Core Beliefs

PRIVACY POLICY

This Privacy Policy describes how www.acesparrow.tech (the “Site” or “we”) collects, uses, and discloses your Personal Information when you engage in any free or paid consultation with us.

COLLECTING PERSONAL INFORMATION

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

DEVICE INFORMATION

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the site.

• Purpose of collection: to load the site accurately for you, and to perform analytics on Site usage to optimize our site.

• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels (including any additional tracking technologies used).

• Disclosure for a business purpose: shared with our processor “Ace Sparrow” (including any additional  vendors with whom you share this information).

ORDER INFORMATION

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers and any other payment types are accepted), email addresses, and phone numbers.

• Purpose of collection: to provide services to you to fulfill our contract, to process your payment information, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our services.

• Source of collection: collected from you.

• Disclosure for a business purpose: shared with our processor “Ace Sparrow” (including additional vendors with whom you share this information. For example, sales channels, payment gateways, shipping and fulfillment apps).

CUSTOMER SUPPORT INFORMATION

• Examples of Personal Information collected: (Modifications to the information listed above or additional information as needed)

• Purpose of collection: to provide customer support.

• Source of collection: collected from you.

• Disclosure for a business purpose: Ace Sparrow is in collaboration a partner firm under a legal agreement.

Minors

The site is not intended for individuals under the age of 18. We intentionally donot collect personal information from children. If you are the parent or guardian and believe your child has provided us with personal information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use “Ace Sparrow” to power our online store. You can read more about how “Ace Sparrow” uses your Personal Information here: https://acesparrow.tech/privacypolicy

• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

• We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases with cookies or other similar technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads

• GOOGLE - https://www.google.com/settings/ads/anonymous

• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal information to provide our services to you, which includes offering services for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

• Your consent;

• The performance of the contract between you and the site;

• Compliance with our legal obligations;

• To protect your vital interests;

• To perform a task carried out in the public interest;

• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the site, we will retain your personal information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We donot engage in fully automated decision-making that has a legal or otherwise significant effect using customer data. Our processor Ace Sparrow uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.

• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

Selling Personal Information

Exercising the right to opt-out from a sale or sharing: We do not transfer your personal data to third parties in exchange for payment. However, as noted above, we may provide the data to third party partners, such as advertising partners, analytics providers, and social networks, who assist us in advertising our products and Services to you. Because these third parties may use the data “Ace Sparrow” provides for their own purposes, “Ace Sparrow’s” provision of data to these parties may be considered a data “sale” or “sharing” (for behavioural advertising) as those terms are defined under the CCPA and other applicable US privacy laws. You can opt out of targeted advertising and any related data “sales” or “sharing” (for behavioural advertising) 

Your rights

GDPR

EEA and UK. If you are a resident of the EEA or the “Ace Sparrow” entity accountable for your Personal Data is otherwise subject to the GDPR, and you believe our processing of your information contradicts the GDPR, you may direct your questions or complaints to the Irish Data Protection Commission. If you are a resident of the UK, direct your questions or concerns to the UK Information Commissioner’s Office. You also have additional rights under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

View cookie information here: https://acesparrow.tech/cookies

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email address] or by mail using the details provided below:

706/138 Walker Street, North Sydney, NSW 2060, Australia

Last updated: 6/11/2026