Privacy Policy

This Privacy Policy explains how Photon Leads collects, holds, uses, and discloses personal information in connection with the operation of our solar lead generation platform. It applies to all personal information collected through our website at https://photonleads.com (the "Website"), via social media lead-capture forms, through our automated Voice Agent telephone system, and in any other interactions you may have with us.

This Privacy Policy has been prepared in accordance with the Privacy Act 1988 (Cth), as amended by the Privacy and Other Legislation Amendment Act 2024, and in compliance with all 13 Australian Privacy Principles (APPs) set out in Schedule 1 to the Privacy Act.

By providing your personal information to us, you consent to the collection, use, and disclosure of your information as described in this Policy. If you do not agree with this Policy, please do not provide your information or use our services.

Company Name: Photon Leads ABN: 33 738 179 228 Registered Address: Suite 329, Level 3, 98-100 Elizabeth Street, Melbourne VIC 3000, Australia Privacy Contact Email: privacy@photonleads.com Phone: +61 468 030 808 Website: https://photonleads.com

- Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) 1–13

• Privacy and Other Legislation Amendment Act 2024 (effective December 2024), including enhanced notification and security obligations and automated decision-making disclosure requirements (to be implemented by December 2026)
• Spam Act 2003 (Cth) — governing commercial electronic messages
• Do Not Call Register Act 2006 (Cth) — governing unsolicited telemarketing calls
• Telecommunications (Telemarketing and Research Calls) Industry Standard 2017 (Cth)
• Relevant surveillance device legislation in each state and territory governing call recording
• Competition and Consumer Act 2010 (Cth) and the Australian Consumer Law — governing fair trading and consumer protection

When you submit a lead form through our Website or a social media advertisement, we collect the following categories of personal information:

- First Name — your given name, used to personalise communications and identify you.

• Last Name — your family name, used for identification and provider referral.
• Email Address — used to send confirmation messages and for provider referral.
• Phone Number — used to initiate Voice Agent calls and for provider referral.
• Residential Address — used to determine your location for matching with local solar providers.
• Electricity Bill Amount — your current or projected electricity bill value, used to assess suitability for solar installation and to help providers prepare accurate quotes.
• Property Type — if provided, used to assist providers in assessing installation suitability.
• Roof Type / Ownership Status — if provided, used to assist providers in assessing installation suitability.

  4.2 Information Collected During Voice Agent Calls

  When our Voice Agent system contacts you by telephone, we may collect:

  - Verbal confirmation or correction of information already provided

• Additional information you provide during the call regarding your property, energy usage, or solar interests
• A voice recording of the call (subject to the call recording disclosures in Section 8)
• Metadata associated with the call, including call duration, timestamps, and call outcome data

  4.3 Information Collected Automatically

  When you visit our Website, we may automatically collect the following technical and usage information:

  - Internet Protocol (IP) address

• Browser type, version, and operating system
• Referring URL and exit pages
• Pages visited, time spent on pages, and links clicked
• Device type and screen resolution
• Cookie identifiers and similar tracking data (see Section 12 for details)

  Where this information is combined with other information we hold about you, or where your identity is reasonably identifiable from the information, we will treat it as personal information.

  4.4 Information We Do Not Collect

  Photon Leads does not intentionally collect sensitive information as defined by the Privacy Act 1988 (Cth). This includes information about health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal records, or financial information beyond electricity bill values. If you inadvertently provide sensitive information, we will take reasonable steps to destroy or de-identify it unless required by law to retain it.

- Website lead submission forms completed by you directly

• Lead capture forms embedded in social media advertising on platforms including Meta (Facebook and Instagram), Google Ads, TikTok, and similar platforms
• Voice Agent telephone calls made to you following your lead submission
• Email correspondence you initiate with us
• Automated technical collection through cookies and web analytics tools as you interact with the Website (see Section 12)

  Where practicable, we collect personal information directly from you. Where we receive your information indirectly (for example, through a social media platform's lead generation form), we will take reasonable steps to notify you that we have collected your information and to direct you to this Privacy Policy.

- Lead Generation and Referral — to process your lead submission and refer your information to Accredited Solar Providers who service your area, enabling them to contact you with a solar installation quote.

• Voice Agent Qualification — to use our automated Voice Agent system to contact you, verify your information, collect additional qualifying information, and confirm your interest in receiving a solar quote.
• Communication — to communicate with you about your lead submission, including sending confirmation emails and SMS messages.
• Quality Assurance — to record and review Voice Agent calls for training, quality improvement, verification, and compliance purposes.
• Marketing (with consent) — to send you information about solar products, services, government rebates, or related matters where you have consented to receive such communications.
• Analytics and Improvement — to analyse aggregate, de-identified data about how users interact with our Website and services, for the purpose of improving our platform.
• Legal Compliance — to comply with applicable laws, regulations, court orders, or lawful requests from government or regulatory bodies.
• Dispute Resolution — to investigate and respond to complaints or disputes, including those involving call recordings.

The primary purpose of collecting your Lead Information is to disclose it to Accredited Solar Providers who service your area. By submitting your Lead Information through our platform, you expressly consent to Photon Leads transmitting your information (including your name, contact details, address, and electricity bill information) to Accredited Solar Providers.

Accredited Solar Providers are required to: use your information solely for the purpose of preparing and delivering a solar installation quote; not disclose your information to any further third party without your consent; handle your information in accordance with the Privacy Act 1988 (Cth); implement and maintain appropriate security measures; and delete your information within a reasonable period if you do not proceed.

Once your information has been transmitted to an Accredited Solar Provider, Photon Leads is not responsible for how that provider subsequently handles your information. We recommend that you review the privacy policy of any Accredited Solar Provider that contacts you.

7.2 Technology and Service Providers

We may disclose your personal information to third-party technology and service providers who assist us in operating our business, including cloud hosting and data storage providers, CRM software providers, Voice Agent technology providers, email and SMS communication service providers, and web analytics and advertising technology providers. These service providers are engaged on a contractual basis and are not authorised to use your information for their own purposes.

7.3 Legal Disclosures

We may disclose your personal information where required by law, including in response to a court order, subpoena, or request from a law enforcement agency or regulatory body including the Office of the Australian Information Commissioner (OAIC), the ACCC, ACMA, or the Clean Energy Regulator.

7.4 Business Transfers

If Photon Leads undergoes a merger, acquisition, asset sale, or restructure, your personal information may be transferred to the acquirer or successor entity. We will take reasonable steps to ensure any such recipient is bound by appropriate privacy protections.

7.5 What We Do Not Do

- We do not sell your personal information to third parties for their own marketing purposes

• We do not disclose your personal information to unaccredited or unvetted installers
• We do not provide your information to more Accredited Solar Providers than the number you consented to at the time of submission

After you submit your lead, you may be contacted by an automated Voice Agent, an artificial intelligence-powered telephony system that acts on behalf of Photon Leads. The Voice Agent is not a human caller. You will be informed at the commencement of any call that you are speaking with an automated voice agent.

The Voice Agent system complies with the Telecommunications (Telemarketing and Research Calls) Industry Standard 2017 (Cth) with respect to calling hours (9:00 am to 8:00 pm Monday to Friday, 9:00 am to 5:00 pm Saturday, no calls on Sundays or Australian public holidays), identification requirements, and opt-out mechanisms.

8.2 Call Recording

All calls made by the Voice Agent, and calls made by any human agent acting on behalf of Photon Leads, may be recorded. By engaging with the Voice Agent or any representative of Photon Leads by telephone, you acknowledge and consent to the recording of the call. You will be informed of the recording at the commencement of each call.

Photon Leads' policy is to notify all call recipients — regardless of their state of residence — that the call is being recorded at the commencement of each call. Continued participation in the call following this notification constitutes consent to recording in all Australian jurisdictions.

8.3 Purposes of Call Recording

- Verification of consent to referral and contact by Accredited Solar Providers

• Quality assurance and training of Voice Agent and human agent systems
• Investigation and resolution of complaints or disputes
• Regulatory compliance and demonstration of compliance to relevant authorities
• Improvement of the accuracy and effectiveness of the Voice Agent system

  8.4 Retention of Call Recordings

  Call recordings are retained for [INSERT PERIOD, e.g., seven (7) years] from the date of recording, or such longer period as may be required by applicable law or regulatory guidance.

By submitting your Lead Information, you expressly consent to Photon Leads and Accredited Solar Providers contacting you by telephone (including automated calls), email, and SMS for the purpose of providing you with solar installation quotes and related information.

9.2 Compliance with Spam Act 2003 (Cth)

All commercial electronic messages sent by Photon Leads comply with the Spam Act 2003 (Cth). Specifically: we only send commercial electronic messages where you have provided express or inferred consent; all commercial messages clearly identify Photon Leads as the sender; all commercial messages contain a functional and prominent unsubscribe mechanism; and unsubscribe requests are actioned within five (5) business days.

9.3 Do Not Call Register — Consent

Photon Leads and its Accredited Solar Providers may contact you by telephone even if your telephone number is registered on the Do Not Call Register, because you have provided express consent to such contact by submitting your Lead Information.

9.4 Opt-Out and Withdrawal of Consent

You may withdraw your consent to receive marketing communications or telephone contact from Photon Leads at any time by:

- Sending an email to privacy@photonleads.com requesting removal from our contact lists

• Using the unsubscribe link included in any email communication from us
• Replying STOP to any SMS communication from us
• Informing the Voice Agent or any human representative during a call that you wish to be removed

  Please note that withdrawal of consent from Photon Leads does not automatically withdraw consent from Accredited Solar Providers to whom your information has already been transmitted. You should contact those providers directly to withdraw consent for their communications.

Security measures we implement include:

- Encryption of data in transit using industry-standard TLS/SSL protocols

• Access controls and authentication protocols limit access to personal information to authorised personnel only
• Regular security assessments and vulnerability testing of our systems
• Data minimisation practices — we collect only the information reasonably necessary for our functions
• Contractual security obligations are imposed on all third-party service providers who process personal information on our behalf
• Staff training on privacy obligations and data handling best practices

  Data Breach Notification

  In accordance with the Notifiable Data Breaches Scheme under the Privacy Act 1988 (Cth), in the event of an eligible data breach, Photon Leads will conduct a prompt assessment, notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable, and notify all affected individuals likely to be at risk of serious harm.

  Overseas Storage

  Some of our technology service providers may store or process personal information on servers located overseas, including in the United States and other countries. Where personal information is stored or processed overseas, we take reasonable steps to ensure that the overseas recipient handles the information in a manner consistent with the APPs.

- Lead Information (name, contact, address) — retained for [INSERT PERIOD, e.g., 3 years] from the date of collection, or until you request deletion, whichever is earlier.

• Call Recordings — retained for [INSERT PERIOD, e.g., 7 years] for compliance and dispute resolution purposes.
• Web Analytics Data — aggregated or de-identified within 26 months of collection; raw data deleted within 14 months.
• Marketing Consent Records — retained for as long as necessary to demonstrate compliance with consent obligations.
• Legal Hold Material — retained as required by the relevant legal obligation, court order, or regulatory direction.

Cookies are small text files stored on your device when you visit a website. They are commonly used to make websites work more efficiently, to remember your preferences, and to provide website operators with information about how users interact with their site.

How We Use Cookies

The Photon Leads Website uses the following types of cookies and tracking technologies:

- Strictly Necessary Cookies — required for the Website to function. These cannot be disabled. They do not store personally identifiable information. This includes plc_anonymous_id, a random identifier (format: PLC-xxxxxxxx…) stored for 365 days that links your form submissions across sessions. It contains no personal information and is not used for advertising or profiling.

• Performance / Analytics Cookies — used to collect information about how users interact with the Website (e.g. pages visited, time on site). We use PostHog, a privacy-focused analytics platform. All input fields and form values are masked in session recordings — we never capture what you type. PostHog does not share data with advertising networks. This category is consent-gated: if you decline, PostHog runs in memory-only mode with no data persisted.
• Marketing / Advertising Cookies — used by our social media advertising platforms (e.g. Meta Pixel, Google Ads) to measure the effectiveness of our advertising campaigns and to serve relevant advertisements on third-party platforms.
• Functionality Cookies — used to remember your preferences, including your analytics consent decision stored in plc_cookie_consent for 365 days.

  Managing Cookies

  You can control and delete cookies through your browser settings. Please note that disabling cookies may affect the functionality of the Website. To opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout. To manage your Meta advertising preferences, visit facebook.com/settings/?tab=ads.

  To change your cookie preference at any time, click "Cookie settings" in the site footer.

- Right of Access (APP 12) — you have the right to request access to the personal information that Photon Leads holds about you. We will respond to access requests within thirty (30) days of receipt.

• Right to Correction (APP 13) — if you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, you have the right to request that we correct the information. We will take reasonable steps to correct the information within thirty (30) days.
• Right to Deletion — where personal information is no longer necessary for the purposes for which it was collected and there is no legal requirement to retain it, you may request that we delete your personal information.
• Right to Complain — if you believe that Photon Leads has breached this Privacy Policy or the APPs, you have the right to make a complaint (see Section 14).
• Right to Anonymity (APP 2) — where lawful and practicable, you have the right to interact with Photon Leads anonymously. However, given the nature of our lead generation service, we will be unable to connect you with Accredited Solar Providers if you do not provide your real contact and address information.

  How to Exercise Your Rights

  To exercise any of your rights, please contact our Privacy Officer:

  - Email: privacy@photonleads.com

• Post: Suite 329, Level 3, 98-100 Elizabeth Street, Melbourne VIC 3000, Australia
• Phone: +61 468 030 808

  We will respond to all requests within thirty (30) days and may request additional information to verify your identity.

If you have a complaint about how Photon Leads has handled your personal information, please contact our Privacy Officer (details in Section 13). Please provide your full name and contact information, a description of the privacy concern or alleged breach, and any relevant dates, communications, or documentation.

We will acknowledge receipt of your complaint within five (5) business days and endeavour to resolve your complaint within thirty (30) days.

External Complaints — OAIC

If you are not satisfied with our response, or if we do not respond within thirty (30) days, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

- Website: www.oaic.gov.au

• Phone: 1300 363 992
• Online Form: www.oaic.gov.au/privacy/privacy-complaints
• Post: GPO Box 5218, Sydney NSW 2001

  You may also contact your state or territory privacy or consumer protection authority.

If we become aware that we have inadvertently collected personal information from a child under 18, we will promptly delete that information from our records. If you are a parent or guardian and you believe that your child has provided personal information to us, please contact our Privacy Officer immediately.

We encourage you to review the privacy policies of these platforms:

- Meta: facebook.com/privacy/policy

• Google: policies.google.com/privacy
• TikTok: tiktok.com/legal/page/row/privacy-policy/en

  Once information is transferred to Photon Leads' systems, Photon Leads assumes sole responsibility for that information in accordance with this Privacy Policy.

Decisions made through these automated systems include: determining which Accredited Solar Providers service your geographical area; assessing the relevance and completeness of your lead submission; and scheduling Voice Agent calls based on submission timing and availability.

You have the right to request information about the automated decision-making processes that apply to your personal information. Please contact our Privacy Officer (Section 18) to make such a request. In accordance with the requirements of the Privacy and Other Legislation Amendment Act 2024, we will provide further disclosures regarding automated decision-making in our Privacy Policy updates prior to December 2026.

For material changes that significantly affect how we collect, use, or disclose your personal information, we will endeavour to notify you by email (where you have provided your email address) or through a prominent notice on our Website at least fourteen (14) days before the change takes effect.

Your continued use of the Website or Service following the posting of an updated Privacy Policy constitutes your acceptance of the changes. If you do not agree to the updated Policy, you must cease using the Website and Service and may contact us to request deletion of your personal information.

- Privacy Officer: Photon Leads

• Email: privacy@photonleads.com
• Postal Address: Suite 329, Level 3, 98-100 Elizabeth Street, Melbourne VIC 3000, Australia
• Phone: +61 468 030 808
• Website: https://photonleads.com
• Business Hours: Monday to Friday, 9:00 am to 5:00 pm AEST/AEDT

  This Privacy Policy was last updated on 25 May 2026 and is effective as of that date.