Privacy Policy

1. Who we are

121 Group Pty Ltd (ABN 49 152 344 780, "we", "us", "121 Group") is an Australian digital marketing agency with offices in Melbourne, Sydney and Perth. We provide marketing, creative, ecommerce and AI-augmented services to Australian healthcare groups, industrial B2B operators, and consumer / B2C brands.

2. The personal information we collect

We may collect the following kinds of personal information:

• Contact information (name, email, phone, position, employer) when you fill out a form, book a call, or correspond with us
• Business information about your organisation when you engage us as a client
• Website usage information (IP, browser, pages visited, time on page) via standard server logs and analytics
• Marketing preferences and consent records
• Information you provide when applying for employment with us

We do not knowingly collect sensitive information (as defined in the Privacy Act) without your explicit consent.

3. How we use your personal information

We use your personal information to:

• Respond to your enquiry, scope a potential engagement, or provide a proposal
• Deliver services under an engagement letter or master services agreement
• Send marketing communications you have opted in to receive (you can opt out at any time)
• Comply with legal, tax, accounting and audit obligations
• Improve our website, services and operations

4. AI-augmented service delivery

121 Group operates a production AI stack (Gemini, Imagen, Veo 3, Vertex AI, BigQuery) for service delivery. Where personal information forms part of an input or output:

• We do not use client-confidential or patient personal information to train any general-purpose AI model
• Any AI processing of client data occurs within our private Google Cloud / Vertex AI environment, with data residency in australia-southeast1 where possible
• Patient personal information from our healthcare clients is excluded from AI processing at the boundary level
• Every AI-generated output that contains, refers to, or could affect a person is reviewed by a human strategist before it is published or sent

See our AI Governance policy for the full operational detail.

5. Disclosure of your personal information

We may disclose your personal information to:

• Service providers we use to operate (e.g. Xero for invoicing, Google Workspace for email, ActiveCampaign for CRM, Resend for transactional email, Google Calendar for appointment booking, Cloudflare for hosting and security)
• Australian regulators or government bodies where required by law
• A purchaser of our business or assets, in the event of a sale (subject to confidentiality obligations)

Some of these service providers may store data outside Australia (typically the United States or the European Union). We use providers with appropriate contractual safeguards in place.

6. Data security

We hold personal information securely. Measures include encrypted storage, access control by role, authentication via Google Workspace SSO, Cloudflare Access on internal systems, and regular security review of our service providers.

7. Accessing or correcting your personal information

You have the right under the Privacy Act to ask us what personal information we hold about you, and to ask us to correct it if it is inaccurate. Email privacy@121group.io with your request.

8. Marketing opt-out

If you have opted in to receive marketing from us, you can opt out at any time by clicking the unsubscribe link in any marketing email, or by emailing privacy@121group.io.

9. Cookies and analytics

We use Cloudflare Web Analytics and standard server logs for privacy-preserving traffic measurement. We also use Google Tag Manager and Google Analytics 4 for traffic and conversion measurement, and, where you download a resource and consent, a server-side Meta Conversions API event to measure our own advertising. Analytics and advertising storage are set to denied by default and are only enabled after you accept via the consent banner. You can decline by choosing Essential only, and the site works fully without acceptance.

Our own measurement engine. This site runs Attributable, our own server-side attribution engine, on Australian infrastructure we control. It sets first-party cookies so that a visit, the ad click that led to it, and any enquiry you choose to make can be connected; when you submit a form we also record a one-way hash (never the plain text) of the email and phone you provide, together with the ad-click identifiers from your visit. This data goes only to our own systems, is never sold, and is shared with an advertising platform (Google or Meta) only in hashed form and only to measure our own advertising. Third-party tags (Google Tag Manager, GA4, Meta) load only after you accept the consent banner.

Embedded booking tool. Our "book a call" and "book an audit" pages embed a Google Calendar appointment scheduler. When that scheduler loads, Google may set its own cookies and receives your IP address and interaction data under Google's own privacy terms. If you do not wish to share data with Google, you can book by phoning us on 1300 121 979 or emailing hello@121group.io instead of using the embedded scheduler.

10. Complaints

If you believe we have not handled your personal information in accordance with the Privacy Act, please contact us first at privacy@121group.io so we can attempt to resolve the matter. If you remain dissatisfied, you can escalate to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. Updates to this policy

We may update this policy from time to time. The current version is always available at this URL with a "last updated" date.

Contact

121 Group Pty Ltd
Privacy Officer: Adam Ducquet
Email: privacy@121group.io
Phone: 1300 121 979