Privacy Policy

1. Who we are

This Privacy Policy explains how Clyra Digital (“Clyra Digital”, “Clyra”, “we”, “us”, or “our”) collects, uses, stores, and discloses personal information. It applies to our website at https://www.clyra-digi.com (the “Site”) and to the digital services we provide, including advertising audits and managed advertising services (together, the “Services”).

• Business name: Clyra Digital
• ABN: 81 355 864 331
• Registered address: 80 Cook Road, Centennial Park NSW 2021, Australia
• Privacy contact: admin@clyra-digi.com

We are committed to protecting your privacy and handling your personal information in an open and transparent way, consistent with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and, where applicable, other data protection laws.

2. Scope

This policy covers personal information about:

• Visitors and prospects who use our Site or contact us, including those who request a free or paid audit.
• Clients who engage our Services and authorise us to access their advertising accounts.
• Where we access data within a client’s connected advertising accounts that relates to their customers, we act on the client’s behalf and the client remains responsible for that data; we process it only to deliver the Services to that client.

3. Information we collect

3.1 Information you provide to us

• Contact and audit-request details: your name, email address, company or website, the advertising platforms you use, and any message or context you submit through our forms.
• Account identifiers you share with us: for example, a Meta Business account ID or Google Ads customer ID provided so we can locate the account you have authorised us to review.
• Communications: records of correspondence when you email or otherwise contact us.

3.2 Information from connected advertising accounts

When you authorise us to access your advertising accounts (for example, by linking your Google Ads account to our manager account, adding us as a partner on your Meta Business account, or connecting your account through an authorised consent flow), we access advertising and performance data within those accounts to deliver the Services. This may include:

• Account, campaign, ad group, ad, and keyword structure and settings;
• Performance metrics such as impressions, clicks, spend, conversions, and conversion value;
• Audience, targeting, and billing-related settings necessary to audit or manage the account.

We access this data only after you have authorised it, and we use it only to provide auditing and account-management services back to you as the account owner. We do not collect login credentials for these platforms; access is granted through each platform’s own authorisation mechanism.

3.3 Information collected automatically

When you visit the Site, we may automatically collect:

• Log and device data: IP address, browser type, device information, pages viewed, and referring URLs.
• Cookies and similar technologies: used to operate the Site, remember your preferences, and measure site performance. This may include analytics and advertising technologies. You can control cookies through your browser settings; some features may not function without them.

4. How we use your information

We use personal information to:

• Respond to enquiries and provide requested audits and reports;
• Provide, operate, and improve our Services, including managing advertising accounts you have engaged us to manage;
• Communicate with you about your account, our Services, and (where permitted) relevant updates;
• Maintain the security and integrity of our systems;
• Comply with our legal and regulatory obligations.

We do not sell your personal information, and we do not use data obtained from your connected advertising accounts for any purpose other than providing the Services to you.

5. Advertising platform data: specific disclosures

5.1 Google user data (Google API Services Limited Use)

Where we access data through Google APIs (including the Google Ads API), our use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We use Google user data only to provide and improve the auditing and account-management features you have requested;
• We do not transfer or sell this data to third parties except as necessary to provide the Services, comply with applicable law, or as part of a merger or acquisition;
• We do not use this data for serving advertising;
• We do not allow humans to read this data unless we have your consent for specific data, it is necessary for security or to comply with the law, or the data has been aggregated and anonymised.

5.2 Meta (Facebook/Instagram) data

Where we access data through Meta’s platforms and APIs, we do so in accordance with Meta’s Platform Terms and Developer Policies. We access this data only with your authorisation and use it solely to deliver the Services to you. You may revoke our access at any time through your Meta Business settings.

5.3 Revoking access

You can withdraw our access to your advertising accounts at any time:

• Google Ads: unlink our manager account in your Google Ads account settings, or revoke access via your Google Account permissions.
• Meta: remove Clyra as a partner in your Meta Business settings.

On request, or following revocation, we will delete or de-identify the associated account data we hold, subject to the retention exceptions in Section 8.

6. Legal bases for processing (where applicable)

Where the EU/UK GDPR applies, we rely on one or more of the following legal bases: your consent; the performance of a contract with you; our legitimate interests in operating and improving our Services (balanced against your rights); and compliance with legal obligations. Where we rely on consent, you may withdraw it at any time.

7. How we share information

We may share personal information with:

• Service providers and sub-processors who help us operate (for example, hosting, form-handling, email delivery, and analytics providers), under obligations of confidentiality and data protection.
• Professional advisors such as lawyers and accountants, where necessary.
• Authorities or other parties where required by law, to enforce our terms, or to protect our rights, users, or the public.
• A successor entity in connection with a merger, acquisition, or sale of assets.

We do not sell personal information.

8. Data retention

We keep personal information only for as long as necessary for the purposes described in this policy, including to provide the Services, meet legal and accounting obligations, and resolve disputes. Advertising-account data accessed for an audit is retained only as long as needed to prepare and deliver the audit and any agreed follow-up, after which it is deleted or de-identified, except where we are required to retain it by law.

9. Data security

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include using encrypted (HTTPS) connections, limiting access to personal information to authorised personnel, and storing data with reputable service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your rights and choices

Depending on your location, you may have the right to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Request deletion of your information;
• Object to or restrict certain processing, and withdraw consent where processing is based on consent;
• Withdraw our access to your connected advertising accounts (see Section 5.3);
• Request a copy of certain information in a portable format (where the GDPR applies).

To exercise any of these rights, contact us at admin@clyra-digi.com. We will respond within the timeframe required by applicable law. You will not be discriminated against for exercising your rights.

11. International data transfers

We may process and store information in countries other than where you are located, including where our service providers operate. Where we transfer personal information across borders, we take reasonable steps to ensure it is handled consistently with this policy and applicable law, including putting in place appropriate safeguards where required.

12. Children’s privacy

Our Site and Services are intended for businesses and are not directed to children. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have collected such information, please contact us and we will take appropriate steps to delete it.

13. Third-party links

Our Site may contain links to third-party websites and services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

14. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above and, where changes are material, take reasonable steps to notify you. Your continued use of the Site or Services after an update constitutes acceptance of the revised policy.

15. How to contact us or make a complaint

If you have questions about this policy or how we handle your personal information, or wish to make a complaint, contact us at:

Clyra Digital
Email: admin@clyra-digi.com
Address: 80 Cook Road, Centennial Park NSW 2021, Australia

If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority. In Australia, this is the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au. If you are in the EU or UK, you may also have the right to complain to your local supervisory authority.