Privacy Policy
Effective date: 21 September 2026
David Pham trading as Simple Growth Group (‘Simple Growth Group’, ‘SGG’, ‘we’, ‘us’ or ‘our’) respects your privacy. This Privacy Policy explains how we collect, hold, use and disclose personal information when you use our websites, submit an enquiry or booking form, schedule or attend a strategy session, communicate with us, or engage our services.
It applies to simplegrowthgroup.com.au, go.simplegrowthgroup.com.au, our strategy-session forms and calendar, email, SMS, telephone and Microsoft Teams communications, and related service delivery. Where the Privacy Act 1988 (Cth) and the Australian Privacy Principles apply to us, we comply with those requirements. We also aim to handle personal information consistently with these standards where a specific exemption may apply.
Plain-language summary
We collect only the information reasonably needed to respond to enquiries, assess campaign suitability, operate client campaigns, follow up prospective borrower enquiries, arrange appointments and deliver services.
What this policy covers
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Some business information may also be personal information when it identifies a sole trader, broker or other individual.
This policy covers prospective clients, clients, website visitors, contacts, prospective borrowers and campaign leads generated or processed through campaigns we manage for our clients, and other individuals who interact with Simple Growth Group. Our services are business-to-business and are not directed to children under 18.
Personal information we collect
Depending on how you interact with us, we may collect:
• identity and contact details, such as your name, business email address and mobile number;
• professional and business details, such as your brokerage name, website, role and primary service area;
• strategy-session qualification information, including your role, number of active loan writers, approximate monthly mortgage enquiries, capacity for additional qualified borrower appointments, current approach to paid advertising, primary service area, biggest growth challenge, and internal qualification or prioritisation information derived from those responses;
• campaign outcome and attribution information, including whether a campaign-generated enquiry or appointment was considered suitable or unsuitable, application, lodged, approved, settled or lost status, relevant outcome dates, outcome or loss reasons, and settlement or commission attribution information where reasonably necessary to measure campaign performance, administer agreed commercial arrangements or calculate performance-based fees;
• campaign-lead and prospective borrower information, where we provide services for a client brokerage, including name, contact details, service area, property or lending enquiry information, purchase, refinance or investment intent, intended timeframe, appointment information, qualification responses and other information submitted through the relevant campaign;
• appointment and communication records, such as selected date and time, time zone, Microsoft Teams meeting details, emails, SMS messages, notes and follow-up history;
• client-service information, including campaign requirements, agreed qualification criteria, service-area availability, contracts, invoices and account records;
• technical and usage information, such as IP address, browser and device type, referring URLs, approximate location, cookie identifiers, page activity and form events;
• marketing preferences, consent records and unsubscribe requests; and
• other information you choose to provide or that we are required or authorised to collect by law.
We generally do not seek sensitive information. Please do not provide sensitive information unless it is reasonably necessary for the interaction and you consent to its collection, or the collection is otherwise permitted by law.
How we collect personal information
We may collect personal information:
• from our client brokerages, their authorised personnel, CRM systems or agreed reporting processes regarding downstream outcomes of enquiries and appointments generated through campaigns we manage;
• through advertising lead forms, landing pages, campaign forms, CRM systems and related follow-up processes operated by us on behalf of our client brokerages;
• directly from you through our website, forms, calendar, email, SMS, telephone calls, Microsoft Teams meetings, proposals, contracts and service delivery;
• automatically through cookies, pixels, analytics tools, server logs and similar technologies when these are enabled;
• from a person who refers you to us, where it is reasonable to expect they have authority to provide your details;
• from public business sources, professional directories, social platforms or advertising platforms where collection is lawful and reasonably expected; and
• from service providers acting on our behalf.
If you provide personal information about another person, you must have authority to do so and, where appropriate, tell them about this Privacy Policy.
Why we collect and use personal information
We may use personal information to:
• operate advertising campaigns for our clients, respond to and follow up campaign enquiries, conduct agreed preliminary qualification, arrange appointments, deliver relevant enquiries to the client brokerage for whom the campaign was operated, track downstream campaign outcomes and attribution, measure and improve campaign performance, and where applicable administer or reconcile agreed performance-based, commission-based or other commercial arrangements;
• respond to enquiries and administer, confirm, reschedule or cancel strategy sessions;
• assess campaign eligibility, qualification criteria, business capacity and service-area availability;
• prepare a relevant strategy discussion and identify practical next steps;
• send appointment confirmations, reminders, Microsoft Teams links and related service communications;
• provide, manage, support and improve our advertising, follow-up, qualification and appointment-booking services;
• maintain CRM, customer-service, billing, accounting and business records;
• measure website and campaign performance, troubleshoot systems, prevent misuse and protect security;
• send direct marketing where you have consented or where otherwise permitted by law; and
• comply with legal obligations, resolve disputes and enforce agreements.
Our systems may use workflow rules and form responses to calculate internal qualification scores, classifications, tags or priority indicators used to help us assess campaign suitability and prioritise enquiries for human review. These tools support our internal review process; we do not currently use them to make decisions with legal or similarly significant effects about individuals solely by automated means.
If you do not provide information
You may choose not to provide personal information. However, if required information is not provided, we may be unable to respond, confirm or tailor a strategy session, assess campaign eligibility, provide a requested service, or meet legal and operational requirements.
When we disclose personal information
We may disclose personal information where reasonably necessary to:
• website, CRM, form, calendar and automation providers, including HighLevel/GoHighLevel;
• email, SMS and communications providers, including Mailgun and relevant telecommunications providers;
• Microsoft 365 and Microsoft Teams for email, documents, meetings and collaboration;
• hosting, domain, security, analytics and technical-support providers;
• advertising and analytics platforms such as Meta or Google, but only where the relevant tags, pixels or services are enabled;
• contractors, professional advisers, accountants, insurers and other providers who support our business;
• government agencies, regulators, courts, law-enforcement bodies or other parties where required or authorised by law; and
• the relevant client brokerage for whom an advertising campaign or borrower enquiry was generated, so that the brokerage can contact the prospective borrower, conduct its own assessment and provide the requested mortgage or finance services;
• a purchaser or adviser in connection with a genuine or proposed business restructure, merger or sale, subject to appropriate confidentiality arrangements.
We do not sell or rent personal information.
Overseas processing and disclosure
Some providers and their subprocessors may store or process information outside Australia, including in the United States and other countries in which they or their infrastructure providers operate. The countries involved can change as provider infrastructure and subprocessors change.
Where Australian Privacy Principle 8 applies, we take reasonable steps in the circumstances to ensure an overseas recipient handles personal information consistently with the Australian Privacy Principles, unless an exception applies. You can contact us for current information about the providers used for your interaction.
Cookies, analytics and advertising technologies
Our websites may use essential cookies for core functionality and, when enabled, analytics or advertising technologies to understand visits, measure form and campaign activity, improve performance and support relevant advertising. These tools may collect device, browser, IP address, page-view and event information.
You can control cookies through your browser and, where offered, our consent settings. Blocking some cookies may affect site functionality. Third-party tools are also governed by their own privacy policies. If we intentionally target people in jurisdictions with additional cookie-consent rules, we will review and update our consent mechanism.
Direct marketing and communications
Where required, we seek consent before sending commercial email or SMS messages. We keep records of consent and identify Simple Growth Group in our marketing communications. You can unsubscribe using the link in an email, replying STOP to an SMS where available, or contacting us. We aim to action an unsubscribe request promptly and within five business days.
Unsubscribing from marketing does not prevent us from sending necessary non-marketing communications about an appointment, active enquiry, contract or service you requested.
Calls, meetings and recordings
We may make notes during calls and meetings. If we propose to record or transcribe a call or meeting, we will notify participants and seek any consent required by applicable law before recording or transcription begins.
Data quality, security and data breaches
We take reasonable technical and organisational measures to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include access controls, account security, reputable service providers, staff or contractor confidentiality obligations, system updates and backups.
No online system is completely secure. If a suspected data breach occurs, we will assess and respond to it and, where the Notifiable Data Breaches scheme applies, notify affected individuals and the Office of the Australian Information Commissioner when required.
Retention and deletion
We retain personal information only for as long as reasonably necessary for the purposes described in this policy, to maintain legitimate business records, resolve disputes and meet legal, accounting or contractual obligations. When information is no longer required, we take reasonable steps to delete or de-identify it, subject to secure backups and legal retention requirements.
Access and correction
You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. Contact us using the details below. We may need to verify your identity before responding.
We aim to respond within a reasonable period, generally within 30 days. We usually do not charge for making a request, although we may charge a reasonable cost where permitted by law. If we refuse a request, we will explain the reasons where required and tell you about available complaint options.
Privacy complaints
If you have a privacy concern or complaint, please contact us and include enough detail for us to understand and investigate the issue. We will acknowledge the complaint promptly and aim to provide a substantive response within 30 days.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC). The OAIC generally expects you to first allow the organisation a reasonable time to respond.
Third-party links
Our websites and communications may link to third-party sites or services. We are not responsible for their privacy practices, security or content. Review the relevant third-party privacy policy before providing information.
Changes to this policy
We may update this Privacy Policy to reflect changes to our services, technology, providers or legal obligations. The current version will be published on our website with an updated effective date. Material changes may also be communicated through another appropriate channel.
Contact us
Business: David Pham trading as Simple Growth Group
ABN: 31 240 459 863
Email: [email protected]
Telephone: 0495 056 888
Privacy page: https://go.simplegrowthgroup.com.au/privacy-policy
