Privacy Policy
Instead LLC – Privacy Policy
Introduction and Scope
At Instead LLC (Instead), privacy is taken seriously. This Privacy Policy explains how
Instead collects, uses, discloses, stores and secures personal information, and outlines
individuals’ rights and choices. Where we handle personal information of Australian
residents, we comply with the Australian Privacy Principles (APPs) under the Privacy Act
1988 (Cth).
Identity and Contact Details
Instead LLC
Telephone: +613 9584 5999
Email: helpdesk@instead.com.au
Privacy enquiries: helpdesk@instead.com.au
Australia contact (if applicable): brett@instead.com.au
What Personal Information We Collect
We collect personal information when you:
- Register or create an account on instead.com.
- Place an order or use our products or services.
- Visit our pages or those of certain partners.
- Enter promotions or sweepstakes.
- Subscribe to newsletters or mailing lists.
- Correspond with us or complete surveys and feedback forms.
Information collected may include:
- Name, email, phone number, and address.
- Product preferences and content personalisation settings.
- Billing and payment information.
- Demographic information (such as language, gender and age) and personal
interests. - Device, network and usage information (IP address, browser and device type,
pages visited, time and date of visit), collected via cookies, SDKs, pixels and similar
technologies. - Sensitive information will only be collected
For Australian users, we may collect TFNs and ABNs where permitted, and documents
required for SMSF administration and audit support. We use this information to compile
tax return files and audit packs and to support clients’ advisers and tax agents.
We may combine information we collect with information from business partners or other
companies, consistent with applicable law and your choices.
How We Collect Information
- Directly from you (online forms, account registration, orders, customer support).
- Directly from clients and end users, including via secure uploads and portals.
- Automatically via cookies and similar technologies (see Section 8).
- From third-party partners and service providers that support our services,
marketing and analytics. - From publicly available sources where permitted and relevant to our services.
- Unsolicited information is assessed promptly and deleted or de-identified if we
could not have collected it lawfully.
Why We Collect and How We Use Personal Information
We use personal information to:
- Deliver, operate, maintain and bill for our products and services, and communicate
about account and customer service issues (including verifying payment
authorisations). - Improve our products and services, including personalisation (language, location,
content recommendations). - Invite participation in surveys and feedback programs.
- Offer product upgrades, training, content and promotions.
- Provide news, newsletters, updates, targeted advertising, promotions and special
offers, with opt-out available at any time. - Understand usage patterns and performance to inform product development and
security. - Provide anonymous or aggregated reporting internally and to select partners.Facilitate online forums and manage misuse or abuse.
- Comply with legal obligations, enforce our terms and protect our rights, users and
the public. - Conduct due diligence and complete corporate transactions (e.g., merger,
acquisition, asset sale). - For Australian clients and end users, to compile and maintain tax return files and
SMSF audit information packs, and to facilitate the work of clients’ advisers and tax
agents.
We will never rent or sell personal information, and we share it only as described in this
policy.
Anonymity and Pseudonymity (Australia)
Where lawful and practicable, Australian individuals may interact with us anonymously or
using a pseudonym (e.g., general enquiries). Identification is typically required to create an
account, complete purchases and comply with legal obligations.
When and How We Share Personal Information
We share personal information with:
- Trusted vendors and partners that provide services such as hosting, IT support,
payment processing, marketing and analytics. They are contractually required to
keep information confidential and use it only for specified purposes. - Professional advisers (lawyers, auditors, insurers) where necessary for our
operations and compliance. - Authorities where required or authorised by law, or to protect our rights, users and
the public. - Entities involved in corporate transactions (bankruptcy, insolvency, acquisition,
merger or asset transfers). In such cases, information is disclosed under
appropriate safeguards.
We may share cookie and other anonymous usage data with affiliates, business partners,
advertisers and ad networks. This data does not identify individuals.
Third-party advertising: Third parties may use web beacons, cookies, JavaScript and
similar technologies to deliver adverts, measure effectiveness and gather anonymous
information about visits and ad views. Choices about interest-based advertising are
available at: https://networkadvertising.org/consumer/opt_out.asp.
Links: Our services may link to third-party websites or products. Their privacy practices
apply to your use of those sites.
Cookies, Analytics and Similar Technologies
Cookies are small data files that help operate and personalise services and measure traffic.
If cookies are disabled in your browser, some features may not function properly.
We use:
- Session and persistent cookies for authentication, preferences and analytics.
- Analytics tools (e.g., Google Analytics or equivalent) to collect usage data; IP
addresses may be truncated or otherwise processed to reduce identifiability. - Advertising cookies/IDs to deliver and measure interest-based advertising, subject
to your choices.
You may control cookies through browser settings and platform-level controls, and opt-out
of certain advertising cookies via industry tools.
Overseas Disclosure and Cross-Border Transfers
We may transfer personal information to recipients outside your country (including cloud
hosting, customer support and analytics providers). Where we do so, we implement
appropriate safeguards such as standard contractual clauses, data processing
agreements, vendor due diligence and technical controls (e.g., encryption, access
controls).
Australia: Where we disclose personal information of Australian residents overseas, we
take reasonable steps to ensure the recipient does not breach the APPs in relation to the
information. If equivalent protections cannot be ensured, we will seek consent where
required by law.
Security
We protect personal information using physical, technical and organisational measures
commensurate with the nature of the information and our operations, including:
- SSL/TLS encryption for purchase pages and data in transit.
- Access controls, strong authentication and least-privilege principles.
- Secure development and change management practices.
- Security monitoring, logging and vendor security assessments.
No method of transmission or storage is completely secure; users should also protect their
credentials and devices.
Our services are hosted on AWS. Data is not stored on Instead-owned on-premises
production servers. MFA is enabled for certain entry points and is being extended across
remaining entry points.
Retention and Deletion
We retain personal information only for as long as necessary for the purposes described
in this policy, to comply with legal obligations and to resolve disputes.
We maintain a documented retention schedule.
When information is no longer required, we delete or de-identify it, subject to legal and
operational requirements.
We retain personal information for as long as needed for the purposes set out in this policy
and to meet legal, regulatory and operational requirements, which for Australian tax and
SMSF records may exceed seven years. We maintain a documented retention schedule.
When no longer required, we delete or de-identify information subject to legal and
operational requirements.
Access, Correction and Choices
You have the right to request:
- Information about your stored data, its origin, recipients and the purposes of
processing. - Correction of inaccurate or incomplete information.
- Deletion, restriction or objection to processing in accordance with applicable law,
and data portability where required by law.
Submit requests to helpdesk@instead.com.au. We will respond within a reasonable period,
typically within 30 days. The data processed before we receive your request may still be
legally processed.
Marketing choices:
- Unsubscribe using the instructions in messages or contact helpdesk@instead.com.au.
- Adjust cookies via browser settings and manage ad preferences via platform
settings and industry tools.
Unique Identifiers (Australia)
We do not adopt, use or disclose government-related identifiers (e.g., tax file numbers) as
our own identifiers. Any identifiers we assign (e.g., account IDs) are used only where
reasonably necessary and handled in accordance with the APPs.
Where we handle TFNs, we do so in accordance with the Privacy (Tax File Number) Rule
2015.
Sensitive Information
We collect sensitive information only where necessary for our services and with consent
or as permitted by law. Sensitive information is subject to heightened access controls and
used for limited purposes consistent with this policy and applicable law.
Children’s Privacy
We do not knowingly collect personal information from children under 13. By using the site,
you represent that you are at least 18 or using the site with the supervision of a parent or
guardian. If you become aware that a child has provided us personal information without
consent, please email helpdesk@instead.com.au.
Complaints and Regulatory Contact (Australia)
Australian residents may lodge a privacy complaint with us at helpdesk@instead.com.au. We
will acknowledge within seven days and aim to resolve within 30 days. If you are not
satisfied, you may contact the Office of the Australian Information Commissioner
(www.oaic.gov.au, 1300 363 992).
Changes to this Policy
We may change this Privacy Policy at any time. For material changes, we will post a
prominent notice on our website and, where appropriate, notify you directly. The most
current version will govern our processing of personal information.
Definitions (Australia)
- Personal information: Information or an opinion about an identified individual, or
an individual who is reasonably identifiable (Privacy Act 1988 (Cth)). - Sensitive information: As defined in the Privacy Act, including health information
and other specified categories. - Government-related identifier: As defined in the Privacy Act (e.g., TFN)