WEBSITE PRIVACY POLICY
physiotherapy.marketing
Last updated: 20 July 2026

1. About this Privacy Policy
Communication Strategies Pty Ltd (ABN 58 645 999 882) (we, us, our) is a marketing services company based in Western Australia. We operate the New Patient Growth Grant (the Grant), a private commercial grant programme delivering professional marketing services to Australian health clinics.
We are committed to protecting your privacy and to handling personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with our website, the Grant programme, and our marketing services generally. It applies to website visitors, Grant applicants, Grant recipients, clients, and anyone else who deals with us.
By using our website, submitting a Grant application, or otherwise providing personal information to us, you consent to the handling of your personal information as described in this Privacy Policy. A shorter collection notice is also provided at the point of collection on the Grant application form; that notice should be read together with this Privacy Policy.2. What personal information we collect
The kinds of personal information we collect depend on how you deal with us. It may include:
– Identity and contact information: your name, position or role, business name, email address, telephone number, and business address.
– Grant application information: information you provide in a Grant application, including details of your clinic (name, ABN or ACN, location, specialty), your responses to the application questions, and information about your clinic’s patient acquisition position, business circumstances, and growth objectives.
– Advertising and campaign information (Grant recipients and clients) : information accessed through advertising accounts you authorise us to access or that we manage on your behalf, including campaign settings, performance data, and advertising expenditure records (see section 6).
– Communications records: records of correspondence, meetings, and phone calls with us, and feedback you provide about the Grant or our services.
– Website and technical information: your IP address, browser type, device information, pages visited, and interaction data collected through cookies and analytics tools when you use our website.Sensitive information. We do not ask for, and do not wish to receive, sensitive information (including health information). Grant applications should describe your clinic and its business circumstances only. Do not include personal information about patients in your application or in any material you provide to us. Several Grant components, including the Patient Reactivation Campaign, the Referral Partner Outreach System, and the Google Review Growth Strategy, are delivered as templates, message sequences, and systems that you operate on your own data; we supply the tools and configuration, and you perform any segmentation or sending. We do not receive, hold, or process your patients’ contact lists or other identifiable patient information. If we receive patient information or other sensitive information we have not requested, we will destroy or de-identify it where lawful and practicable to do so.
3. How we collect personal information
We collect personal information:
– directly from you: when you submit a Grant application through our website, contact us, subscribe to communications, enter into a service agreement with us, or deal with us in the course of delivering the Grant Services;
– automatically: through cookies, analytics tools, and server logs when you use our website. You can adjust your browser settings to refuse cookies, although parts of the website may not function fully if you do; and
– from advertising platforms: where you have authorised us to access, or where we create and manage on your behalf, advertising accounts (such as Google Ads) in connection with the Grant Services or our other services.
Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym, for example, when making a general enquiry. However, we cannot assess a Grant application, award the Grant, or deliver the Grant Services unless you identify yourself.
4. Why we collect, hold and use personal information
We collect, hold and use personal information for the following purposes:
– administering the Grant programme, including receiving and assessing applications, verifying eligibility, selecting the recipient, and notifying applicants of outcomes;
– delivering the Grant Services to the recipient, including campaign setup and management, audits, performance reviews, and reporting;
– creating and managing the recipient’s advertising account and verifying the recipient’s compliance with the Minimum Ad Spend condition of the Grant;
– communicating with you about your application, the Grant, or our services;
– with your consent, sending you marketing communications about our services (see section 5);
– referencing the Grant recipient’s participation in the Grant for promotional purposes (limited to the clinic’s name, suburb, and specialty), unless the recipient has objected in accordance with the Grant Terms and Conditions;
– operating, maintaining and improving our website and services; and
– complying with our legal obligations and establishing or defending our legal rights.
We only collect personal information that is reasonably necessary for these purposes, and we will not use or disclose your personal information for another purpose unless you have consented, you would reasonably expect us to do so and the purpose is related to a purpose above, or the use or disclosure is otherwise permitted or required by law.
5. Marketing communications
We may send you marketing communications about our services by email or other electronic means only where you have consented, or where consent can reasonably be inferred in accordance with the Spam Act 2003 (Cth), for example, through an existing business relationship with us.
Submitting a Grant application does not, by itself, constitute consent to receive marketing communications. Consent to marketing is sought separately through an unbundled opt-in on the application form and elsewhere on our website.
Every commercial electronic message we send will identify us as the sender, include our contact details, and contain a functional unsubscribe facility. If you opt out, we will action your request within five (5) business days. You may opt out of marketing communications at any time by using the unsubscribe facility in the message or by contacting us using the details in section 14.
We do not use or disclose your personal information for direct marketing by third parties.
6. Advertising account access (Grant recipients and clients)
Delivery of the Grant Services involves advertising and related accounts — for example, Google Ads, Google Business Profile, and website analytics accounts. Where this occurs:
– for the Google Ads account used to run your campaigns, we create and operate a dedicated campaign account within our advertising manager account. That account carries your own payment method (so the advertising platform bills you directly for your advertising spend) and is kept separate from other clients’ accounts by the platform’s own controls. The account is built with our proprietary systems and know-how and remains our account and intellectual property; it is the means by which we deliver the campaign management service and does not transfer to you at the end of the engagement. You may request a report of the performance and conversion data attributable to your own campaigns for your records;
– for other accounts, access is granted through the platform’s own user-permission systems, remains under your control, and can be revoked by you at any time (noting that revoking access may prevent us from delivering the Grant Services);
– we access and use account data only to the extent reasonably necessary to deliver the Grant Services, report on performance, and verify compliance with the Minimum Ad Spend condition;
– we do not access, collect, or use personal information about the clinic’s patients from these accounts; and
– we relinquish our access to your own accounts (such as your Google Business Profile and website analytics) at the end of the Grant Period or on earlier termination, unless we agree otherwise with you; the campaign account we create and operate under our manager account remains ours.
7. Disclosure of personal information
We do not sell personal information. We may disclose personal information to:
– our service providers, including IT, hosting, cloud storage, email, customer relationship management, and analytics providers, for the purpose of operating our business and delivering our services;
– advertising platform operators (such as Google), to the extent necessary to set up and manage campaigns on your behalf;
– our professional advisers, including lawyers, accountants and insurers, where reasonably required;
– regulators, law enforcement bodies, and courts, where the disclosure is required or authorised by law; and
– other parties with your consent.
Our service providers are only permitted to use personal information for the purpose for which it was disclosed to them.
8. Overseas disclosure
Some of our service providers and the advertising platforms we use (including Google) store or process data on servers located outside Australia, including in the United States. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure the recipient handles the information in a manner consistent with the APPs, or we rely on another basis permitted under APP 8, including your consent where applicable. By submitting a Grant application or engaging our services, you acknowledge that your personal information may be transferred to and stored by such providers overseas.
9. Security of personal information
We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include access controls limiting who within our business can access personal information, use of reputable cloud service providers with security certifications, encryption of data in transit, password and multi-factor authentication controls, and staff obligations of confidentiality.
If a data breach occurs that is likely to result in serious harm to any individual, we will comply with our obligations under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.
10. Retention and destruction
We keep personal information only for as long as it is reasonably necessary for the purposes described in this Privacy Policy, or as required by law. As a guide:
– Unsuccessful Grant applications: retained for twelve (12) months after the close of the relevant grant round (to support the integrity and auditability of the selection process), then destroyed or de-identified;
– Grant recipient and client records: retained for seven (7) years after the end of the Grant Period or client engagement, consistent with legal, accounting and record-keeping obligations;
– Marketing lists: retained until you unsubscribe or ask us to remove your details; and
– Website analytics data: retained in accordance with the retention settings of our analytics providers.
When personal information is no longer required, we take reasonable steps to destroy it or ensure it is de-identified.
11. Data quality
We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up to date, complete and relevant. Please let us know if your details change or if you believe information we hold about you is inaccurate.
12. Access and correction
You may request access to the personal information we hold about you, or ask us to correct it, by contacting our Privacy Officer using the details in section 14. We will respond to your request within thirty (30) days.
There is no charge for making a request. We will not charge you for correcting your personal information. If we charge for giving access, the charge will not be excessive and we will tell you the likely cost before proceeding.
In limited circumstances permitted by the Privacy Act, we may refuse access or correction, for example, where giving access would have an unreasonable impact on the privacy of others. If we refuse your request, we will give you written reasons and information about how you can complain about the refusal.
13. Complaints
If you believe we have breached the APPs or mishandled your personal information, please contact our Privacy Officer using the details in section 14, setting out the details of your complaint. We will acknowledge your complaint within seven (7) days and aim to resolve it within thirty (30) days.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):
– Website: www.oaic.gov.au
– Phone: 1300 363 992
– Post: GPO Box 5288, Sydney NSW 2001
14. Contact us
Privacy Officer
Communication Strategies Pty Ltd (ABN 58 645 999 882)
375 Bagot Road, Subiaco WA 6008
Email: [email protected]
15. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The current version will always be published on our website, with the date it was last updated. Material changes affecting how we handle Grant application data will be notified on the Grant application page.

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