PRIVACY POLICY

Starts at 60 Pty Ltd (ACN 168 338 289)  |  startsat60.com

Effective: 1 January 2026

ABOUT THIS POLICY

This policy applies to Starts at 60 Pty Ltd (ACN 168 338 289) and its group companies, including Travel at 60 Pty Ltd (ACN 615 812 121) (referred to as ‘we’, ‘us’ or ‘our’). We operate startsat60.com, an online publishing platform, and related websites, applications and services (our Services).

We are bound by the Privacy Act 1988 (Cth), the 13 Australian Privacy Principles (APPs), and the Privacy and Other Legislation Amendment Act 2024 (Cth), which received Royal Assent on 10 December 2024. This policy explains how we collect, use, store and disclose your personal information. By using our Services, you consent to the practices described in this policy. We may update this policy from time to time by publishing a revised version on our website.

PERSONAL INFORMATION WE COLLECT

We may collect the following types of personal information:

• Name, email address, phone number, and mailing or billing address
• Age or date of birth, and gender
• Credit card or other payment information, for the purpose of processing transactions
• Driver licence details or other identification documents, where required for travel or related services
• Device identifiers, IP address, browser type, geo-location, and website usage data
• Details of products, services or bookings you have requested or enquired about
• Communications, feedback, survey responses and user-generated content you provide to us

We collect this information when you register, make a booking or purchase, submit an enquiry, communicate with us, or interact with our Services. Where you make a booking on behalf of another person, you confirm that you have obtained that person’s consent and made them aware of this policy. If your personal information is provided to us by another person without your consent, please notify us immediately at [email protected].

Where lawful and practical, you may interact with us anonymously or using a pseudonym. However, this may limit our ability to provide some or all of our Services.

SENSITIVE INFORMATION

We will only collect sensitive information (such as health information) where you have given your express consent and the collection is reasonably necessary for the provision of our Services, or where collection is required or authorised by law.

WHY WE COLLECT AND USE YOUR PERSONAL INFORMATION

We collect, hold and use your personal information to:

• Provide, manage and improve our publishing, travel and group product services
• Process transactions and send booking, order or payment confirmations
• Send service updates, security alerts and information you have requested
• Send direct marketing communications, in accordance with the Spam Act 2003 (Cth) and APP 7 you may opt out at any time
• Personalise your experience on our platform and conduct analytics and research
• We may use your data to create audience segments for advertising and marketing purposes, including lookalike audiences and targeted campaigns.
• Administer promotions, competitions or surveys
• Comply with our legal obligations and resolve disputes

DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information to:

• Our employees, related group companies, agents and contractors
• Third-party travel suppliers, merchants and service providers who fulfil bookings made through our platform
• Payment system operators and financial institutions
• Analytics, advertising and technology service providers who assist us in operating our Services
• Professional advisers, including legal and accounting firms
• Any person to whom our business or assets are transferred
• Government agencies, regulators or law enforcement bodies, where required or authorised by law

We may also share your personal information with trusted third parties who hold other information about you, to develop anonymised consumer insights to improve our services. If we sell, merge or transfer any part of our business, your personal information may be disclosed as part of that transaction.

OVERSEAS DISCLOSURE

We may disclose personal information to recipients located outside Australia, including in the United States of America, United Kingdom, Ireland and Singapore, for the purposes of providing our Services and operating our technology platforms. By using our Services, you consent to this disclosure.

We will take reasonable steps to ensure that overseas recipients handle your personal information consistently with the APPs. The Privacy and Other Legislation Amendment Act 2024 (Cth) introduced a framework allowing the Governor-General to whitelist countries for overseas data transfers under APP 8. As of 1 January 2026, no countries have yet been whitelisted. We will monitor and comply with any whitelist determinations as they are made.

DIRECT MARKETING

We and our related group companies may send you marketing communications by email, SMS or other electronic means. Under the Spam Act 2003 (Cth) and APP 7, we will only send commercial electronic messages where we have your express or inferred consent, and each message will clearly identify us and include a functional unsubscribe facility. You may opt out at any time by using the unsubscribe link in any communication or by contacting us at [email protected]. Unsubscribe requests will be actioned within 5 business days.

COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies on our website to improve your experience, remember your preferences and analyse website usage. We may use cookies and tracking technologies to build profiles about your interests and behaviour in order to deliver personalised content and targeted advertising across our Services and third-party platforms. Third-party providers, including analytics and advertising networks such as Google Analytics and Facebook, may also set cookies on your device subject to their own privacy policies. You may disable cookies through your browser settings, but some features of our Services may not function as intended if you do so.

SECURITY OF YOUR PERSONAL INFORMATION

We take reasonable steps to protect your personal information from unauthorised access, misuse, loss or disclosure. Under APP 11, as strengthened by the Privacy and Other Legislation Amendment Act 2024 (Cth), we are required to maintain both technical measures (such as encryption and access controls) and organisational measures (such as internal policies, staff training and access privilege structures) to keep your personal information secure. We hold personal information in both electronic and physical form. We retain personal information only for as long as reasonably necessary to fulfil the purposes outlined in this policy, including to comply with legal, regulatory, tax, accounting or reporting obligations. When personal information is no longer required, we take reasonable steps to securely destroy or de-identify it.

If we become aware of an eligible data breach under the Notifiable Data Breaches (NDB) scheme, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable and take steps to contain the breach and limit its impact.

SERIOUS INVASIONS OF PRIVACY

The Privacy and Other Legislation Amendment Act 2024 (Cth) introduced a statutory tort for serious invasions of privacy, which came into force on 10 June 2025. This gives individuals the right to bring a legal claim directly  without first going through the OAIC where a serious invasion of their privacy has occurred.

A claim may be made on two grounds: intrusion upon seclusion (for example, unauthorised surveillance or access to personal records) and misuse of personal information (for example, over-collection, inappropriate disclosure, or unauthorised storage or modification of personal data). An individual does not need to prove financial loss to bring such a claim.

As a publishing business, we are mindful of this obligation. We take care in how we collect, handle, publish and disclose personal information about individuals, and we do not collect more personal information than is reasonably necessary for the purposes described in this policy.

AUTOMATED DECISION-MAKING

The Privacy and Other Legislation Amendment Act 2024 (Cth) introduced transparency obligations for automated decision-making under new APP 1.7 and APP 1.8. These obligations require APP entities to disclose in their privacy policies the kinds of personal information used in automated decision-making, the kinds of decisions made solely by automated systems, and the kinds of decisions where automated systems play a substantially direct role. These obligations come into force on 10 December 2026.

We use technology on our platform, including personalisation and content recommendation tools, that may use your personal information to tailor your experience. We are currently reviewing our automated systems to ensure full compliance with APP 1.7 and APP 1.8 by 10 December 2026 and will update this policy accordingly. We may use automated systems, including artificial intelligence and machine learning tools, to personalise content, recommend products, and support marketing and operational decisions. These systems may use personal information such as browsing behaviour, engagement data and preferences.

ACCESSING OR CORRECTING YOUR PERSONAL INFORMATION

Under APP 12, you have the right to request access to the personal information we hold about you. Under APP 13, you may request correction of information that is inaccurate, out of date, incomplete or misleading. To make a request, contact us using the details below. We may need to verify your identity and will respond within a reasonable time. In limited circumstances permitted by law, access may be declined, and we will inform you of the reason.

COMPLAINTS

If you consider that we have not complied with the Privacy Act 1988 (Cth) or the APPs in handling your personal information, please contact us in the first instance using the details below. We will acknowledge your complaint and respond within a reasonable period. If you are not satisfied with our response, you may lodge a complaint with the OAIC:

• GPO Box 5218, Sydney NSW 2001
• Phone: 1300 363 992
• Email: [email protected]
• Website: www.oaic.gov.au

CONTACT US

For questions about this policy, to request access to or correction of your personal information, or to opt out of marketing, please contact us at:

• Email: [email protected]
• Website: startsat60.com