GDPR Compliance Statement

Last Updated: May 17, 2026

1. Introduction

While Twinkling Suspension is based in Australia and primarily operates under Australian privacy laws, we recognize that some of our clients or website visitors may be located in the European Union (EU) or European Economic Area (EEA). This GDPR Compliance Statement outlines how we comply with the General Data Protection Regulation (GDPR) for individuals in those regions.

2. Data Controller

For the purposes of GDPR, Twinkling Suspension is the data controller responsible for your personal data.

Contact Details:
Twinkling Suspension
Level 12, 385 Bourke Street
Melbourne VIC 3000
Australia
Email: [email protected]

3. Legal Basis for Processing

We process personal data under one or more of the following legal bases:

  • Consent: You have given clear consent for us to process your personal data for a specific purpose
  • Contract: Processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
  • Legal obligation: Processing is necessary for us to comply with the law
  • Legitimate interests: Processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests

4. Your Rights Under GDPR

If you are located in the EU/EEA, you have the following rights regarding your personal data:

4.1 Right to Access

You have the right to request copies of your personal data. We may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

4.2 Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

4.3 Right to Erasure

You have the right to request that we erase your personal data, under certain conditions.

4.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data, under certain conditions.

4.5 Right to Object to Processing

You have the right to object to our processing of your personal data, under certain conditions.

4.6 Right to Data Portability

You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.

4.7 Right to Withdraw Consent

Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time.

5. How to Exercise Your Rights

To exercise any of your rights under GDPR, please contact us at:

Email: [email protected]

We will respond to your request within one month, although this period may be extended by two further months in certain circumstances.

6. Data Protection Officer

While we are not required to appoint a Data Protection Officer under GDPR, all data protection inquiries can be directed to our designated privacy contact at [email protected].

7. International Data Transfers

As an Australian company, personal data collected from EU/EEA individuals will be transferred to and processed in Australia. Australia is recognized by the European Commission as providing adequate protection for personal data. We ensure that appropriate safeguards are in place for any further international transfers.

8. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

  • To provide our services to you
  • To comply with legal, accounting, or reporting requirements
  • To resolve disputes and enforce our agreements

Financial services records are typically retained for a minimum of seven years in accordance with regulatory requirements.

9. Automated Decision-Making and Profiling

We do not use automated decision-making or profiling that would have legal or similarly significant effects on individuals.

10. Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data in transit and at rest
  • Regular security assessments and updates
  • Access controls and authentication mechanisms
  • Staff training on data protection
  • Incident response procedures

11. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly.

12. Third-Party Service Providers

We may engage third-party service providers to process personal data on our behalf. We ensure that:

  • All processors are carefully selected and assessed
  • Written contracts are in place with appropriate data protection terms
  • Processors only process data in accordance with our instructions
  • Appropriate technical and organizational measures are implemented

13. Cookies and Tracking

We use cookies and similar technologies on our website. For EU/EEA visitors, we obtain consent before placing non-essential cookies. For more information, please see our Cookies Policy.

14. Children's Data

Our services are not directed at children under 16 years of age. We do not knowingly collect or process personal data from children. If we become aware that we have collected data from a child without appropriate consent, we will take steps to delete that information.

15. Supervisory Authority

If you are located in the EU/EEA and believe that our processing of your personal data violates GDPR, you have the right to lodge a complaint with a supervisory authority in the EU member state where you reside, work, or where the alleged violation occurred.

16. Changes to This Statement

We may update this GDPR Compliance Statement from time to time. Any changes will be posted on this page with an updated revision date.

17. Contact Us

If you have any questions about our GDPR compliance or wish to exercise your rights, please contact us:

Email: [email protected]
Address: Level 12, 385 Bourke Street, Melbourne VIC 3000, Australia