1. Introduction

This Privacy Policy explains how Samuel Grixti, trading as The Marksman Method (ABN 64 803 990 474), a sole trader based in Victoria, Australia ("we", "us", "our"), collects, uses, discloses, and protects personal information in connection with our website, marksmanmethod.com, and the services we provide to our clients.

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Policy applies to personal information we collect about our clients, and personal information our clients' own customers may have, which we process on our clients' behalf as part of delivering the Services.

2. Two Types of Personal Information We Handle

Client information: personal and business information about you, if you are a client who has purchased or enquired about our Services.

End-customer information: personal information about your own customers or leads (for example, names, phone numbers, and message history) that is collected, stored, or processed through the website, missed-call text-back, review funnel, follow-up sequences, or unified inbox we build and run for you.

3. What Personal Information We Collect

Contact details — name, business name, email address, phone number

Billing details — collected and stored securely by our payment processor, Stripe (see Section 6)

Account and business information you provide when we set up your website and automations — e.g. business description, logo, service area, and content for your site

Communications data generated through the Services — SMS, MMS, call logs, call recordings (if enabled), and inbox messages between you and your customers

Website usage data — such as browser type, IP address, and pages visited, if you use analytics or cookies on marksmanmethod.com

4. How We Collect Personal Information

We collect personal information directly from you when you enquire about, sign up for, or use our Services. We also collect information automatically through the systems we operate for you (for example, when a customer texts, calls, or fills out a form connected to your website or automations).

5. How We Use Personal Information

To provide, operate, and improve the Services

To communicate with you about your account, billing, and support

To process payments

To meet legal and regulatory obligations

We do not use your end-customers' personal information for our own marketing purposes, and only process it as needed to deliver the Services to you.

6. Sharing Information with Third Parties

We do not sell or rent personal information. We share personal information with the following categories of trusted third-party service providers, only as needed to deliver the Services:

Stripe — for processing payments. Stripe stores and processes your billing and card details directly; we do not store your card details ourselves. See Stripe's privacy policy at stripe.com/privacy.

GoHighLevel (GHL) — the platform used to run your website hosting, SMS/MMS/calling, unified inbox, and automation workflows.

Twilio — the telephony and messaging carrier used to send and receive SMS, MMS, and calls through the Services.

These providers are only permitted to use personal information to provide their services to us, and are bound by their own privacy and security obligations. You can find GoHighLevel's privacy policy at gohighlevel.com/privacy-policy and Twilio's at twilio.com/legal/privacy.

7. Overseas Disclosure

GoHighLevel and Twilio are US-based companies, and Stripe also operates internationally. As a result, some personal information may be stored or processed on servers located outside Australia, including in the United States. Where this occurs, we take reasonable steps to ensure your information continues to be handled in a manner consistent with the Australian Privacy Principles.

8. Data Storage & Security

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. However, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal information for as long as needed to provide the Services and for a reasonable period afterwards to meet legal, accounting, or reporting obligations. If you cancel your plan, we will provide you with an export of your business data (see Section 8 of our Terms and Conditions) and will delete or de-identify personal information we no longer need to retain, except where we are required by law to keep it.

10. Access, Correction & Complaints

You may request access to, or correction of, personal information we hold about you by contacting us using the details in Section 13. We will respond to reasonable requests within a reasonable timeframe.

If you have a concern about how we've handled your personal information, please contact us first so we can try to resolve it. If you're not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

11. Cookies & Website Analytics

Our website may use cookies or similar technologies to understand how visitors use the site and to improve its performance. You can control or disable cookies through your browser settings.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "last updated" date below reflects the most recent version. Material changes will be notified to active clients by email.

13. Contact Us

If you have questions about this Privacy Policy or how we handle personal information, contact us at [email protected]

Last updated: 15 September 2026.