1. What this policy covers
This policy explains how The Trustee for Rowe Digital Trust, ABN 13 313 912 737, of Brisbane, Queensland, Australia (we, us) handles personal information on rowedigital.net, the corporate website you are reading. We trade under the business names BubSync and My Energy Agent.
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
The short version: this is a set of static pages. There are no accounts, no forms, no cookies and no analytics. Unless you email us, we do not learn who you are.
2. Products have their own policies
This policy does not cover our products. Each one holds its own accounts and its own data, and publishes its own privacy policy. If you are looking for what a product collects, how long it keeps it, or how to have it deleted, that policy is the one that applies to you:
- BubSync — privacy policy on bubsync.com
- My Energy Agent — privacy policy on myenergyagent.au
What we never do, anywhere: we do not sell personal information, we do not trade it, and we do not use the content you store in a product to build advertising profiles.
3. What this website collects
If you only read the site
Nothing you type, because there is nothing to type into. Serving a page creates a technical log record at our content delivery network, which includes your IP address, the page requested, the time, and your browser's user agent string. Those logs exist so we can see that the site is up and investigate abuse.
Your light or dark theme preference is stored in your own browser. It never reaches us.
If you email us
- Your email address, your name if you give it, and what you wrote
- Anything you choose to attach
We keep that correspondence so we have context if you write again. Please do not send us sensitive information, such as health or financial details, by email. If you need to give a product that kind of information, do it inside the product.
What we do not collect here
- No account details, because there are no accounts.
- No payment or card information, because no payment is ever taken on this website.
- No advertising identifiers, and no cross-site tracking of any kind.
4. Why we collect it
We use what little we hold to:
- deliver the pages you asked for and keep the site available;
- detect and investigate abuse, attacks and faults;
- answer your email and keep a record of the conversation; and
- meet our legal and record-keeping obligations.
We do not profile visitors, we do not do behavioural advertising, and we do not make automated decisions about you.
5. Cookies, analytics and trackers
This website sets no cookies. It loads no analytics, no advertising pixels, no tag managers, no social widgets and no third-party fonts. Typefaces are served from our own domain. Nothing on the page phones anyone else.
The only thing stored in your browser is the theme preference described above, kept in local storage on your device. Clearing your site data removes it.
Our products are different: an app has to keep you signed in, so it uses cookies or equivalent storage. Each product says so in its own privacy policy.
6. Payments
No payment is taken on this website, so there is nothing to disclose about card data here. We do not operate a checkout, we do not hold card numbers, and we do not pass anything to a payment provider from these pages.
Subscriptions are bought inside a product or through an app store. Who processes that payment, and what they hold, is set out in that product's privacy policy and in the store's own terms.
7. Who we share it with
We disclose personal information only in these situations:
- Service providers. The vendors that host this site and carry our email, listed below. They may use the information only to provide their service to us.
- Professional advisers. Our accountants and lawyers, where needed and under a duty of confidence.
- Legal requirements. Where we are required or authorised by law, a court order, or a regulator, or to establish or defend a legal claim.
- Safety. Where we reasonably believe disclosure is necessary to prevent a serious threat to life, health or safety.
- Business transfer. If our business is sold or transferred, to the acquirer, subject to this policy continuing to apply.
Service providers for this website
| Provider | What they do for us | Where data may be held |
|---|---|---|
| Amazon Web Services | Hosting and content delivery for this website, including request logs | Australia, United States |
| Our email provider | Carrying the email you send to our published company address | Australia, United States |
Each product publishes its own list of providers, which is longer than this one because a product has more moving parts.
8. Overseas disclosure
This site is served from a content delivery network with edge locations around the world, including in Australia, and its logs may be processed in the United States. Email may also be processed outside Australia by our email provider.
Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it consistently with the Australian Privacy Principles, including by using written contractual protections.
9. How long we keep it
- Web and delivery logs: up to 12 months, then deleted.
- Email you send us: up to 24 months, unless it relates to a contract or a record we are required to keep for longer.
- Records we must keep by law: for the period the relevant law requires, which for financial records is five years.
We destroy or de-identify personal information when we no longer need it and are not required to keep it.
10. How we protect it
The site is static, served over TLS from object storage with no application server and no database behind it, which removes most of the ways a website leaks data. Access to the hosting account is restricted and protected by multi-factor authentication. More detail is in our security overview.
11. Access, correction and deletion
You can ask us for a copy of the personal information we hold about you, ask us to correct it, or ask us to delete it. Email hello@rowedigital.net. We do not charge for access requests, and we will respond within 30 days, usually much sooner.
For anything held inside a product — your account, your entries, your subscription history — send the request to that product instead, using the address in its privacy policy. We cannot reach into a product's data from here, and routing it through us only makes it slower.
We may need to verify who you are before acting. There are narrow cases where the Privacy Act lets us refuse a request; if we refuse, we will tell you why in writing and how to complain about it.
12. Data breaches
If a breach happens that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme, and we will tell you what happened, what data was involved, and what to do about it.
13. Complaints
If you think we have mishandled your personal information, email hello@rowedigital.net with the details. We will acknowledge within 5 business days and give you a written response within 30 days.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au or on 1300 363 992.
14. Changes to this policy
We will update this policy if what the website does ever changes. The date at the top of the page shows the current version.
Questions about this policy
Write to hello@rowedigital.net and we will respond within 1 business day. That address covers this website, the company, and formal notices.
Anything about a product — your account, a charge, a refund, or the data held in it — goes to that product's own support address, listed on our support page.