Privacy Policy
Effective 6 November 2026. Replaces the policy dated 3 November 2026. Covers foundlymedia.com.au, clinics.foundlymedia.com.au and onboarding.foundlymedia.com.au.
Who we are
Foundly Media is a partnership between Nic Burton and Chris Pecipajkovski trading as Foundly Media, ABN 24 528 350 583, based in Wollongong, New South Wales, Australia. In this policy we, us and our mean Foundly Media.
We run Meta advertising for PTSD and mental health clinics in Australia, the United Kingdom, the United States and Canada. We also host one website we built for an earlier client. We no longer offer websites, content work, Google Ads or local search services and we have no clients for them.
This policy explains what personal information we collect, why we collect it, who we share it with, where it goes, how we hold it and how you can contact us about it. We handle personal information in line with the Australian Privacy Principles in the Privacy Act 1988 (Cth). Sections near the end set out additional rights for people in the United Kingdom, the United States and Canada.
You means anyone whose personal information we handle. That includes people who visit any of our websites, people who enquire with us or book a call, our clients and their staff, and the people who enquire with a clinic through advertising we run on the clinic's behalf.
Our websites
We operate three websites and they work differently.
- The agency site at foundlymedia.com.au is built and hosted by us on Cloudflare. It has a contact form and a tracking notice that lets you decline Meta tracking.
- The clinics funnel at clinics.foundlymedia.com.au is built on the nomads.inc platform, which is owned and operated by Nomads, the business of our coach Connor Bluhm. The platform is hosted on Vercel and its media files are stored on Supabase. The funnel has a short video, a short questionnaire, a contact form and a call booking step. It does not have a tracking notice. Meta tracking on the funnel runs as soon as a page loads.
- The client onboarding site at onboarding.foundlymedia.com.au is built and hosted by us on Cloudflare. Clients sign in with an access code we give them, watch our onboarding videos and complete a short quiz after each one. We record which videos have been watched and the quiz answers and results.
Where this policy says something applies to one site only, it says so.
What we collect and how
When you enquire through the agency site
Your name, phone number, email address, clinic or business name, the package you are asking about and anything you put in the message. The form is processed by a Cloudflare function and the enquiry is emailed to us through Resend. If you contact us by phone, email or Instagram we collect whatever you choose to give us.
When you use the clinics funnel
- Your answers to a short questionnaire about your clinic, such as whether you own it, its monthly revenue band, whether you are the decision maker and the type of treatment it provides.
- Your name, email address and phone number when you complete the form.
- The time you choose when you book a call, and any notes you add to the booking.
- Technical information the platform records, such as your IP address, browser and the pages you visit.
Form submissions and bookings on the funnel are held on the nomads.inc platform by Nomads and its hosting providers, Vercel and Supabase. The nomads.inc platform holds only the details of clinic owners and managers who enquire with us. It does not hold the details of anyone who enquires with a clinic through advertising we run.
When you have a sales call with us
When you book a call through the funnel, one of us calls you at the booked time. We may also call, text, WhatsApp or email you before then to confirm the booking and remind you of it. We text you only if you have agreed to receive text messages. We take notes about your clinic, your goals and what you tell us about your business.
- We record sales calls using Fathom, a call recording and transcription tool.
- We tell you at the start of the call that it is being recorded and that the recording will be shared.
- Every sales call recording is shared with our coach, Connor Bluhm, for training. We also keep recordings as a record of what was discussed.
- If you become a client we may record onboarding and review calls in the same way and we tell you at the start of each one.
- If you do not agree to the recording, say so at the start of the call and we will not record it.
When you become a client
The information above plus your trading name, business number, business address, the names and roles of the people we work with, your logo and brand assets, the details of your consultant calendar and the access you grant us to your Meta Business Portfolio, Facebook Page, Instagram account and ad account. We may also hold invoices, payment records and the messages exchanged in the WhatsApp group we run for each client.
When you use the onboarding site we record your access code, when you watched each video and your quiz answers and results. We use them to confirm onboarding is complete and we keep them with your client records.
For the earlier client whose website we host, any personal information submitted through that website belongs to that client. We handle it only to keep the website running.
People who enquire with a clinic through advertising we run
When we run advertising for a clinic, people who respond to those ads submit their details through a funnel that we build and run for that clinic. That funnel is separate from the clinics funnel at clinics.foundlymedia.com.au and is not on the nomads.inc platform. The clinic is responsible for those people's personal information. We handle it only on the clinic's instructions and only to do the work the clinic has engaged us for. In practice this means the following.
- We call each person who enquires and take their name, email address and phone number.
- We book them into the clinic's own consultant calendar and send them a booking confirmation and reminders by text message, where they have agreed to receive texts, or by email. We send them nothing else.
- We do not record these calls.
- We do not assess, screen, counsel or treat anyone. We do not ask anyone to describe their health or diagnosis. If a person volunteers health information on a call, we do not write it down beyond what the clinic needs to take the booking.
- The qualifying form on a clinic's funnel asks questions agreed with the clinic, which may include whether the person is looking for help with what the clinic treats. The answers are sensitive, they belong to the clinic and we use them only to make the call and the booking. We do not send them to Meta.
- A clinic's funnel uses the Meta Pixel in the clinic's own Meta account. The clinic's tracking notice and privacy notice explain that tracking.
- Ad spend is paid by the clinic directly to Meta and the ads run in the clinic's own ad account.
- We keep a booking record for each person, being their name and contact details, when they enquired, when we called, the booking and whether the clinic tells us they attended or were admitted. We keep it while we work with that clinic and delete it within 30 days after that work ends. We do not use it for any other purpose or for any other client.
- The clinic remains responsible for its own privacy obligations to the people who enquire, including having a privacy notice that covers the ads, the funnel and our role in making the first call.
When you visit the agency site
Cloudflare keeps standard web logs covering IP address, browser, pages requested and time.
We use the Meta Pixel and the Meta Conversions API to measure our advertising and to show our ads to people who have visited the site. Our tracking notice appears on your first visit. Tracking runs when you arrive and stops if you choose No thanks. A stored No thanks means nothing loads on later visits. You can change your choice at any time through the Tracking choices link at the bottom of every page, through your browser's cookie settings and through your Meta account settings.
When tracking runs, Meta receives your IP address, browser details, the pages you view, Meta cookie identifiers and whether you tap our phone number or email address. If you send us an enquiry with tracking allowed, Meta also receives your email address in hashed form so that Meta can match the enquiry to our ads. We never send Meta your name, your phone number or your message. Automatic button click tracking is switched off. Meta may combine what it receives with information it already holds about you.
We do not use Google Analytics on the agency site.
When you visit the clinics funnel
The nomads.inc platform and Vercel keep standard web logs.
The Meta Pixel is installed on every page of the funnel. It runs when a page loads. There is no tracking notice on the funnel and no way to decline tracking on the funnel itself. The Pixel sends Meta a page view for each step and an event as you move through the funnel, including when you reach the booking step. Meta receives your IP address, browser details and Meta cookie identifiers with each event. We do not use the Conversions API on the funnel, so nothing is sent to Meta from a server on our side. You can limit this tracking through your browser's cookie settings, through an ad blocker and through your Meta account settings.
Why we collect it
- To respond to your enquiry, hold a call with you and quote for work.
- To run and report on advertising for our clients and to make the first call and booking for people who enquire with a clinic.
- To keep the website we host for an earlier client running.
- To invoice you and keep the records tax law requires.
- To measure whether our own marketing works, including which ads bring in enquiries, and to show our ads to people who have visited our websites.
- To train ourselves and improve how we run sales calls. Sales calls are recorded and shared with our coach as described above.
- To send you occasional information about our services if you have enquired with us or worked with us. Every marketing message we send identifies us and includes a way to opt out, and we stop when you ask.
We do not sell personal information. We do not use one client's data, or the data of the people who enquire with one clinic, to build audiences or campaigns for anyone else.
Who we share it with
We share personal information only as needed to do the work described in this policy and to run and measure our own advertising.
- Meta Platforms, for Facebook and Instagram advertising, the Pixel and the Conversions API.
- Nomads, which operates the nomads.inc platform our clinics funnel is built on, and whose founder Connor Bluhm coaches us. Connor Bluhm also receives every sales call recording.
- Vercel, which hosts the clinics funnel.
- Supabase, which stores the media files for the clinics funnel.
- Cloudflare, which hosts the agency site and the client onboarding site, processes form submissions, stores onboarding video and quiz records, and relays tracking events to Meta.
- Resend, which delivers enquiry emails to us.
- Fathom, which records and transcribes our sales calls and holds the recordings and transcripts.
- Our business phone provider, which supplies the overseas phone numbers we use to call and text clinic owners and the people who enquire with a clinic. It holds call and message logs and, where we turn it on, call recordings. We do not record calls with people who enquire with a clinic.
- Google, which provides our business email and the file storage and forms we use for client feedback and reporting.
- WhatsApp, owned by Meta, for the group we run with each client.
- Xero, our accounting software, and our accountant.
- Our clients, where you have enquired with a clinic through advertising we run for that clinic. Your details go to that clinic and are booked into its calendar.
- Contractors we engage for specific work, under confidentiality obligations, and only the information the task needs.
- Anyone the law requires us to disclose to.
All the above categories exclude text messaging originator opt-in data and consent. This information will not be shared with any third parties, excluding aggregators and providers of the text message services.
Mobile numbers and text messages
How we collect it. You give us your mobile number when you fill in one of our forms or when you give it to us on a call.
How we use it. We call you about your enquiry and your booking. We text you if you tick the text message box on our contact form, give us your number on a form of ours that says we will text you, or agree on a call. We only text to book your call, confirm it, remind you of it or change it. Nothing else, and never marketing. We send up to 3 texts in total for each enquiry. Message and data rates may apply. Reply STOP at any time to opt out, or HELP for help. If you opt out, reply START to the same number to opt back in.
How we protect it. Your number and your text consent are kept in our business email, our lead records, our business phone provider's system and the platforms that hold our form submissions, listed in this policy. Within Foundly Media only Nic and Chris can see them. We protect the accounts we control with unique passwords and two factor authentication wherever the service offers it.
Who sees it. We do not share your mobile number or your text consent with third parties or affiliates for their marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text message services. Our business phone provider sends and receives messages for us only.
Where it goes
Most of the providers above are based in the United States and may store your information there and in the other countries where they operate. Our business phone provider may store call and message logs in the United States or in Europe (the European Union or the United Kingdom). Tracking data from the agency site and the clinics funnel goes to Meta. Form submissions and bookings on the clinics funnel are held by Nomads and its hosting providers, Vercel and Supabase, which may store data outside Australia. Sales call recordings are held by Fathom and, once shared, by Connor Bluhm.
By using our websites, enquiring with us, booking a call or engaging us you consent to these overseas disclosures. We choose providers with published security practices. Once your information is in their systems we cannot enforce Australian privacy law against them, and the laws that apply to your information may differ from the laws in your own country.
If you are in the United Kingdom, Canada or the European Economic Area, see the country sections below.
How we hold it
Enquiry and client information lives in our email, our project files and the third party platforms above. We protect the accounts we control with unique passwords and we turn on two factor authentication wherever the service offers it. Access to client ad accounts is granted through Meta's own partner and user tools, so you can see and revoke it at any time. We do not ask for your passwords.
- We keep client records for seven years after the engagement ends for tax purposes.
- We delete or de-identify enquiry data held in our own systems that does not turn into work within twelve months.
- Enquiry data held on the nomads.inc platform is kept by Nomads. If you ask us to delete it, we will pass your request to Nomads and ask it to act.
- Sales call recordings and transcripts are held in our Fathom account and by Connor Bluhm.
- The booking record for people who enquire with a clinic is kept while we work with that clinic and deleted within 30 days after that work ends.
- Tracking data held by Meta is kept under Meta's own retention policies.
Access, correction, deletion and complaints
You can ask us what personal information we hold about you, ask us to correct it, or ask us to delete it where the law allows. Email nic@foundlymedia.com.au or chris@foundlymedia.com.au and we will respond within 30 days. Where the information is held by Nomads, Fathom or a clinic, we will pass your request on and help them respond.
If you think we have mishandled your information, tell us first and we will try to fix it. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au.
If you enquired with a clinic through advertising we run, you can contact us or the clinic. Where the clinic holds your information we will pass your request to the clinic and help it respond.
If you are in the United Kingdom
If you are in the United Kingdom, UK GDPR and the Data Protection Act 2018 apply to our handling of your personal data because we offer our services to people in the United Kingdom. The clinics funnel in particular is aimed at clinic owners in the United Kingdom.
- Controller. Foundly Media is the controller of the personal data you give us through our websites and on calls. Where we handle enquiries on a clinic's behalf, the clinic is the controller and we are its processor.
- Lawful basis. We rely on our legitimate interests to respond to your enquiry, hold a call with you and run our business. We rely on contract to deliver work you engage us for. We rely on legal obligation to keep tax records. We rely on consent for marketing emails, for call recording and for tracking cookies on the agency site, where our tracking notice gives you that choice. The clinics funnel does not currently ask for consent before the Meta Pixel loads. If you do not want that tracking, use your browser's cookie settings or an ad blocker before you visit the funnel, or contact us through the agency site instead.
- Your rights. You can ask for access to your personal data, ask us to correct it, ask us to erase it, ask us to restrict how we use it, object to our use of it, ask for a copy in a portable format and withdraw consent at any time. Email nic@foundlymedia.com.au and we will respond within one month.
- Transfers. Your personal data is transferred outside the United Kingdom, to Australia where we are based and to the countries where our providers store data. Contact us if you want to know more about how we protect it.
- Complaints. You can complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
- Recordings. We tell you at the start of a call if it is being recorded and that the recording will be shared with our coach. If you do not agree, say so and we will not record.
If you are in the United States
If you are in the United States, the privacy rights available to you depend on the state you live in. Our business is small and we do not currently meet the thresholds at which most state privacy laws apply. We still handle your information as this policy describes, and you can contact us with any request at any time.
- What we collect. The categories above. On the clinics funnel that means your name, email, phone number, your questionnaire answers, your booked call time and the technical data and Meta tracking described earlier.
- Tracking. Meta Pixel data from our websites is shared with Meta for advertising measurement and for showing our ads to people who have visited our sites. Some state laws describe this as sharing for targeted advertising. On the agency site you can decline it through our tracking notice. On the clinics funnel there is no notice and you can limit it through your browser settings, an ad blocker or your Meta settings.
- Requests. You can ask what personal information we hold about you, ask us to correct it, ask us to delete it and ask us to stop using it for marketing. Email nic@foundlymedia.com.au. We will respond within 45 days.
- Patient enquiries. When we handle enquiries on a United States clinic's behalf, the clinic is responsible for its obligations under HIPAA, state health privacy laws and the laws governing calls and text messages, and for any agreement those laws require it to have with us.
- Calls. We call people in the United States only where they have asked us to call them. We do not make marketing calls or send marketing text messages to people in the United States who have not asked to hear from us.
- Recordings. We tell you at the start of a call if it is being recorded and that the recording will be shared with our coach. If you do not agree, say so and we will not record.
- Children. Our websites are for business owners and are not directed to children under 16. We do not knowingly collect information from children.
If you are in Canada
If you are in Canada, the Personal Information Protection and Electronic Documents Act applies to our handling of your personal information in the course of commercial activity, along with provincial laws in Alberta, British Columbia and Quebec where they apply.
- Consent. We collect, use and disclose your personal information with your consent, which you give when you enquire with us, book a call or engage us. You can withdraw consent at any time, subject to legal and contractual restrictions, by emailing nic@foundlymedia.com.au.
- Transfers. Your personal information is stored and processed outside Canada, in Australia and in the countries where our providers store data, where it is subject to the laws of those countries and may be accessible to their authorities.
- Your rights. You can ask for access to your personal information, challenge its accuracy and ask us to correct it. We will respond within 30 days.
- Complaints. You can complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca or on 1 800 282 1376. Residents of Quebec can contact the Commission d'accès à l'information du Québec.
- Marketing messages. We send commercial electronic messages only with your consent or where the law otherwise allows, and every message includes a way to unsubscribe.
- Recordings. We tell you at the start of a call if it is being recorded and that the recording will be shared with our coach. If you do not agree, say so and we will not record.
- Patient enquiries. When we handle enquiries on a Canadian clinic's behalf, the clinic is responsible for its obligations under federal and provincial health privacy laws and for any agreement those laws require it to have with us.
Changes
We update this policy when our services or providers change. The effective date at the top tells you when it last changed. Continued use of our websites or services after a change means you accept the updated policy. Where a change materially affects how we use information we already hold about you, we will tell you before it takes effect.
Contact
Foundly Media, Wollongong NSW, Australia