Privacy Policy

Smile Pathways Australia ("we", "us", "our") is an Australian company (ABN: [Your ABN Here]) that helps eligible Australians navigate the ATO's Compassionate Grounds early superannuation release framework to fund major dental treatment.

We are not a superannuation fund, licensed financial adviser, or dental provider. We are an administrative and consulting service. Any ATO Compassionate Grounds application is lodged by or on behalf of the individual in accordance with ATO requirements.

We may collect the following categories of personal information:

• Identity information: First name, last name
• Contact information: Mobile number, email address
• Financial information: Approximate superannuation balance (range only, as selected in the eligibility quiz)
• Health information: General information about your dental condition (e.g. number of missing or broken teeth, how severely it is affecting your quality of life), collected only to assess eligibility for the ATO Compassionate Grounds process
• Technical data: IP address, browser type, device type, pages visited, referral source (e.g. Meta ad campaign ID), time and date of visit
• Communication records: Notes or records from calls, emails, or messages exchanged with our team

We collect personal information in the following ways:

• Directly from you, via the eligibility quiz and lead form on our website
• By phone or email, during or after a consultation with our team
• Automatically, via cookies and analytics tools when you visit our website (see Section 10)
• From Meta, when you interact with our Facebook or Instagram advertisements and are directed to our website (see Section 6)

We only collect personal information by lawful and fair means. We do not collect information in an unreasonably intrusive way.

We collect and use your personal information to:

• Assess your eligibility for the ATO Compassionate Grounds early superannuation release process
• Contact you to schedule and conduct a free, no-obligation consultation
• Assist with preparing and lodging your ATO application (if you choose to proceed)
• Communicate updates about your application, our process, or our services
• Improve our website and services using aggregated, anonymised analytics data
• Measure the effectiveness of our advertising campaigns (see Section 6)
• Comply with our legal and regulatory obligations

We will only use your information for the purpose for which it was collected, or for a directly related secondary purpose, unless you have given consent, or disclosure is required or authorised by Australian law.

We do not sell your personal information. We may share it with the following parties, where necessary to provide our services:

• Dental providers: If you choose to proceed with treatment, relevant information (such as your name and the nature of treatment required) is shared with your treating dental practice to obtain quotes required for the ATO application
• The Australian Taxation Office (ATO): Application information is submitted directly to the ATO as required by the Compassionate Grounds process
• Your superannuation fund: Once ATO approval is obtained, we may assist in notifying your fund to action the release of the approved amount
• Technology and service providers: We use trusted third-party services to operate our website, manage communications, store data securely, and support our business (e.g. CRM platforms, scheduling tools, cloud hosting). These providers are contractually bound to protect your data and are prohibited from using it for their own purposes
• Meta Platforms: Limited technical data for advertising measurement purposes only (see Section 6)

We run advertising campaigns on Meta platforms (Facebook and Instagram). If you reached our website by clicking one of our ads, Meta may have passed limited anonymised data about that interaction to us for advertising measurement.

We may use Meta's advertising tools, including the Meta Pixel and Conversions API, to measure ad performance and reach relevant audiences. This can involve sharing limited, hashed (encrypted) data such as email addresses with Meta solely for audience matching and reporting purposes.

What we do not do: We do not use your dental health information or superannuation information for advertising targeting. We do not retarget individuals who have submitted health-related information to us.

You can review and manage your Meta advertising preferences at any time: facebook.com/adpreferences ↗

Your personal information is stored on secure servers located in Australia and/or with reputable cloud infrastructure providers. We implement reasonable technical and organisational security measures, including:

• SSL/TLS encryption for all data transmitted via our website
• Role-based access controls limiting who within our organisation can access personal information
• Regular review of our security practices and procedures
• Contractual data protection obligations with all third-party service providers

Despite these measures, no method of data transmission over the internet or electronic storage is 100% secure. If you believe your information may have been compromised, please contact us immediately using the details in Section 13.

We retain personal information for as long as is necessary to:

• Provide our services to you
• Comply with legal obligations, including ATO record-keeping requirements
• Resolve any disputes and enforce our agreements

As a general guide:

• Completed ATO application records are retained for 5 years in line with standard Australian financial and tax record-keeping obligations
• Enquiry-only records (where you completed the quiz or consultation but did not proceed) are deleted or de-identified within 12 months

You may request earlier deletion of your data at any time, subject to our legal obligations, by contacting us (see Section 13).

Under the Privacy Act 1988 and the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you, and request a copy
• Correct information that is inaccurate, incomplete, or out of date
• Request deletion of your personal information (subject to our legal obligations to retain certain records)
• Opt out of direct marketing communications at any time, every marketing email includes an unsubscribe link, or you can contact us directly
• Withdraw consent where we rely on your consent to process your information
• Complain if you believe we have mishandled your personal information (see Section 13)

To exercise any of these rights, please contact us using the details in Section 13. We will acknowledge your request within 5 business days and respond in full within 30 days. We may need to verify your identity before actioning your request.

Our website uses cookies, small text files placed on your device, to enable site functionality, improve your experience, understand usage patterns, and support our advertising measurement.

We use the following types of cookies:

• Essential cookies: Required for the site and quiz to function correctly (e.g. maintaining your quiz session state). Cannot be disabled without affecting site functionality.
• Analytics cookies: Help us understand how visitors interact with our site (e.g. Google Analytics). Data collected is anonymised and aggregated.
• Advertising cookies: Used to measure the performance of our Meta advertising campaigns (Meta Pixel). These do not contain your name or health information.

You can manage or disable cookies through your browser settings at any time. Disabling certain cookies may affect the performance or functionality of our website.

Our services are intended solely for Australian adults aged 18 and over who hold a superannuation account in their own name. We do not knowingly collect personal information from anyone under the age of 18.

If you believe we have inadvertently collected personal information from a minor, please contact us immediately and we will delete it promptly.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we do, we will revise the "Last updated" date at the top of this page.

Where changes are material, we will notify you by email (if we hold your email address) or by displaying a prominent notice on our website. Continued use of our services after the effective date of any changes constitutes your acceptance of the updated policy.

We encourage you to review this page periodically.

If you have questions about this Privacy Policy, want to exercise your rights, or wish to make a complaint about how we have handled your personal information, please contact our Privacy Officer:

We will acknowledge complaints within 5 business days and aim to resolve them within 30 days. If you are not satisfied with our response, or if we fail to respond within 30 days, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC):