Last updated: 1/08/2026
Who we are:
This website is operated by EFCOMM Pty Ltd (ACN 607 661 727 / ABN 72 607 661 727) trading as Cheat Code ("we", "us", "our"). We're a face-to-face sales and marketing agency with offices in Australia and New Zealand.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and the Privacy Act 2020 (NZ) and the Information Privacy Principles.
What we collect:
Depending on how you deal with us, we may collect:
Contact details — name, email, phone number, location.
Enquiry information — your business, the services you're interested in, and anything else you tell us.
Job application information — résumé, work history, education, qualifications, right-to-work status, references, interview notes and assessment results.
Marketing preferences — whether you've opted in to email or SMS updates.
Technical information — IP address, browser and device type, pages viewed and referral source, collected automatically through cookies and analytics.
We don't seek sensitive information (such as health or background details) unless it's genuinely necessary for a role and you've consented to us collecting it.
You can deal with us anonymously or under a pseudonym where it's lawful and practical, but we generally can't respond to an enquiry or assess an application without your real details.
How we collect it:
Mostly directly from you — through forms on this website, by phone, email or SMS, at interviews and events, and through job boards such as SEEK. We may also collect information from referees you nominate, from publicly available sources such as LinkedIn, and automatically through cookies when you use the site.
Why we use it:
We use personal information to:
respond to enquiries and provide our services;
assess and progress job applications, and contact you about current or future roles;
manage our relationship with clients and candidates;
send marketing and updates where you've opted in;
improve the website and understand how it's used; and
meet our legal obligations.
We only use your information for the purpose it was collected for, a directly related purpose you'd reasonably expect, or where you've consented or the law requires it.
Who we share it with:
We may disclose personal information to:
Service providers who help us operate — our CRM and website platform (GoHighLevel), email and SMS providers, analytics and advertising platforms, cloud storage and recruitment tools;
Clients we represent, where relevant to a campaign, in de-identified or aggregate form wherever possible;
Referees and background-check providers, with your consent, as part of a job application; and
Regulators, courts or law enforcement, where required or authorised by law.
We don't sell personal information.
Overseas disclosure:
Some of our service providers store or process data outside Australia and New Zealand, including in the United States, the European Union and other countries where those providers operate data centres. This includes our CRM, website hosting, email and SMS platforms, and analytics and advertising services.
Where we disclose personal information overseas, we take reasonable steps to ensure it's handled consistently with Australian and New Zealand privacy law, including through our contracts with those providers. By providing your information you acknowledge it may be stored and processed outside your country.
Personal information moving between our Australian and New Zealand operations is handled under this policy in both countries.
Marketing and communications:
If you give us your email address or phone number, we'll use it to respond to your enquiry, application or account.
Where you've opted in, we'll also send you marketing by email and SMS in line with the Spam Act 2003 (Cth) and the Unsolicited Electronic Messages Act 2007 (NZ). You can opt out at any time by using the unsubscribe link in any email, replying STOP to any SMS, or emailing us at [CONTACT EMAIL]. We'll action it promptly. You'll still receive messages about an active enquiry, application or account.
Cookies and tracking:
This website uses cookies and similar technologies for functionality, analytics and advertising, including tools provided by Google and Meta. These help us understand site usage and measure our advertising. You can block or delete cookies through your browser settings, though some parts of the site may not work properly if you do.
How we store and protect it:
We store personal information in secure cloud-based systems with access limited to staff who need it. We take reasonable technical and organisational steps to protect it from misuse, loss, unauthorised access, modification and disclosure — including access controls, encryption in transit, and staff training.
No system is completely secure. If a data breach occurs that's likely to cause serious harm, we'll notify affected individuals and the Office of the Australian Information Commissioner (OAIC) or the Office of the New Zealand Privacy Commissioner, as required.
How long we keep it:
We keep personal information only as long as we need it, or as required by law.
Unsuccessful job applications — retained for [24] months so we can contact you about future roles, then deleted or de-identified. Tell us if you'd like yours removed sooner.
Enquiries — retained for the life of the relationship and a reasonable period afterwards.
Employment and client records — retained for the periods required under employment, tax and corporations law.
Accessing and correcting your information:
You can ask us for a copy of the personal information we hold about you, or ask us to correct it if it's wrong or out of date. Email us at [CONTACT EMAIL].
We'll respond within 30 days. There's no charge, though we may charge a reasonable fee for large or complex requests. If we can't give you access, we'll explain why.
If you're in New Zealand, you have the right to access and correct your information under the Privacy Act 2020 (NZ).
Complaints:
If you think we've mishandled your personal information, email us at [CONTACT EMAIL] with the details. We'll acknowledge your complaint and aim to resolve it within 30 days.
If you're not satisfied with our response, you can contact:
Australia — Office of the Australian Information Commissioner, oaic.gov.au, 1300 363 992
New Zealand — Office of the Privacy Commissioner, privacy.org.nz, 0800 803 909
Changes to this policy:
We may update this policy from time to time. The current version is always published on this page with the date it was last updated.
Contact us:
EFCOMM Pty Ltd trading as Cheat Code Level 5, 3 Alison Street, Surfers Paradise QLD 4217 Email: [CONTACT EMAIL] Phone: 0477 703 618
