Introduction

Nexa Data Solutions is a business operated by Clearstone Capital Pty Ltd (referred to as “Nexa,” “we,” “us,” or “our”) in New South Wales and Queensland, Australia. We are committed to protecting the privacy of individuals and businesses and to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. This Privacy Policy explains how we collect, use, store, and disclose your personal information when you use our services or visit our website (www.nexadatasolutions.com). It also outlines your rights and our practices for safeguarding your information. We take reasonable steps to protect personal information from theft, misuse, interference, loss, unauthorized access, modification, or disclosure and to ensure your data is handled securely and lawfully.

By providing your personal information to Nexa (for example, by filling out our service forms, scheduling a job, or making a payment online), you consent to the practices described in this Privacy Policy. We encourage you to read this Policy carefully and contact us if you have any questions.

Information We Collect

Personal Information: Nexa may collect a range of personal and business information necessary to provide our data cabling, networking, and IT infrastructure services. This information may include:

• Identity and Contact Details: Your name, date of birth, residential or business address, email address, phone number, and social media handles or contact information.
• Service Details: Information related to the services you request, such as details about your premises (e.g. floor plans or network layouts), the type of infrastructure or equipment you have or need, and any specific issues or requirements you communicate to us.
• Payment Information: For billing and payment processing, we may collect payment details. However, we do not store your full credit card numbers on our servers; online payments are processed via secure third-party payment gateways (e.g. through our accounting integration) for your protection.
• Photos and Videos: With your awareness, our technicians may capture photos or video footage at job sites (for instance, pictures of cabling installations or network equipment) for documentation and quality assurance. These images could be considered personal information if they include identifiable individuals or unique aspects of your property. We may also later use some photos or videos for marketing or portfolio purposes, but only in accordance with the use and disclosure practices described below and subject to your opt-out or consent preferences.

We will only collect personal information by lawful and fair means. In most cases, we collect information directly from you – for example, when you fill out an online form on www.nexadatasolutions.com, speak with us by phone, send us an email, or provide details to our technicians on site. If we need to collect personal information from someone else (e.g. if a building manager provides access details for a job), we will do so only with proper authority or as permitted by law.

Non-Personal Information: When you visit our website, we may automatically collect some technical information (such as your IP address, browser type, and browsing statistics) through cookies or analytics tools. This information is generally not identifiable and is used to improve our website and services. Our Cookie Notice (if applicable) provides more detail on how we use cookies. You can adjust your browser settings to refuse cookies, but some site features might not function properly as a result.

How We Use Personal Information

Nexa uses the personal information we collect for purposes necessary to carry out our business and provide you with services, including:

• Service Delivery and Operations: We use your information to schedule and perform the services you requested (e.g. data cabling installation, network setup, IT infrastructure maintenance). For example, our team will use your contact details and address to arrive on-site and complete the job, and details about your IT environment to ensure we bring the right equipment and solutions.
• Communication: We use your phone number, email, or other provided contact channels to communicate with you about your service requests. This includes sending confirmations and reminders for appointments, notifying you of any changes or issues, providing progress updates, and responding to your inquiries or support requests.
• Administration and Records: Personal details and job information are entered into our Customer Relationship Management (CRM) system (such as GoHighLevel) and our job management platform (such as Simpro) to efficiently manage schedules, work orders, and project history. We also use your information in our accounting software (such as Xero) to issue quotes, invoices, and receipts, and to process payments and refunds.
• Improvement and Quality Assurance: We may analyze information (including feedback you provide and internal records of services performed) to improve our services, train our staff, and maintain quality standards. Photos or videos taken during jobs are primarily for internal documentation — for instance, to verify that installation standards are met, or to help our team plan future stages of work.
• Marketing and Testimonials: With your consent or as otherwise permitted by law, we may use your contact information to send you marketing communications about new services, special offers, or relevant industry updates. We respect your choice – if you prefer not to receive marketing emails or messages, you can opt out at any time. Additionally, with your permission, we might use non- sensitive details of projects (and occasionally anonymised photos/videos of installations) in our marketing materials or case studies to showcase our work. We will not publicly share any image or video that clearly identifies you, your family, or sensitive aspects of your premises without your explicit consent.
• Legal Compliance and Protection: In some cases, we may need to use or disclose your information to comply with legal obligations, such as keeping records required by tax law or responding to lawful information requests. We may also use your information to enforce our agreements or protect our rights, privacy, safety, or property, or those of our clients or others (for example, to investigate or prevent fraud, security incidents or other misuse of our services).

We will not use your personal information for purposes other than those above unless you have consented or the use is otherwise permitted under the Privacy Act. We do not sell or rent your personal data to third parties for their marketing purposes.

Disclosure of Personal Information

Nexa understands the importance of keeping your information private. We only share personal information with third parties in a few circumstances, such as:

• Within Our Company and Team: Employees, technicians, and contractors of Nexa (including those working under Clearstone Capital Pty Ltd) may access personal information strictly on a need- to-know basis to perform their job duties. For example, a technician will receive your name, address, and service details to complete the installation at your site. All staff and contractors are bound by confidentiality obligations.
• Service Providers and Partner Platforms: We use reputable third-party software and service providers to run our operations. Your personal information may be stored or processed in these systems as part of our workflow:
  • CRM (GoHighLevel): Stores client contact details, communications, and service requests.
  • Job Management (Simpro): Holds job schedules, work orders, and technical details needed to deliver services.
  • Accounting/Payment (Xero and payment gateways): Manages billing information, invoices, and processes online payments securely.

These third-party platforms are used to provide and enhance our services, and we ensure they have appropriate data protection measures. However, they are independent services, and their handling of data is also governed by their own privacy policies and terms. We only disclose to these providers the information necessary for them to perform their functions for us (for instance, passing your name and email to Xero to send you an invoice). We do not allow these service providers to use your personal information for their own marketing or other unrelated purposes.

• Business Transfers: If Nexa (Clearstone Capital Pty Ltd) undergoes a business transition such as a merger, acquisition, or sale of assets, personal information held by us may be one of the transferred assets. It would remain subject to the promises made in this Privacy Policy (unless you consent otherwise or the law permits). We would notify you or post a notice on our website in the event of such a transfer.
• Legal Requirements: We may disclose personal information when required by law, or if we have a good-faith belief that such action is necessary to comply with legal processes or respond to requests from government authorities. For example, we might have to provide information under a court order or to assist in a law enforcement investigation.
• Protection of Rights and Safety: If necessary, we may share information to enforce our Terms of Service or other agreements, or to protect the rights, property, or safety of our business, our clients, or others. This could include exchanging information with other companies or organizations for fraud protection or credit risk reduction.

In all cases of sharing, we strive to limit the information disclosed to what is relevant for the specific purpose and to ensure appropriate confidentiality and security agreements are in place.

Overseas Disclosure: Some of the third-party platforms we use might store or process data in servers located outside Australia. For example, our CRM or other cloud service providers might utilise data centers in the United States or other countries. When we disclose personal information to an overseas recipient (such as a cloud service provider), we will take reasonable steps to ensure they protect the information consistently with Australian standards and this Privacy Policy. We note that if personal data is held overseas (for instance, on a cloud server), Australian law may not apply to that storage location; however, our contracts and the safeguards we require of our providers are intended to protect your information. By engaging with our services or providing your information, you consent to the possible transfer of your information overseas for the purposes described above. If you would like to know more about which countries your information may be stored in, please contact us (our details are provided below).

We do not otherwise share your personal information with third parties unless you have consented to the disclosure, or the disclosure is permitted by law. We do not sell your personal data to third parties.

Data Security and Storage

Nexa Data Solutions takes the security of your personal information seriously. We implement a variety of administrative, physical, and technical security measures to help protect your personal data from unauthorized access or disclosure and against misuse, interference, loss, or alteration. These measures include secure databases with access controls, encryption of sensitive information where appropriate, firewall and network security for our digital systems, and regular training for staff on data protection practices. We also follow industry best practices and cybersecurity frameworks, such as the Australian Cyber Security Centre’s guidelines, to continually improve our security posture. (For example, we align our practices with the ACSC “Essential Eight” strategies for mitigating cyber threats.)

While we strive to protect your data, it’s important to understand that no method of electronic storage or transmission over the internet is completely infallible. In fact, even the best-recommended security strategies cannot guarantee protection against all cyber threats. Accordingly, we cannot guarantee absolute security of your information. You play a role in security as well – please keep your account credentials (if any) confidential and be aware of common cyber risks (like phishing scams). If you have reason to believe that your interaction with us is no longer secure (for example, if you feel your account or information has been compromised), please contact us immediately.

All personal information we collect is stored either on secure servers in controlled environments or in secure physical locations. Our primary systems (CRM, job management, accounting software) are password- protected and accessible only by authorized personnel who require access to perform their duties. We regularly update our systems and apply security patches to guard against vulnerabilities. Additionally, if we keep any paper records (such as signed work orders or copies of documents), those are stored in our secure office locations or locked cabinets with controlled access.

If a data breach does occur that is likely to result in serious harm (for example, unauthorized access to your personal data), we will follow the Notifiable Data Breaches scheme under Australian law. This means we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required, and take steps to contain and remedy the breach.

Data Retention and Destruction

We will retain your personal information only for as long as it is needed for the purposes outlined in this Privacy Policy, or as required by law (for example, we may need to keep certain transaction records for a number of years for taxation or accounting purposes). When we no longer require personal information for our business purposes and are not legally required to retain it, we will take reasonable steps to destroy the information or de-identify it. In doing so, we will follow any applicable guidelines and use secure methods to prevent unauthorized access during the destruction process. For instance, physical documents may be securely shredded, and electronic files will be deleted or overwritten in a manner that prevents recovery.

Please note that if you unsubscribe from marketing communications or opt out of certain uses of your data, we may still retain your contact information on a suppression list to ensure we honor your opt-out (so that you are not inadvertently contacted again). Also, backup copies of data might be retained for a period in secure archives until those backups cycle out, but we will not restore personal data from backups except as permitted by law or for a business purpose consistent with this Policy.

Accessing and Correcting Your Information

We respect your right to access the personal information we hold about you and to request corrections if needed. You may contact us (see Contact Us section below) to:

• Access: Request a copy of the personal information we hold about you. We will need to verify your identity before fulfilling such requests. We will respond to your request within a reasonable time (usually within 30 days). In some cases, we may not be able to give you access to certain information (for example, if it would unreasonably affect someone else’s privacy or if giving access is prohibited by law), but we will always provide reasons if we deny access. Where appropriate, we may offer access via a supervised viewing of records or provide a summary if full access cannot be granted.
• Correction: If you believe any personal information we hold about you is inaccurate, out-of-date, incomplete, or misleading, please let us know. We will promptly update or correct the information as requested. If we disagree that the information is incorrect, we will inform you of our refusal (with reasons) and your options to have a statement of correction noted.

There is generally no charge for requesting access to or correction of your information. However, if your request is unusually complex or resource-intensive, we may charge a reasonable fee to cover the cost (we would inform you in advance and seek your agreement to any fee).

Privacy Preferences and Opt-Out

• Marketing Communications: If you have subscribed to our newsletters or agreed to receive promotional emails/SMS, you can opt out at any time by clicking the “unsubscribe” link in the message or by contacting us with your request. We will process your opt-out as soon as practicable. Please note you will still receive transactional or service-related communications from us (such as appointment confirmations or invoices) as those are not promotional.
• Photos and Media Use: If you do not want us to use photos or videos of your premises or installations for marketing or public- facing purposes, you have the right to opt out or withhold consent. Simply inform our technician on-site or contact us via email/phone to let us know your preference. We will mark your account to ensure no identifiable media from your jobs are used externally. (Do note that we may still keep and use images internally for documentation and training, as these uses are essential to our service quality. Internal use images will not be disclosed publicly.)
• Cookies/Online Tracking: As mentioned, you can control cookies through your browser settings. You can also opt out of certain analytics tracking by using tools like browser extensions or the “Do Not Track” setting, if our site honors it. Refer to our Cookies notice (if available) for more opt-out information related to analytics or advertising cookies.

By exercising any of these choices, you will not be denied any service; we respect and accommodate your privacy preferences.

Complaints and Enquiries

If you have any questions about this Privacy Policy or how we handle your personal information, or if you wish to make a privacy-related complaint, please contact us using the details in the Contact Us section below. We take privacy complaints seriously.

When we receive a complaint, we will acknowledge it and try to resolve it with you as quickly as possible. We may ask you for more details, and we’ll investigate the issue. We will inform you in writing about the outcome of the investigation and any steps we will take to address your complaint. If you are not satisfied with our response, you have the option to refer the matter to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted at www.oaic.gov.au or by phone at 1300 363 992.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal obligations or for other operational reasons. When we make significant changes, we will post the updated Policy on our website with a new “Last Updated” date and/or notify you by other means (for example, via email or a notice on our homepage). We encourage you to review our Privacy Policy periodically to stay informed about how we are protecting your information.

Your continued use of our services or website after any changes to this Privacy Policy constitutes your acceptance of the updated terms, unless separate explicit consent is required by law for the change (in which case we will obtain that consent).

Contact Us

If you would like to contact us regarding any privacy matters, please use the following details:

Nexa Data Solutions (Clearstone Capital Pty Ltd)
Email: office@nexadatasolutions.com
Mailing Address: PO Box 216, Shellharbour City, NSW, 2529
Telephone: +61461141110

Please note that for security and verification purposes, we may need to verify your identity before disclosing or discussing any personal information matters.