Privacy Policy

Who We Are

Prime 73 Strategy ("Prime 73", "we", "us", "our") is an AI consulting and implementation firm operating across the Asia-Pacific region. Our primary operating entity is based in Sydney, Australia, with headquarters in Manila, the Philippines.

We provide services including AI readiness assessments (Prime Diagnostic™), workflow integration (PrimeStream™), fractional advisory (Vanguard Advisory™), and training (Prime Vanguard™ Training).

For the purposes of applicable privacy law, Prime 73 Strategy is the data controller in respect of personal information processed in connection with our website, marketing activities, and professional services.

Information We Collect

We collect personal information in the following ways:

Information you provide to us directly

• Name, job title, company name, and business email address — when you complete our contact form, book a call, or subscribe to the Prime Vanguard Briefing
• Country, industry, and company size — when you complete our free AI Readiness Assessment
• Assessment responses — the answers you provide in the AI Readiness Assessment tool
• Message content — the body of any enquiry submitted via our contact form
• Correspondence — email exchanges with our team

Information collected automatically

• IP address and approximate geographic location
• Browser type, operating system, and device information
• Pages visited, time on site, and navigation patterns (via analytics)
• Referral source (how you arrived at our website)

Information from client engagements

In the course of delivering professional services, we may process personal information about your employees, customers, or other individuals — for example, in connection with stakeholder interviews conducted during a Prime Diagnostic™ engagement. This processing is governed by our engagement-specific data processing agreements.

How We Use Your Information

We do not use personal information for automated profiling or decision-making that produces legal or similarly significant effects.

Legal Basis for Processing

Depending on the jurisdiction and the nature of the processing, we rely on the following legal bases:

• Consent — for newsletter subscriptions and marketing communications; you may withdraw consent at any time
• Contract performance — for processing necessary to deliver our professional services to you
• Legitimate interests — for responding to enquiries, improving our website, and maintaining business records; we have assessed that our interests do not override your rights
• Legal obligation — where we are required to process data to comply with applicable law

For individuals in Australia, we comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. For individuals in Singapore, our processing is conducted in accordance with the Personal Data Protection Act 2012 (PDPA). For individuals in Hong Kong, we comply with the Personal Data (Privacy) Ordinance (PDPO) and associated PCPD guidance.

Sharing of Information

We do not sell personal information. We do not share personal information with third parties for their marketing purposes.

We may share personal information in the following limited circumstances:

• Service providers — third parties who assist us in operating our business (e.g. email delivery, analytics, document storage). These parties are contractually bound to process data only as instructed by us and to maintain appropriate security standards.
• Professional advisors — lawyers, accountants, and insurers, where necessary and subject to confidentiality obligations.
• Regulatory authorities — where we are required to disclose information by applicable law, court order, or regulatory authority.
• Business transfers — in the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred as part of that transaction; we will notify you in advance if this occurs.

Vendor relationships and referral arrangements. Prime 73 holds referral and affiliate arrangements with certain software vendors. These are commercial arrangements only: we do not share your personal information with vendor partners for their marketing, and referral income never influences the recommendations we make. Where a vendor is relevant to a recommendation in your engagement, that relationship is disclosed to you in writing under our Vendor Disclosure Policy.

International Transfers

Prime 73 Strategy operates across Australia, Singapore, Hong Kong, and the Philippines. Personal information may be accessed by our team members in any of these locations in the course of delivering our services.

Where we transfer personal information across borders, we ensure that appropriate safeguards are in place — including contractual protections — consistent with the requirements of applicable privacy law in each jurisdiction.

Some of our third-party service providers may process data in countries outside the APAC region. Where this occurs, we conduct due diligence on their data protection practices and ensure appropriate safeguards are in place before transferring personal information.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, and as required by applicable law.

• Enquiry and contact data — retained for 2 years from last contact, unless an engagement commences
• Client engagement data — retained for 7 years from engagement completion (consistent with standard professional services obligations)
• Newsletter subscribers — retained until you unsubscribe, or until the list is dormant for 3 years
• AI Readiness Assessment responses — anonymised immediately on submission unless you provide your email address, in which case retained for 1 year
• Website analytics data — retained in aggregated, anonymised form; raw data retained for 14 months

When retention periods expire, we securely delete or anonymise personal information.

Your Rights

Depending on your jurisdiction, you may have the following rights in relation to your personal information:

• Access — to request a copy of the personal information we hold about you
• Correction — to request correction of inaccurate or incomplete information
• Deletion — to request deletion of your personal information, subject to legal retention obligations
• Portability — to receive your personal information in a structured, machine-readable format
• Objection — to object to processing based on legitimate interests
• Withdrawal of consent — to withdraw consent at any time where processing is consent-based
• Complaint — to lodge a complaint with the relevant data protection authority in your jurisdiction

To exercise any of these rights, contact us at hello@prime73strategy.com. We will respond within 30 days. We may need to verify your identity before processing your request.

Relevant authorities by jurisdiction: Office of the Australian Information Commissioner (Australia) · Personal Data Protection Commission (Singapore) · Office of the Privacy Commissioner for Personal Data (Hong Kong).

Security

We implement technical and organisational measures appropriate to the sensitivity of the personal information we hold and the risks of our processing activities. These include:

• Encryption of data in transit (TLS) and at rest
• Access controls limiting data access to personnel with a legitimate need
• Regular review of third-party service provider security practices
• Incident response procedures for suspected data breaches

No transmission of data over the internet is completely secure. While we take reasonable precautions, we cannot guarantee the security of information you transmit to us. If you believe your personal information has been compromised, please contact us immediately.

Cookies

Our website uses cookies and similar technologies for the following purposes:

We do not use advertising or tracking cookies. We do not allow third-party advertising networks to place cookies on our website.

You can control or delete cookies through your browser settings. Disabling analytics cookies does not affect your ability to use our website.

Children

Our website and services are directed at business professionals and are not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, please contact us and we will delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where required by law, notify affected individuals directly.

We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes acceptance of the updated policy.

How to Contact Us

For any questions, requests, or complaints relating to this Privacy Policy or our handling of your personal information, please contact us:

We will acknowledge your query within 5 business days and provide a substantive response within 30 days, or notify you if we require more time.