Privacy Policy

1.1. WOLF.CO Pty Ltd (ACN 687 451 681) its Related Bodies Corporate (as that term is defined in the Corporations Act 2001 (Cth) (collectively referred to as “we”, “us” or “our”) is committed to protecting the privacy of personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (as amended from time to time) (“Privacy Laws”).

1.2. This Privacy Policy sets out how we collect, use, and disclose your personal information when you:

(a) visit our website at www.wolfco.au and any associated websites, platforms, portals, applications and digital services operated by us (“Website”);

(b) access or use our cloud-based franchise network management software platform (“Platform”), whether as a subscriber, an authorised user of a subscriber, or an individual whose information is entered into the Platform;

(c) engage us to provide franchise recruitment, franchise advisory, creative and brand, sales infrastructure, legal and compliance coordination or other professional services (“Consulting Services”);

(d) submit an enquiry, download materials, subscribe to communications, register for or attend an event or program, or otherwise interact with us;

(e) apply for an employment position with us, or offer to provide services to us as a contractor or consultant; or

(f) otherwise engage with us and provide personal information to us by any other means, including physically or electronically,
(collectively, the “Services”).

1.3. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

1.4. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

2.1. We handle personal information in two different capacities:

(a) For our own purposes: we collect and handle personal information about our clients and their personnel, prospective clients, Website visitors, referral partners, franchise candidates who engage with us directly, event participants, job applicants, and contractors, for the purposes described in this Privacy Policy; and

(b) On behalf of our clients: our franchisor clients and Platform subscribers (“Clients”) may enter, upload and store information in the Platform (including information relating to their franchisees, franchise candidates, personnel and other individuals) (“Client Data”). We host, store and process Client Data on behalf of the relevant Client for the purposes of providing the Platform and the Services.

2.2. Where we handle Client Data, the relevant Client is responsible for the collection of that information, for obtaining all necessary consents from, and giving all necessary notices to, the individuals concerned, and for the decisions made about that information. If your personal information has been entered into the Platform by one of our Clients (for example, if you are a franchisee or franchise candidate of a franchisor that uses the Platform), you should contact that Client in the first instance with any questions, or any request for access to or correction of your information, and you should refer to that Client’s own privacy policy. We will refer any request we receive to the relevant Client and provide reasonable assistance.

3.1. When used in this Privacy Policy, the terms “personal information” and “sensitive information” have the meaning given to them under the Privacy Laws, and we are referring to information that identifies, relates to, describes or can be associated with you.

3.2. We only collect your personal information where that personal information is necessary for one or more of our business functions or to provide the Services.

3.3. The types of personal information we collect may vary depending on the type of interaction you have with us.

3.4. When you use our Services, the personal information we collect includes:

(a) Basic contact details, including your full name, position or role, business name, address, phone number and email address;

(b) Business and client information, including information about your business, franchise system, network, objectives and requirements;

(c) Account information, including your username, password, security details, role, permissions and preferences used to create and secure your account on the Platform or the Website;

(d) Franchise candidate information, where you express interest in, apply for, or are considered for a franchise opportunity that we or our Clients are involved in recruiting for, including your contact details, background, experience, qualifications, financial capacity indicators, suitability assessments and progress through recruitment stages;

(e) Call recordings and transcripts, where calls, meetings or other communications are recorded and transcribed through the Platform or in the course of our Services, including your voice, image (where applicable), the content of the communication and any transcripts, summaries or analyses derived from them (see section 7);

(f) Billing and payment information, including billing contacts and details required to invoice and process payments. Payments are processed via third-party payment processors;

(g) Support and communications information, including any information you choose to provide when contacting us for assistance, submitting enquiries, providing feedback or otherwise communicating with us;

(h) Marketing preferences, so we understand how you wish to receive marketing communications and promotional materials from us;

(i) Marketing interaction data, such as information about your engagement with our marketing emails and other promotional content;

(j) Event and program information, including registration details and participation records for events, webinars, workshops or programs we run or are involved in;

(k) Device and usage data, including your IP address, device information, browsing behaviour and information about how you use the Website and the Platform, which helps us understand how people use our Services and improve our offerings;

(l) Franchise network management information, including information relating to franchisors, franchisees, prospective franchisees, directors, officers, managers, employees, contractors and other personnel within a franchise network, together with information concerning onboarding, training, compliance activities, audit outcomes, support requests, operational reviews, performance assessments, network communications, action items, tasks and other information required to administer, support, monitor and manage a franchise network through the Platform;

(m) Operational and performance information, including information about business operations, sales performance, benchmarking, key performance indicators, customer service outcomes, training completion, compliance with franchise standards and other information used by franchisors and franchisees to operate, support and improve franchise network performance;

(n) User-generated content and records, including notes, correspondence, meeting records, reports, forms, surveys, acknowledgements, policies, procedures, uploaded documents, recordings, transcripts and other content created, uploaded, stored, shared or processed through the Platform in connection with the operation and management of a franchise network; and

(o) Workforce and personnel information, including contact details, position information, training records, certifications, qualifications, employment-related information and workplace compliance records relating to personnel engaged by franchisors or franchisees, where such information is uploaded to or managed through the Platform.

3.5. Some features of the Services may require you to directly provide us with certain information about yourself. You may choose not to provide this information, but doing so may prevent you from using or accessing these features.

3.6. If you do not provide us with your personal information, this may impact or restrict our ability to interact with you.

3.7. We do not collect sensitive information about you (which includes information about racial or ethnic origin, religious beliefs, health or criminal record) without your express consent or otherwise in accordance with the Privacy Laws.

4.1. Your personal information may be collected by us in various ways, including, but not limited to, when you:

(a) visit or engage with the Website, submit an enquiry, complete an enquiry form, franchise application form or lead generation form (including through Meta Lead Ads, Google Lead Ads or similar advertising platforms),

(b) create an account on, log into, or use the Platform, or are set up as an authorised user by a Client;

(c) engage us, or are involved in an engagement, for Consulting Services;

(d) express interest in, apply for, or participate in a franchise recruitment process that we manage or support;

(e) participate in a phone call, video conference, meeting, webinar or other communication that is recorded or transcribed through the Platform or in the course of our Services;

(f) subscribe to our newsletter or other communications (if applicable);

(g) register for, attend or participate in an event, webinar, workshop, seminar, information session or program;

(h) participate in a survey or feedback form;

(i) engage in any support interactions (including email, phone, video conference and social media);

(j) contact any of our employees, contractors or officers;

(k) apply for a position with us, or offer to provide services to us as a contractor;

(l) interact with the Website or the Platform through cookies, analytics and other tracking technologies;

(m) interact with our marketing partners or advertising platforms, including when you engage with our advertisements or promotions; and/or

(n) use third-party applications and services integrated with the Website or the Platform (such as customer relationship management, scheduling, video-conferencing, transcription, email marketing and analytics tools), which may provide us with information relating to your interactions with those applications.

4.2. We may also collect personal information about you from third parties, including from our Clients (where your information is provided to us in connection with the Services), publicly available sources, and our service providers.

5.1. We collect your personal information so that we can use it for our functions and activities and provide the Services. This includes using your personal information for the following purposes:

(a) Providing the Platform: to provide, operate, secure and support the Platform, including creating and managing accounts, hosting and processing Client Data, generating notifications, workflows, milestones, dashboards, reports and other outputs, and providing technical support;

(b) Providing the Consulting Services: to provide franchise recruitment, franchise advisory, franchise development and marketing services;

(c) Franchise recruitment: to identify, assess, and manage franchise candidates through recruitment processes conducted by us or on behalf of our Clients, to assess suitability for franchise opportunities, and to track candidate progress through recruitment stages;

(d) Recording and transcription: to record, store, transcribe, summarise and analyse calls and meetings conducted through or uploaded to the Platform, or in the course of our Services, as described in section 7;

(e) Benchmarking and insights: to produce de-identified and aggregated benchmarking data, performance metrics, industry insights and best-practice frameworks, as described in section 8;

(f) Billing and administration: to invoice, process payments, verify payment methods, manage subscriptions and renewals, and administer our contractual relationships;

(g) Customer service: to provide support, respond to feedback, complaints and enquiries, troubleshoot issues, manage our relationships with Clients, prospective Clients, franchisees and franchise candidates, and send important service-related, administrative and transactional communications (including Platform notifications, maintenance and renewal notices);

(h) Marketing communications: to keep you informed about marketing initiatives, including direct marketing campaigns, promotions, events, new products and services, newsletters and updates, using email, SMS, phone and retargeting advertisements;

(i) Recruitment and engagement: to assess, process and manage employment applications, and to assess and engage contractors and consultants;

(j) Service and Website improvement: to recognise the device you use, analyse how you interact with the Website, the Platform and our Services, conduct analytics, monitor usage patterns, and improve functionality, performance, security and user experience, including through analytics and performance optimisation tools;

(k) Internal business operations: to support our internal operations, including business administration, record keeping, fraud prevention, security, risk management, and compliance with legal and regulatory obligations;

(l) Research and insights: to conduct market research and to understand preferences, patterns and behaviours to enhance our product and service development;

(m) CRM and record management: to create, maintain, update and manage records within our customer relationship management systems and other business systems used to administer our Services, manage client and candidate relationships and maintain accurate business records; and

(n) Product development: for administrative, planning, product or service development, quality control and research purposes.

5.2. We may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, or for such purposes as may be required or permitted by law.

6.1. Where Clients enter, upload or store Client Data on the Platform (including franchise agreements, franchisee and candidate records, meeting recordings and related information), we host, store, process, transcribe, back up and otherwise handle that Client Data on the Client’s behalf, in accordance with our agreement with the Client and this Privacy Policy.

6.2. Each Client is responsible for ensuring that it has collected Client Data lawfully, and that it has obtained all consents and given all notices required under the Privacy Laws for us to handle the Client Data in this way.

6.3. We retain Client Data for the duration of the relevant Client’s subscription, and afterwards in accordance with our agreement with the Client (including any continued access arrangement the Client has elected). Client Data will then be deleted or de-identified in accordance with that agreement and our data retention practices, except to the extent that we are required or permitted to retain the Client Data to comply with applicable laws, regulatory requirements, legal process, insurance requirements, audit obligations, dispute resolution requirements or legitimate business record-keeping requirements.

7.1. The Platform and our Services include functionality that enables calls, meetings and other communications to be recorded, stored, transcribed, summarised and analysed.

7.2. Where we record a call or meeting for our own purposes, we will notify you before recording begins and, where required by applicable law, obtain any necessary consents. If you do not wish to be recorded, please let us know at the start of the communication.

7.3. Where a recording is made by or on behalf of a Client through the Platform, the Client is responsible for notifying participants and obtaining any consents required by law. If you have participated in a communication recorded by a Client, please direct any questions to that Client in the first instance.

7.4. We and our Clients may use recordings, transcripts, summaries and analyses for the purpose of providing and improving the Services, maintaining records of communications, training, quality assurance, compliance, dispute resolution and other purposes described in this Privacy Policy.

7.5. Transcripts, summaries and analyses may be generated using automated technologies (including third-party speech-to-text services).

8.1. We may de-identify and aggregate information (including information derived from Client Data and usage of the Platform) so that it no longer identifies you or any individual, and use it to operate, improve and develop the Platform, Services and our other products and services, and to produce and publish benchmarking data, performance metrics, industry insights and best-practice frameworks.

8.2. De-identified and aggregated data may be disclosed and made available to other clients and prospective clients (for example, for benchmarking purposes), but only in a form that does not identify you, any individual, or any Client.

9.1. We use cookies, web beacons and similar technologies on the Website, Platform and through our Services to identify specific devices and collect aggregate information on how visitors are experiencing the Website and the Platform. A “cookie” is a small text file stored on a user’s computer or other internet-connected device which contains information about the user. Cookies collect device information, IP address, approximate location, pages visited, time spent, interactions, form and enquiry activity, advertising interactions and related conversion data. This information helps us understand usage patterns, improve functionality and performance, personalise your experience, and support our marketing and advertising activities.

9.2. The tools and technologies which may place cookies on your device, include, but are not limited to:

(a) analytics tools (such as Google Analytics);

(b) advertising and social media pixels (such as Meta Pixel);

(c) platform, session and login cookies used to operate the Website and the Platform;

(d) marketing, customer relationship management and customer engagement tools; and

(e) user experience and performance tools, including heatmapping and session recording technologies (where enabled).

9.3. Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies through your browser controls. Please keep in mind that removing or blocking cookies can impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking cookies may not completely prevent how we share information with third parties such as our service providers.

10.1. Where you have consented, we may use your personal information from time to time to contact you (including via SMS, email or telephone) to let you know about news, special offers, products and services that you might be interested in (“Marketing Communications”).

10.2. You may opt out at any time by following the instructions in the Marketing Communications, or otherwise by contacting us directly via the contact details in section 20 below.

10.3. If you opt out of Marketing Communications, we may still send you non-promotional communications that are necessary for administrative, transactional or service-related purposes, such as invoices, account notices, Platform notifications, renewal notices or important service updates.

11.1. We may disclose any personal information we collect, hold, use or otherwise process about you, regardless of the source from which that information was obtained, where reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by law.

11.2. The types of persons and organisations to whom we may disclose your personal information include:

(a) our employees, related entities, suppliers, consultants, contractors or agents:

(i) to carry out the purposes set out in section 5 above or for other purposes directly related to the purpose for which the personal information is collected; and/or

(ii) to assist us in providing and promoting our products and services to you (including contractors we engage from time to time to perform all or part of the Services, who are bound by confidentiality and privacy obligations);

(b) suppliers and third-party service providers who assist us in operating, managing, supporting and improving our business and services, including cloud hosting providers, IT infrastructure providers, customer relationship management (CRM), Google Workspace, software and platform vendors, transcription and speech-to-text providers, video-conferencing and telephony providers, system administrators, electronic payment providers (including Stripe), accounting software providers (including Xero), analytics providers, development partners, customer support platforms, recruitment partners, marketing agencies, data processing providers, debt collection agents and electronic network administrators;

(c) Meta Platforms, Google and other advertising, marketing and social media platforms used to support our marketing, communications and lead generation activities;

(d) our Clients, where you are a franchise candidate, franchisee or other individual whose information is collected or processed in connection with the Services we provide to that Client;

(e) franchise legal specialists and other professionals with whom we coordinate in delivering legal and compliance coordination services, where relevant to the engagement;

(f) professional advisors, including accountants, solicitors, business advisors, consultants and other specialists;

(g) any person or entity to whom we sell or transfer, or propose to sell or transfer, all or part of our business or assets, subject to appropriate confidentiality arrangements;

(h) law enforcement agencies, regulators, courts and other government bodies where required or permitted by law; and/or

(i) any other person or organisation where you have provided your consent or where disclosure is otherwise permitted by law.

12.1. Your personal information may be held and stored in both electronic and physical form. Electronic records may be stored by us or by third-party service providers engaged by us (including cloud hosting, data storage and IT infrastructure providers). Physical records may be stored at our business premises or at secure storage facilities operated by us or our service providers.

12.2. Where we store your personal information depends on the nature of your interactions with us, the services we provide, and the purposes for which we collect, use and disclose your personal information.

13.1. We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These measures include implementing role-based access controls, multi-factor authentication, endpoint security measures, secure password requirements, regular software updates and patch management, and internal information security policies and procedures. Access to personal information is restricted to personnel who have a legitimate business need to access that information in the performance of their duties.

13.2. Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security”. In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

13.3. How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, to comply with legal obligations, to resolve disputes or to enforce applicable contracts and policies. When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

13.4. If a data breach occurs that is likely to result in serious harm to any individual, we will comply with our obligations under the Notifiable Data Breaches scheme in the Privacy Act 1988 (Cth), including assessing the breach and notifying affected individuals and the Office of the Australian Information Commissioner where required.

14.1. We may disclose personal information to our third-party suppliers and service providers located outside of Australia for some of the purposes listed above (including cloud hosting, transcription, analytics and marketing technology providers and administrative support providers). This may involve disclosure to countries including, without limitation, the United States of America, the Philippines, Singapore and New Zealand.

14.2. By providing us with your personal information, you consent to the transfer of your personal information overseas.

14.3. We will use reasonable endeavours to ensure that any overseas recipient of personal information handles that information in a manner consistent with the Australian Privacy Principles. However, we cannot guarantee the privacy or security practices of overseas recipients.

15.1. When you are on the Website or the Platform, you may be directed to other websites that are beyond our control. If you visit one of these linked websites, you should review their privacy and other policies. A link to a third-party website is not an endorsement by us as to the accuracy or trustworthiness of that website or any contents and information collected, and we are not responsible for the policies and practices of those third-party websites.

16.1. Under the Privacy Laws, you have rights to access and correct personal information that we hold about you.

16.2. You may request access to the personal information and seek correction of same by contacting us via the contact details in section 20 below.

16.3. There may be instances where we cannot grant you access to the personal information that we hold about you, for example, if it would result in a breach of confidentiality or would interfere with the privacy of others.

16.4. If your personal information is held by us as Client Data on behalf of a Client, we may refer your request to the relevant Client, who is responsible for responding to it (see section 2).

16.5. We may charge a reasonable administration fee to cover the costs of meeting your request.

16.6. Where we receive a request to access or correct personal information, we will take reasonable steps to respond to such requests within a reasonable period of time.

17.1. Generally, when you apply for a position with us, or offer to provide services to us as a contractor or consultant, through the Website, a third-party website or a recruitment agency, we will collect and store the type of personal information we reasonably require to assess your application.

17.2. Depending on the position or engagement that you are applying for, we may collect and store some or all of the following information (without limitation) from you:

(a) full name;

(b) date of birth and/or age;

(c) postal address;

(d) telephone number and email address;

(e) education and qualification details;

(f) employment history, business details (including ABN and insurances, for contractors) and other information relating to your work experience;

(g) information that would enable us to identify you and your work entitlements in Australia, such as your driver’s licence or passport details; and

(h) references (it is your responsibility to ensure that you provide us with contact details of people who have provided their express consent to you for their personal information to be included in your application).

17.3. In considering your application, we may also obtain personal information about you from third parties, for example, from your previous employers or clients, or nominated referees. Subject to your consent, we may also collect sensitive information about you such as information about your health (including any disability) or any criminal record you may have.

17.4. We may, unless you tell us otherwise, store your personal information for future employment or engagement opportunities.

17.5. We may disclose your information to:

(a) your referees, previous employers or previous clients;

(b) recruitment agencies or contractors acting on our behalf;

(c) our related entities;

(d) law enforcement agencies to verify whether you have a criminal record;

(e) educational organisations to the extent necessary to verify your qualifications; and

(f) other government bodies for the purposes of assessing your working rights in Australia.

18.1. We may modify or update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal or regulatory reasons.

18.2. We will post the revised Privacy Policy on our Website, update the “Last Updated” date and take any other steps required by the Privacy Laws.

19.1. If you have queries and/or complaints about how we handle your personal information, please contact us in accordance with section 20 below.

19.2 If you are dissatisfied with our response to your complaint or consider that we have breached the Privacy Laws, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):

(a) Address: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001

(b) Phone: 1300 363 992

(c) Email: enquiries@oaic.gov.au

(d) Website: https://www.oaic.gov.au/

20.1. Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please contact us at shawn.tracey@wolfco.au.

Last Updated: Tuesday 18th August 2026