Party Service Providers and they are not subject to this Policy. Any such information that you disclose to Third Party Sites and Third Party Service Providers will be subject to their own privacy policies or other terms, of which you should make yourself aware. You acknowledge and agree that we are not responsible for any Personal Information you choose to disclose to a third party through any Third Party Sites or Third Party Service Providers, even if referred to by or linked to any of our Websites or Services, and that such third parties may store Personal Information you disclose to them in any location in accordance with their own security standards.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Hosting and Transfer of Information we collect

We engage a third party Hosting Service Provider to provide data storage services and to store Personal Information, data and information submitted by users of our Services. Our Hosting Service Provider and other third party service providers may transmit, maintain and store all or parts of Personal Information, data and information on multiple servers across various jurisdictions in addition to servers in Australia. Servers in which information (including Personal Information) may be stored by our Hosting Service Provider and other third party service providers are likely to be located in Australia, New Zealand, Singapore and the United States, although additional or other locations may be used by our Hosting Service Provider or other third party service providers in the future.

By providing us with information (including Personal Information), using our Website or Services or registering to use any of our Services, you: (a) consent to us transferring Personal Information, data and information (including the categories of Personal Information listed in this Privacy Policy) to our Hosting Service Provider and any other third party provider for the purpose of allowing our Hosting Service Provider and third party service providers to host all data necessary to support our Website and the Services you use and for us to provide, and facilitate payment for, the information and services accessible via our Website and Services; and (b) consent to us, our Hosting Service Provider and any other third party service provider, transmitting, maintaining and storing Personal Information, data and information (including the categories of Personal Information listed in this Privacy Policy) between and on servers located outside of Australia, including in the regions referred to above. We may engage other data storage providers or store your information (including Personal Information) on servers in other locations in the future and will update this Privacy Policy if that is the case.

How long do we keep your Personal Information secure and private?

We keep Personal Information only for as long as is reasonably necessary for the purpose that it has been processed and taking into account any legal requirements under the Act or any other applicable laws of New South Wales, Australia.

Safety and Security


All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology.

It is important for you to protect against unauthorised access to your password and to your computer so we advise that you sign off when you have finished using a shared computer and strongly recommend and that you do not use the browser’s password memory function as that would permit other people using your Device to access your Personal Information.


We operate a ‘one-way’ password security system – that is, each password is encrypted and sent only to you. We cannot RESEND a password, as we do not store it. We can only reset a password upon request.

Without stating the obvious, you should never share your password – it is the gatekeeper to your List protection. Anybody who leaves your organisation should have the access to the Services terminated immediately.

The Dreaded Hack

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website and any transmission is at your own risk.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss, interference, use, destruction, modification or disclosure of your Personal Information. However, we cannot guarantee the security of such information and, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alterations of any information you submit to our Website.

We will also comply with the notification and other requirements of the Act where your Personal Information held by us has been inadvertently lost or disclosed or improperly accessed and that loss, disclosure or access may result in serious harm to the person to whom the Personal Information relates.

Your rights

You can always choose not to provide information. If the information is needed for a transaction or process, then the transaction or process will not proceed.

You will usually be able to add or update certain information on pages such as “My Account”. When you update information, we will keep a copy of the prior version for our records unless you write to us to require us not to.

The Act gives you the right to access Personal Information held about you and to request that it is corrected if any of your details held are incorrect. Your right of access can be exercised in accordance with the Act. If you wish to access your Personal Information, or believe that any of the Personal Information we hold about you is inaccurate, incomplete, irrelevant, out-of-date or misleading, please contact us via email to We will respond to any access request within a reasonable period. Any access request may be subject to a fee of $20 to meet our costs in providing you with details of the information we hold about you. We will take reasonable steps to correct any inaccurate, incomplete, out-of-date, irrelevant or misleading Personal Information if you request us to do so, where required by law. If we decline to make the requested amendment for reasons permitted by the Act, if you ask us to do so, we will include a note with that Personal Information in your file that you have requested it to be amended.

If you wish to verify the details that we hold about you may do so by contacting us via e-mail to Our security procedures mean that we may request proof of identity before we reveal information.

We may withhold or refuse you access to Personal Information if we are legally authorised to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person. We will give you reasons explaining why we have refused access, or refused access in the form you have requested, unless it would be unreasonable to do so, having regard to the reasons for our refusal.

If you would like to know more about data protection generally, there is information available from the Australian Information Commissioner at the following website –

How can you stop receiving marketing information?

Where marketing information is forwarded to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message. If you no longer wish to be contacted by us or receive such marketing information, you can advise us by emailing us at or by clicking the ‘unsubscribe function’ (where marketing information is sent electronically).

We will keep a record of your request to ensure you do not receive that information in the future.

You cannot refuse to receive information which we are required to provide you by law.

Date of Effectiveness

This Policy as it stands and published by our Website is effective from the date of you commencing to use the Services.


We reserve the right to make changes to this Policy at any time. Such changes will be posted via the Website. We will also advise you of any substantive changes by presenting you with the revised Policy when you first log into the platform following the change. We suggest that you visit our Website regularly to keep up to date with any changes.

Jurisdiction and governing law

All matters relating to the Website are governed by the laws of New South Wales, Australia, without reference to conflict or choice of law principles. You agree that the jurisdiction and venue for any legal proceeding relating to our Website and this Policy shall be in appropriate courts located in New South Wales, Australia. We do not warrant or imply that the Website or materials on it are appropriate for use outside of this jurisdiction. The information contained on our Website concerning any products or services is applicable only in the jurisdiction and these products or services may not be available in all locations. If you are located outside of this jurisdiction, you are solely responsible for compliance with any applicable local laws.


If you still require clarification on any aspect of our Policy, please use the “Contact Us” feature on our Website, or alternatively, write to or email us at:

Sure Harvest Pty Ltd
Privacy Department
PO Box 388
Sydney Markets NSW 2129

If you have a complaint, then we will take reasonable steps try to resolve the complaint with you as quickly as practicable. Complaints may also be made directly to the office of the Australian Information Commissioner through its website located at


For the purposes of this Policy:

Hosting Service Provider means Amazon Web Services and any other person or entity we may engage from time to time to provide data hosting and storage services in connection with the Website or Services or to provide serving infrastructure which operates under our direction.

Personal Information means any information or data that you provide us in any form from time to time which relates to a living individual who can be identified from, or whose identity is apparent or can reasonably be ascertained from, that information or data alone or in conjunction with other information already held by the recipient, controller or processor of such information or data and includes any expression of opinion about the individual and any indication of the intentions of the recipient or any other person in respect of that individual.

Services means any website, product, service or software solution operated or provided by us and our related companies from time to time via any distribution platform (including online and via mobile applications), including any services described in this Policy.

Website means the website located at, any website that may replace that website, and any other website from which we may provide or facilitate provision of the Services from time to time.

This Policy should be read in conjunction with the Terms that apply to the Services you use.