Privacy Policy

SCAFFOLD Advisory Pty Ltd (ACN 696 757 874) ("SCAFFOLD Advisory", "we", "us", "our") is committed to protecting the privacy of individuals who interact with our business. This Privacy Policy explains how we collect, use, store, disclose, and protect personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This policy applies to all personal information collected through our website (scaffoldadvisory.com), diagnostic questionnaires, service engagements, and any other interactions with our business.

We collect personal information that is reasonably necessary for our business functions. This includes:

Contact and identity information

• Full name and role/title
• Business name and legal structure
• Email address and phone number
• State of operation

Business and financial information

• Annual revenue, profit figures, and financial statements
• Cash flow data, debt levels, and working capital information
• Staff count, utilisation rates, and operational metrics
• Owner salary and drawings (for EBITDA normalisation purposes)
• Business valuation estimates and exit intentions

Operational and technology information

• Software systems currently in use
• Process documentation status
• AI tool adoption and technology comfort levels

Engagement information

• Service tier selected
• Diagnostic questionnaire responses
• Communications with SCAFFOLD Advisory (email, call notes)
• Invoicing and payment records

We collect personal information through:

• Diagnostic questionnaire — hosted via Google Forms
• Direct communications — email, phone, and video calls
• Website — contact forms and enquiry submissions
• Engagement documents — proposals, agreements, and onboarding materials
• Third-party referrals — insolvency practitioners, accountants, or other referral partners (where applicable)

Where practicable, we collect personal information directly from you. If we receive information about you from a third party, we will take reasonable steps to notify you.

We collect and use personal information to:

• Deliver our diagnostic, advisory, and implementation services
• Conduct financial analysis, EBITDA normalisation, and value gap assessments
• Generate diagnostic reports, dashboards, and action roadmaps
• Communicate with you about your engagement and service delivery
• Issue invoices and manage payment
• Comply with legal and regulatory obligations
• Improve our services, systems, and methodologies (using anonymised or aggregated data only)

We will not use your personal information for any purpose unrelated to the above without your consent.

Your information is stored and processed using the following systems:

Security measures we apply

• HTTPS encryption on all web-facing systems
• Password-protected access to all platforms, with access limited to SCAFFOLD Advisory personnel only
• AI analysis conducted using zero-data-retention settings where available
• Data sanitisation applied before AI processing to remove unnecessary personal identifiers

Retention

We retain your personal information for a minimum of 7 years in accordance with Australian accounting and tax record-keeping obligations, unless a shorter retention period applies or you request earlier deletion (subject to our legal obligations).

We do not sell, rent, or trade your personal information. We may disclose personal information to:

• Technology platform providers listed in Section 5 — as data processors only, not for their own use
• Referral partners (e.g. insolvency practitioners or accountants) — only where you have given consent or where disclosure is directly related to your engagement and you would reasonably expect it
• Legal and regulatory authorities — where required by law, court order, or regulatory obligation
• Professional advisors (e.g. our insurers or legal counsel) — where necessary to protect our legitimate business interests

Where personal information is disclosed to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the APPs.

SCAFFOLD Advisory uses AI tools to assist with diagnostic analysis. We want to be transparent about how this works:

• Financial and operational data from your diagnostic questionnaire may be processed through AI models to generate findings and recommendations
• Before submission to AI systems, we apply a data sanitisation step to remove or anonymise direct personal identifiers where they are not required for the analysis
• Where possible, we use API-based access to AI tools under settings that do not permit your data to be used for AI model training
• All AI-generated analysis is reviewed by a qualified human consultant before delivery to you
• AI outputs are advisory only — no automated decisions are made that have legal or significant financial effect without human review and your informed agreement

Under the APPs, you have the following rights regarding your personal information:

To exercise any of these rights, contact us using the details in Section 9.

For all privacy-related enquiries, access requests, correction requests, or complaints, please contact us:

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Our website (scaffoldadvisory.com) may use standard web analytics tools to collect anonymised data about visitor behaviour, including pages visited, time on site, and general geographic location. This data is not linked to personally identifiable information.

We do not currently use advertising cookies or third-party tracking pixels. If this changes, this policy will be updated and visitors will be notified.

We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal obligations. The current version will always be available at scaffoldadvisory.com/privacy.

Material changes will be notified to active clients by email.