1. Introduction
SBR Guide ("we", "our", or "us") is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Privacy Policy explains how we collect, use, disclose, store, and safeguard your personal information when you visit our website sbrguide.com or use our services.
By using our website or submitting information to us, you consent to the collection and use of your personal information as described in this policy.
2. About Us
SBR Guide is an independent information resource that helps business owners understand Small Business Restructuring (SBR) and connects them with licensed restructuring practitioners. The website sbrguide.com is operated by SUG Labs International Ltd ("we", "our", or "us").
For privacy enquiries, contact us at: hi@sbrguide.com
3. What Personal Information We Collect
The types of personal information we may collect include:
Information you provide directly:
- Name and contact details (email address, phone number)
- Business name, ABN, and business information
- Responses to our eligibility questionnaire (including financial situation)
- State or territory location
- Industry or business type
- Communications you send to us via contact forms or email
- Any other information you choose to provide
Information collected automatically:
- IP address and approximate geographic location
- Browser type, version, and device information
- Operating system
- Pages visited, time spent on pages, and navigation paths
- Referral source (how you found our website)
- Date and time of your visit
- UTM parameters and marketing campaign data
Sensitive information:
We do not intentionally collect sensitive information (such as health information, religious beliefs, or criminal records). If you provide sensitive information voluntarily, you consent to us collecting it for the purpose for which you provided it.
4. How We Collect Personal Information
We collect personal information through:
- Our eligibility assessment forms
- Contact forms on our website
- Email and phone communications
- Cookies and web analytics tools
- Third-party sources where you have consented to share information with us
Anonymity and pseudonymity
Where practicable, you may interact with us anonymously or using a pseudonym. However, if you do not provide certain personal information, we may not be able to assess your eligibility for SBR or connect you with a restructuring practitioner.
5. Why We Collect and How We Use Your Information
We collect and use your personal information for the following purposes:
- • Service delivery: To assess your eligibility for Small Business Restructuring and provide relevant information
- • Practitioner connections: To connect you with licensed ASIC-registered restructuring practitioners who can assist your business
- • Communication: To respond to your enquiries and provide customer support
- • Marketing: To send you relevant information, updates, and educational content (with your consent)
- • Website improvement: To analyse usage patterns and improve our website and services
- • Legal compliance: To comply with our legal and regulatory obligations
- • Business operations: For internal record keeping and administrative purposes
We will only use your personal information for the primary purpose for which it was collected, or for a secondary purpose that you would reasonably expect, unless we have your consent.
6. Disclosure of Your Information
We may disclose your personal information to:
Licensed restructuring practitioners
When you submit an eligibility form or request a consultation, we share your contact details and relevant business information with selected ASIC-registered practitioners so they can contact you. You will be informed which practitioners will receive your information.
Service providers
Third-party providers who assist us in operating our website and delivering services, including:
- Website hosting and edge infrastructure (Cloudflare, Inc. — USA)
- Database and backend services (Supabase, Inc. — USA)
- Email delivery (Resend)
- Payment processing for practitioner accounts (Stripe, Inc. — USA). Stripe tokenises card details; we store only the resulting token, not card numbers. See Stripe's privacy policy.
- Website analytics (Google Analytics and Cloudflare Web Analytics)
Other disclosures
- Professional advisers: Accountants, lawyers, or other professional advisers as required
- Law enforcement and regulators: When required by law, court order, or to comply with legal obligations
- Business transfers: In connection with any merger, acquisition, or sale of business assets
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
7. Cross-Border Disclosure
Some of our service providers may be located outside Australia. When we disclose personal information to overseas recipients, we take reasonable steps to ensure they comply with the Australian Privacy Principles or are subject to substantially similar privacy laws.
Our service providers may be located in:
- United States (website hosting with Cloudflare, backend services with Supabase, payment processing with Stripe, analytics with Google)
- European Union (certain software providers)
By providing your personal information to us, you consent to this cross-border disclosure. We will take reasonable steps to ensure overseas recipients handle your information in accordance with the APPs.
8. Data Security
We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:
- SSL/TLS encryption for data transmitted through our website
- Secure hosting with Cloudflare's enterprise-grade infrastructure
- Access controls limiting who can access personal information
- Regular security reviews of our systems
- Secure destruction of personal information when no longer required
However, no method of electronic transmission or storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
9. Data Retention
We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Generally:
Eligibility enquiries
Up to 2 years after last interaction
Contact form submissions
Up to 2 years
Analytics data
Aggregated, anonymised form
Marketing consent records
Duration of subscription + 2 years
When personal information is no longer required, we will take reasonable steps to securely destroy or de-identify it.
10. Your Rights Under Australian Privacy Law
Under the Privacy Act 1988, you have the following rights:
Access
You can request access to the personal information we hold about you. We will respond within 30 days. In some circumstances, we may charge a reasonable fee. We may refuse access in certain circumstances permitted by law.
Correction
If you believe the personal information we hold about you is inaccurate, incomplete, or out of date, you can request that we correct it. We will respond within 30 days.
Deletion
You can request that we delete your personal information. We will comply unless we are required to retain the information by law or for legitimate business purposes.
Marketing opt-out
You can opt out of receiving marketing communications at any time by clicking "unsubscribe" in our emails or contacting us directly. We will process your opt-out request promptly and at no cost.
To exercise any of these rights, please contact us at hi@sbrguide.com
11. Direct Marketing
We may use your personal information to send you marketing communications about our services and educational content related to Small Business Restructuring. We will only do this if:
- You have consented to receive marketing communications, or
- You would reasonably expect to receive such communications based on your interaction with us
Every marketing communication will include a simple way to opt out. If you opt out, we will stop sending you marketing materials promptly (and within 5 business days at most).
We do not provide your personal information to third parties for their direct marketing purposes without your explicit consent.
12. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to improve your experience on our website. Cookies are small text files stored on your device that help us remember your preferences and understand how you use our site.
Types of cookies we use:
Essential cookies
Required for the website to function properly. Cannot be disabled.
Analytics cookies
Help us understand how visitors interact with our website.
Marketing cookies
Measure advertising effectiveness and show relevant content.
Preference cookies
Remember your settings and preferences for a better experience.
Managing cookies
You can control cookies through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling cookies may affect the functionality of our website.
To opt out of Google Analytics tracking across all websites, you can install the Google Analytics Opt-out Browser Add-on.
13. Third-Party Links
Our website may contain links to third-party websites, including ASIC, the ATO, and licensed restructuring practitioners. These websites have their own privacy policies, and we are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party websites you visit.
14. Children's Privacy
Our website and services are not intended for children under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately and we will delete the information.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:
- Update the "Last updated" date at the top of this page
- Post the updated policy on our website
- Where appropriate, notify you by email if you have provided your contact details
We encourage you to review this Privacy Policy periodically. Your continued use of our website after any changes constitutes acceptance of the updated policy.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact us:
We aim to respond to all privacy-related enquiries within 14 days.
17. Complaints
If you believe we have breached the Australian Privacy Principles or mishandled your personal information, we encourage you to contact us first so we can try to resolve your concerns.
To make a complaint:
- 1 Email your complaint to hi@sbrguide.com with "Privacy Complaint" in the subject line
- 2 Include details of your complaint and any relevant information
- 3 We will acknowledge your complaint within 7 days
- 4 We will investigate and respond to your complaint within 30 days
If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Phone: 1300 363 992
Online complaint form: www.oaic.gov.au/privacy/privacy-complaints