Privacy Policy.

This privacy policy explains how Toulios Wealth Management Pty Ltd (ACN 667 133 977 · ABN 68 667 133 977), an Australian private company (“Toulios”, “we”, “us”, “our”), collects, uses, discloses and stores personal information.

We are bound by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). This policy applies to our website, our consulting engagements, and any other interactions you have with us.

We only collect personal information that is reasonably necessary for our consulting services. Typical categories include:

• Identification details: name, role, employer.
• Contact details: email address, phone number, postal address.
• Engagement context: company stage, the brief you share with us, your responses to the AI Readiness Scorecard.
• Technical data: IP address, device/browser type, pages visited (via standard server logs and analytics).
• Communications: emails, call notes, materials you share during an engagement.

We do not knowingly collect sensitive information (as defined in the Privacy Act) unless it is required for a specific engagement and you have given consent.

We use personal information to:

• Respond to your enquiry and arrange a strategy call.
• Deliver consulting and advisory services we have been engaged to provide.
• Send tailored follow-up relating to the topic of your enquiry.
• Improve our website, content, tools (including the AI Readiness Scorecard) and service quality.
• Meet our legal, regulatory, accounting and record-keeping obligations.

We do not sell your personal information. We do not use your data to train third-party AI models. We do not engage in profiling or automated decision-making that produces legal or similarly significant effects.

We collect and process personal information on the following bases:

• Consent, when you fill in a form, run the scorecard, or otherwise voluntarily provide information.
• Contract, to deliver services you have engaged us to perform.
• Legitimate interests, to operate our website and respond to enquiries in a responsive, professional manner.
• Legal obligation, to comply with applicable laws and regulatory requirements.

We treat client information with the utmost discretion. We share personal information only with:

• Trusted service providers under contract (hosting, email delivery, analytics) bound by confidentiality and data-processing obligations.
• Professional advisers (accountants, lawyers) where strictly necessary.
• Authorities, where required by law or to protect our or a third party’s rights.

We do not disclose engagement details to other clients, prospects or third parties. Mutual NDAs are available on request before substantive discussions.

Some of our service providers (e.g. cloud hosting, email infrastructure and analytics) may store and process data in countries outside Australia, including the United States and the European Union. When this occurs, we take reasonable steps to ensure recipients handle your information consistent with the APPs and applicable laws.

We retain personal information only for as long as is reasonably necessary to deliver our services, comply with applicable laws, or maintain a record of our business activities. Enquiry and scorecard submissions are typically retained for up to seven (7) years from the date of last interaction, after which they are deleted or anonymised.

We apply reasonable physical, technical and administrative safeguards to protect personal information against loss, misuse, unauthorised access, modification or disclosure. These include access controls, encryption in transit (TLS), reputable cloud providers, and confidentiality obligations for our team and service providers.

No system is perfectly secure. If we become aware of a notifiable data breach affecting you, we will comply with the Notifiable Data Breaches scheme under the Privacy Act.

Our website may use first-party and third-party cookies for essential functionality and aggregated analytics. Cookies do not personally identify you. You can disable cookies in your browser; some parts of the site may not function as intended if you do so.

Under the Privacy Act and APPs, you have the right to:

• Request access to the personal information we hold about you.
• Request correction of inaccurate or out-of-date information.
• Withdraw consent for marketing communications at any time.
• Request deletion of your personal information where we are not legally required to retain it.
• Make a complaint about how we handle your personal information.

To exercise any of these rights, contact us using the details below. We will respond within 30 days.

If you are not satisfied with how we have handled your personal information, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

We may update this privacy policy from time to time to reflect changes in our practices or in applicable law. The “Last updated” date at the top of this page will always reflect the most recent revision.

For any privacy enquiry, please reach out via the Contact page, or write to us at privacy@touliosWealth.com.

Toulios Wealth Management Pty Ltd · Sydney · Australia.