Privacy Policy

This Privacy Notice was last reviewed or revised on August 21 2025. Lucent Layer (“Lucent Layer,” “we,” “our,” or “us”) is a business owned and operated by Galloway & Pierce Pty Ltd (“Galloway & Pierce” or “G&P”), Australia.

We understand that privacy is important. We are committed to respecting your privacy and protecting personal information in accordance with applicable privacy and data-protection laws. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information when it is collected through our websites, digital platforms, communications, and business activities, including service delivery, automation systems, integrations, events, and professional engagements.

Where required by law, this Privacy Policy applies when Galloway & Pierce is acting as the organisation responsible for handling personal information (sometimes referred to as a “data controller” or equivalent term).

1. Applicable Privacy Laws

Lucent Layer, through Galloway & Pierce, handles personal information in accordance with:

  • the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs); and
  • the New Zealand Privacy Act 2020, where applicable.

Individuals located in other jurisdictions may also have rights under local data-protection laws, which we respect and respond to where required.

2. How We Collect Personal Data

We collect personal information in the course of our business activities, either directly from you or from third parties.

Direct collection

We may collect personal information directly from you when you:

  • interact with our websites or manage cookie preferences
  • submit forms, enquiries, or automation requests
  • subscribe to updates, newsletters, or alerts
  • register for or participate in events, workshops, or briefings
  • provide feedback or respond to surveys
  • contact us by email, phone, or messaging platforms
  • engage us for automation, CRM, or workflow services

Collection from third parties

We may also receive personal information from third parties, including:

  • clients, contractors, or delivery organisations in the course of engagements
  • CRM systems, marketing platforms, or integrations connected to your business
  • publicly available sources such as business websites or professional profiles
  • service providers supporting our operations

We take reasonable steps to ensure that third parties are authorised to share personal information with us for the intended purpose.

3. Why We Use Personal Information

We use personal information only for legitimate business purposes, including:

  • managing professional and client relationships
  • designing, building, and maintaining automation systems and workflows
  • delivering services, integrations, and technical support
  • facilitating communications across CRM, messaging, and automation platforms
  • providing access to updates, reporting, and system outputs
  • administering events, onboarding, and service delivery processes
  • collecting feedback to improve our services
  • meeting legal, regulatory, and contractual obligations
  • maintaining the security and performance of our systems

Where required, processing is based on consent, contractual necessity, compliance with law, or legitimate business interests.

4. What We Do Not Do With Your Personal Data

Lucent Layer and Galloway & Pierce do not:

  • sell personal information to third parties
  • use personal information for automated decision-making that produces legal or similarly significant effects
  • attempt to unlawfully identify or re-identify individuals from de-identified data
  • use personal information for purposes unrelated to our business activities

Sensitive personal information (such as health or demographic data) is only collected where necessary, lawful, and relevant to the service being delivered, and is handled with appropriate safeguards.

5. Access to Personal Information and Overseas Transfers

Personal information may be accessed by:

  • authorised personnel within Lucent Layer and Galloway & Pierce
  • trusted service providers supporting IT systems, automation infrastructure, hosting, analytics, and communications
  • professional advisers or regulators where required by law

Overseas storage and processing

Lucent Layer uses third-party platforms and infrastructure, including CRM systems, automation platforms, cloud hosting, and communication tools.

As a result, personal information may be stored or processed outside Australia or New Zealand. Where overseas transfers occur, we take reasonable steps to ensure appropriate safeguards are in place, including contractual protections and confidentiality obligations consistent with this Privacy Policy.

6. Disclaimers

We take reasonable technical and organisational measures to protect personal information against misuse, interference, loss, unauthorised access, or disclosure.

These measures include:

  • access controls and role-based permissions
  • secure cloud infrastructure and platforms
  • encryption and authentication protocols where applicable
  • confidentiality obligations for personnel and service providers

No method of transmission or storage is completely secure. While we take reasonable precautions, we cannot guarantee absolute security.

7. How Long We Keep Your Personal Data

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including the operation and maintenance of automation systems, or as required by law, regulation, or contractual obligations. When personal information is no longer required, it is securely deleted or de-identified.

8. Children's Data

Lucent Layer does not knowingly collect personal information from individuals under the age of 16. Our services are intended for business and professional use.

If we become aware that personal information relating to a child has been collected without appropriate consent, we will take steps to delete it.

9. Your Privacy Rights

Depending on your location, you may have rights to:

  • access personal information we hold about you
  • request correction of inaccurate or outdated information
  • request deletion or restriction of processing, subject to legal obligations
  • withdraw consent where processing is based on consent
  • object to certain uses, including direct marketing
  • lodge a complaint with a relevant privacy regulator

9. Your Privacy Rights

To exercise your rights or raise a privacy question or concern, please contact:

Data Protection Officer
Galloway & Pierce Pty Ltd
chloesutton@lucentlayer.com.au

We will respond in accordance with applicable law and may need to verify your identity before acting on a request.If you are not satisfied with our response, you may lodge a complaint with:

  • the Office of the Australian Information Commissioner (OAIC); or
  • the Office of the New Zealand Privacy Commissioner, as applicable

11. Updates to This Policy

We may update this Privacy Policy from time to time. The most current version will be published on our website, with the review date updated accordingly.