Privacy Policy
1. Who we are
No Names Digital Pty Ltd ACN 638 089 693 (we, us, our) operates FairAlly, an electricity bill review service.
Postal: Suite 181, 79-83 Longueville Road, Lane Cove NSW 2066
We are the entity that collects and holds your personal information for FairAlly.
2. What we collect
Information you give us
- Name, email address, mobile number and postcode (registration)
- Your electricity bill file, and the information it contains: your name, address, NMI (National Metering Identifier), retailer, plan, tariff, consumption and charges
- Any additional information you give us for a review
- Support messages and correspondence
- Your communication permissions and the wording version you consented to
Information collected automatically
- Device, browser, approximate location and IP address
- Pages viewed and actions taken on the Site
- Login, security and session information
Information from other sources
- Plan and pricing data from electricity retailers, the AER Energy Product Reference Data service and other authorised plan sources
- Our CRM and service providers, where you have interacted with us through them
We do not ask for and do not want: your Medicare number, tax file number, driver licence, passport, bank account numbers, or any sensitive information. Do not send these to us.
3. Why we collect it, and the basis
We collect and use your personal information to:
- Create and verify your account
- Read and extract data from the electricity bill you upload
- Review your current electricity plan and compare it against available plans
- Prepare and show you a cost comparison and its assumptions
- Contact you about your review, and ask for missing information
- Provide support and handle complaints and privacy requests
- Detect and prevent fraud, misuse and security incidents
- Meet our legal and record-keeping obligations
- Compare review outcomes over time, using de-identified information, to check that our comparisons remain the best available to our customers (see clause 8.2)
- Send you marketing, only where you have separately given us permission (see clause 6)
We do not use your bill data for marketing to you unless you have given separate permission.
4. Automated processing and artificial intelligence
We use automated systems, including artificial intelligence, to read and structure the information in your bill.
- Ally is a fictional artificial intelligence assistant. Ally is not a human.
- Our cost comparison is calculated by a tested calculation method, not by an AI model inventing figures.
- We keep a record of review outcomes and the assumptions used.
- Where a comparison cannot be reliably calculated, we may refer your review to a human reviewer.
Automated decision-making transparency: from 10 December 2026, where we arrange for a computer program to use your personal information to make a decision that could reasonably be expected to significantly affect your rights or interests, we must describe that in this policy.
5. Who we share it with
We may disclose your information to:
| Recipient | Why |
|---|---|
| Cloud hosting and infrastructure providers | To host the Site and store your files |
| Our CRM provider | To manage your account record, tags and notifications |
| Email and SMS delivery providers | To send verification, review and notification messages |
| Bill-processing and comparison systems we operate | To perform the review |
| Our professional advisers | Legal, accounting and insurance, where needed |
| Regulators and law enforcement | Where required by law |
| A purchaser or successor | If the business or its assets are sold or restructured |
We do not sell your personal information.
5A. Overseas disclosure
Some of our service providers store or process data outside Australia.
Where we disclose personal information overseas, we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles. This does not apply where an exception under APP 8 applies.
6. Marketing and consent
- Marketing permission is separate, optional and unticked by default. Giving us your mobile number is not marketing permission.
- We record the wording version, the time and the source of each permission you give.
- You can withdraw marketing permission at any time using the unsubscribe link in any message, or by contacting us.
- We stop the relevant marketing communication when you reply or unsubscribe.
- We do not send marketing to you on behalf of other brands without your specific consent.
7. Security
We take reasonable steps to protect your personal information, including:
- private storage for uploaded bills, with access controlled per customer
- opaque document identifiers rather than guessable references
- short-lived authorised access to your documents
- server-side ownership checks so one customer cannot access another's bill or result
- encrypted transmission
We seek to exclude your bill data, address, NMI and tokens from analytics, URLs and public logs.
No system is perfectly secure. If a data breach occurs that is likely to result in serious harm, we will notify affected individuals and the OAIC as required by the Notifiable Data Breaches scheme.
8. Retention and deletion
There is no single retention period. We keep different information for different periods, and we keep each of them only for as long as we need it for a purpose in clause 3, or as required by law.
8.1 Your bill and review record
| What | How long | Why |
|---|---|---|
| Your uploaded bill (identifiable) | 90 days after your review is finalised, then deleted | We no longer need the document itself once the review is complete |
| Your account record (name, contact, plan details, review outcome) | While your account is open, then 7 years | Corporations Act 2001 (Cth) s 286 financial records, and to answer your questions and honour any guarantee |
| Consent and permission records | 5 years after the permission ends | To evidence your permission or its withdrawal |
| Transaction and billing records | 7 years | Corporations Act 2001 (Cth) s 286 |
| Tax records | 5 years from lodgement | Australian Taxation Office requirements |
8.2 De-identified analysis — the five-year benchmark record
You may withdraw your bill from our system at any time, and we will delete it. We keep a de-identified version of the review data for up to 5 years so we can compare outcomes over time and check that the results we give people are still the best available to them.
De-identified means the record does not identify you and cannot reasonably be used to identify you. We remove:
- your name, address, email address and mobile number
- your NMI and meter identifiers
- your account numbers and any document reference that points back to you
- your exact street address (we keep the general area and postcode zone at most)
We convert your consumption and pricing information into a benchmark record — usage profile, tariff structure type, network area, projected cost difference and the assumptions used.
De-identified information is not personal information under the Privacy Act 1988 (Cth), so it is not subject to the access, correction or deletion rights in clause 9.
We do not attempt to re-identify anyone, and we do not permit anyone else to.
8.3 Your deletion rights
You can ask us to delete your personal information at any time. When we delete, we delete or de-identify it, subject to any legal requirement to keep a record (for example our tax and financial records).
Deleting your account does not delete the de-identified benchmark record, because that record is no longer about you.
9. Your rights
You can ask us to:
- access the personal information we hold about you
- correct information that is inaccurate, out of date, incomplete or misleading
- delete your information, where we are not required to keep it
- withdraw marketing permission
- answer your questions about how we handle your information
We aim to respond within 30 days.
If you are not satisfied, you may complain to the Office of the Australian Information Commissioner (OAIC), oaic.gov.au or 1300 363 992.
10. Cookies and analytics
We use cookies and similar technologies to operate the Site, keep you signed in, remember your preferences and understand how the Site is used.
You can control cookies through your browser settings. Blocking some cookies may stop parts of the Site working.
We do not place your bill data, address, NMI or tokens into analytics tools.
11. Children
The Service is for people aged 18 and over. We do not knowingly collect information from children.
12. Changes to this policy
We may update this policy. We will post the current version and update the date. Material changes will be notified to registered users.
Last updated: 25 September 2026