# Cleano Legal Policies **Status: Draft for business verification and Australian legal review. Prepared 21 October 2026. Not an assertion of compliance or an effective contract.** These drafts describe the Australian cleaning business and the website changes prepared with them. They must not be treated as final policies until the separate action list is completed. They contain no invented operator identity, ABN, DPO, security certification, advertising identifier or AI provider. They do not create a separate legal entity called Cleano. Publication alone does not establish contract acceptance. ## 1. Terms of Service ### Services and Contract Formation Cleano provides residential and commercial cleaning through its cleaners in Australia. The accepted quote specifies the property, agreed tasks, price, frequency and scheduled service. A quote request is free and is not a booking. A service contract is formed when an adult customer accepts the quote after being given the applicable terms and cancellation policy. A 50% bank-transfer deposit is required to secure the booking slot; the remaining 50% is due on completion. Payment instructions are supplied separately. Do not send banking passwords or card credentials through the website. Only agreed tasks are included. Extra work and price changes require agreement before the extra work begins. Cleano may decline unsafe, unlawful or out-of-scope work and will explain any effect on the booking and amounts paid. Cleano does not guarantee a landlord's decision, bond recovery, permanent stain removal or outcomes outside the agreed scope. These statements do not qualify any express promise or non-excludable consumer guarantee. ### Eligibility, Access and Accounts Customers must be at least 18 and authorised to arrange access to the property. Provide accurate contact and service information, reasonable safe access, and relevant hazard information without unnecessarily disclosing sensitive information. Do not misuse the site, interfere with its security, upload unlawful material or impersonate another person. The current website has no customer account registration. If accounts are introduced, separate account rules must be provided before launch, addressing credentials, unauthorised access, eligibility, security and closure. Cleano may restrict abusive or unlawful website use, but restriction does not remove an existing booking obligation or statutory remedy. Booking cancellation and any refund must be handled fairly under the cancellation policy and applicable law. ### Intellectual Property Cleano retains the rights it owns in its branding, website design, text and code. Other material remains subject to its owners' rights and licence conditions. Visitors receive a limited permission to access the site for legitimate service enquiries and bookings, not to commercially reproduce its content or falsely imply affiliation. Statutory exceptions and third-party licence rights are preserved. AI-generated images do not necessarily attract copyright or exclusive ownership; no broader exclusivity is asserted than the law permits. ### Website Availability and Warranties To the extent permitted by law, the informational website is supplied as available and without additional warranties concerning uninterrupted or error-free operation. This does not disclaim the obligation to provide cleaning services with due care and skill, fitness for a disclosed purpose where applicable, within a reasonable time, or in accordance with express commitments. ### Consumer Guarantees and Liability Nothing excludes, restricts or modifies rights, guarantees, remedies or liabilities that cannot lawfully be excluded, including under the Australian Consumer Law. Depending on the failure, remedies may include re-performance, cancellation, an appropriate refund and compensation for reasonably foreseeable loss. These rights can apply to business customers as well as household customers. Only where lawful and fair, liability for website use outside those protected rights is limited to reasonably foreseeable direct loss, and the aggregate amount paid for the service giving rise to the claim. Indirect, incidental, consequential, exemplary and punitive losses are excluded only to the extent the exclusion is legally effective. This limitation does not apply to fraud, wilful misconduct, personal injury, damage caused by a failure to exercise due care and skill, or any non-excludable liability. It must not be read as excluding foreseeable property damage or consumer compensation. No clause guarantees immunity from claims. ### Misuse and Third-Party Claims To the extent lawful and fair, a customer is responsible for reasonable, proven third-party losses directly caused by the customer's unlawful or deliberately harmful misuse of the site or material supplied by that customer. This does not cover Cleano's negligence, unlawful acts, breach of contract or statutory responsibilities. Cleano must give reasonable notice, mitigate loss and permit reasonable participation in a defence; no settlement imposing obligations on the customer may be made without consent. There is no blanket duty to defend all claims against Cleano. ### Cancellation, Disputes and Governing Law The Refund and Cancellation Policy forms part of the service terms when supplied before acceptance. NSW law governs, subject to mandatory protections of any applicable jurisdiction. Contact info@cleanoservices.com.au or 0434 274 784 with booking details and the requested remedy. The parties may agree to mediation after a dispute arises. Court, tribunal, regulator and urgent-relief rights remain available; this draft imposes no mandatory arbitration or class-action waiver. NSW courts have non-exclusive jurisdiction, subject to any mandatory forum rights. ### Changes and Severability Changes apply prospectively. The terms supplied at acceptance govern an existing booking unless a lawful variation is agreed. Keep a copy of the quote and terms. An invalid term is severed only where lawful without rewriting the bargain or removing consumer protections. No failure to enforce a provision automatically waives it. ## 2. Privacy Policy ### Scope and Contact This draft concerns Cleano's Australian cleaning enquiries and services. Contact info@cleanoservices.com.au or 0434 274 784 for privacy questions or requests. No dedicated DPO or overseas representative is represented as appointed. The operator identification, provider inventory and AI-training controls must be verified before this becomes an effective public notice. ### Information Collected - Enquiries and bookings: names, telephone numbers, email addresses, property addresses, service selections, property size and room counts, preferred dates/times, recurring-service preferences and comments. - Communications and service administration: correspondence, quotes, acceptances, complaints, service records and payment status. - Billing: bank-transfer references, transaction amounts, dates and relevant payer information for reconciliation. The current site has no card-payment checkout; Cleano does not ask for banking passwords or card credentials in the quote form. - Technical information: hosting/request logs may include IP address, request time, browser/device data and requested pages. Actual providers, log settings and retention require verification. - Optional analytics: after opt-in, GA4 receives page/event, device/browser and online identifier data and may process IP addresses in providing its service. Optional tracking is distinct from essential request delivery. Do not include health details, access/alarm codes, identification documents or other sensitive information in the general enquiry box. A separate secure process is needed for genuinely necessary sensitive information. The service is not directed to children; booking acceptance is limited to adults. ### Purposes and Legal Bases Information is used to respond to requested enquiries, quote, schedule and provide cleaning, reconcile bank transfers, manage recurring jobs, handle complaints and meet legal obligations. Where GDPR/UK GDPR applies, pre-contract steps and contract performance support necessary enquiry/service processing; legal obligation supports required records; legitimate interests may support proportionate security, administration and legal claims subject to balancing and objection rights. Optional analytics and advertising require the applicable consent/opt-out controls and are not conditions of service. Consent can be withdrawn prospectively without invalidating earlier lawful processing. Cleano has stated that customer enquiry information is used to train a model to improve enquiry responses. Model training is a separate purpose from answering a particular enquiry. The model/provider, datasets, lawful basis, meaningful choice, retention, transfers, safeguards and ability to honour deletion requests are not yet verified. The website does not obtain AI-training consent; submitting a form or accepting cookies does not authorise training. This unresolved practice is a release blocker, not a claim that training is compliant or that it has been stopped by these website changes. ### Recipients, Advertising and Transfers Enquiries pass to Cleano's n8n workflow and Google Sheets. Information necessary to perform cleaning may be provided to the assigned cleaners. Hosting, email, banks and other service providers receive information necessary for their functions; the exact inventory and contracts require verification. Regulators, professional advisers or dispute participants may receive information where lawful and necessary. Cleano reports storage/processing in Australia and the United States. Supabase is planned for a future CRM but is not represented as a current integration. Google Analytics is the existing optional analytics integration. Cleano intends to use Google Ads, Meta and remarketing, but the new consent manager does not install those tags. Whether existing off-site systems disclose data for advertising or train models has not been audited. No blanket statement that data is never sold/shared is made. Any sale/sharing or targeted advertising must first be mapped and supported by required notices, contracts and opt-out mechanisms. Where applicable, international transfers require a recognised lawful mechanism, provider agreements, transfer-risk review and supplementary safeguards, rather than a presumption that US storage is automatically lawful. Contact Cleano for information about applicable safeguards. Website access from another country does not by itself establish GDPR or CCPA applicability. ### Retention and Security The business's proposed minimisation target is 30 days for unconverted enquiries after the enquiry is closed. This is not a verified automated deletion process. Booking/service, financial, employment, dispute and legally required records need separate schedules. Australian tax records are generally retained for at least five years; employment records and other obligations may require longer. Records subject to a claim or legal hold are retained as required and then securely deleted or de-identified when no longer needed. Backup, email, workflow execution, Sheet and model copies must be included in deletion planning. Security controls have not been verified. This notice does not promise encryption at rest, MFA, access auditing, certifications or deletion from trained models. Appropriate access restriction, authentication, secure transport, backups, provider oversight and incident response are required operational work. No internet transmission or storage system is risk-free. Privacy incidents and suspected misuse can be reported through the contact above. ### Rights and Requests Depending on applicable law, you may request access, a copy/portability, correction, deletion, restriction, withdrawal of consent, or object to processing, including relevant direct marketing. California residents, where CCPA/CPRA applies, may also request disclosure of categories/specific pieces, sources, purposes and recipients; opt out of sale/sharing; limit qualifying sensitive-personal-information uses; correct information; and use an authorised agent. Cleano must not discriminate unlawfully for exercising rights. Email the request and enough information to locate the relevant record. Identity and authorised-agent verification must be proportionate; do not email identification documents or passwords unless a secure process is arranged. Legal retention exceptions may limit deletion and will be explained. Rights must be propagated to relevant processors where required, not just removed from the public website. Where applicable, GDPR requests are generally answered within one month, with a permitted extension of up to two further months for complexity/volume and notice within the first month. CCPA requests generally require acknowledgement within ten business days and a substantive response within 45 calendar days, subject to lawful extensions; sale/sharing opt-outs have separate, shorter requirements. The operational process and statutory exceptions must be verified. You may complain to the OAIC or another competent regulator, including a relevant EEA/UK supervisory authority or California regulator when their law applies. ### Cookies and Changes Use Cookie settings to change browser-level preferences. Global Privacy Control forces advertising off in this browser. The control cannot delete prior disclosures or change external AI, email or CRM processing. Material purpose changes require updated notice and, where necessary, a fresh lawful basis or consent before the new use. This draft has no effective date until approved. ## 3. Cookie Policy ### Essential Storage The consent manager stores `cleano-consent-v1` in this browser's local storage: policy version, save time and category choices. It treats the choice as expired after 180 days and asks again; local storage has no automatic browser expiry and the record may remain until overwritten or cleared. Rejection is saved on the same terms as acceptance. Hosting/security technologies needed to deliver a requested page require a verified inventory. Essential does not mean every business-useful technology is exempt from consent. ### Analytical Cookies GA4 (measurement ID `G-S8VRM9R8Z2`) is loaded only after Analytical consent. Common first-party GA4 cookies include `_ga` and `_ga_S8VRM9R8Z2`, identifying browsers/sessions; Google's typical default lifetime is up to two years, subject to configuration, refresh and browser restrictions. Actual collection and retention settings must be verified. Google receives visit and device information; the new loader disables Google signals and advertising personalisation signals regardless of Advertising preference. ### Performance and Advertising Performance covers optional diagnostic/experience-measurement tools separate from analytics; no separate tool is installed by this manager. Advertising covers ad measurement, retargeting and cross-site personalisation, such as planned Google Ads/Meta integrations. This manager installs no Ads or Meta tag, including when Advertising is accepted. Future tags must be classified, inventoried and technically gated before release. Category permission is not consent to unspecified future purposes or providers; material changes require renewed notice and choices. ### Choices and Withdrawal Accept All enables the offered optional category preferences, except Advertising under Global Privacy Control. Reject Non-Essential leaves every optional category off. Manage Preferences lets you choose Analytical, Performance and Advertising independently; Essential is always on. All three actions have equal visual prominence. Closing preferences without saving makes no change. The controls work without requiring a quote or account. Cookie settings is available persistently in the footer. Withdrawal saves the new choices, attempts to remove recognised first-party analytics/ad cookies accessible on this site and reloads the page to unload tracking scripts. It cannot remove third-party/HttpOnly cookies, undo earlier processing or erase server-side records. Browser settings can clear additional site data. Preferences are specific to this browser, device and origin, not a cross-device account choice. Storage-blocked browsers may be asked again, defaulting optional tracking off on a new page. No JavaScript means the new manager does not load optional tags. External booking tools, linked websites and third-party services have their own technologies; their behaviour must be checked separately. The consent manager does not control links once you leave this site. Google Fonts on the modern pages and Google Sites/Jotform resources on legacy pages need a separate third-party-request review. ## 4. Refund and Cancellation Policy ### Prices, Deposits and Cancellation A 50% bank-transfer deposit secures the slot, with 50% due on completion. Cancel by email to info@cleanoservices.com.au or telephone 0434 274 784, identifying the scheduled job. Notice is measured against the scheduled start in Sydney local time. Cancellation at least 24 hours before the start attracts no cancellation fee, and amounts prepaid for the cancelled work are refundable. Cancellation less than 24 hours before the start or a no-show may attract a fee of up to AUD 70, limited to reasonable unrecovered loss and reduced where costs are avoided or the slot is refilled. This is not an additional cleaning charge or a penalty. Any fee must have been disclosed before quote acceptance. Prepayments are credited against a lawful fee, with the balance refunded; the same loss is not charged twice. For recurring work, this applies only to the affected visit, not all future visits. Giving at least 24 hours' notice cancels the relevant recurring visit without that fee. Contact Cleano to confirm which future visits should stop. Rescheduling and inability to access a property should be discussed promptly; any charge must be agreed in advance, lawful and proportionate rather than implied from this draft. Cleano cannot charge a customer cancellation fee when Cleano cancels or fails to provide the booked service. Where Cleano cancels, the customer may choose a suitable alternative or refund of unprovided services. Statutory rights and exceptional circumstances must be considered. ### Refund Eligibility and Consumer Rights A completed service that met the agreed scope and consumer guarantees is not ordinarily refundable merely because the customer changes their mind. There is no blanket exclusion for completed work, deposits, consumed digital content or complaints made after a fixed deadline. No digital deliverables are currently part of the confirmed business model. Where a service fails a consumer guarantee, the available remedy depends on the nature of the failure and applicable law. A minor remediable failure may be corrected within a reasonable time; a major failure may support cancellation, refund for the affected/unprovided service and compensation for foreseeable loss. A seven-, fourteen- or thirty-day reporting window does not override those rights. Report concerns promptly so evidence can be assessed, but delay does not automatically extinguish a claim. This policy does not impose a re-clean as the only remedy for every failure. ### Request Procedure and Payment 1. Email or call with the name on the booking, scheduled service date, relevant issue, evidence reasonably available and requested remedy. Do not send sensitive bank credentials. 2. Cleano reviews the agreed scope, work performed, cancellation notice and consumer rights, and explains the proposed outcome and any reasonable information needed. 3. Approved refunds are processed by bank transfer within up to seven business days after approval and verification of payment details, or sooner where required by law. Bank processing may affect receipt. This is a processing timeframe, not a deadline to exercise statutory rights. 4. If unresolved, request further review or contact NSW Fair Trading, the appropriate tribunal/court or another competent authority. Keep the quote, terms, payment and correspondence records. Where applicable mandatory foreign withdrawal rights exist, they remain intact. The confirmed services target Australia; no generic EU 14-day withdrawal regime is represented as automatically applying to every Australian booking. Before entering an applicable EU/UK distance-services market, provide the required pre-contract information, cancellation instructions/form, and separate express request/acknowledgement for early performance where needed. ### Payment Disputes Bank transfer is the confirmed payment method, not a card checkout. Verify unexpected changes to bank details through a trusted contact. Contact Cleano promptly about an incorrect charge or suspected fraud, and contact the bank where appropriate. Customers are not required to waive statutory remedies, bank fraud processes or future lawful card-dispute rights. Cleano should provide accurate records, not penalise legitimate disputes or delay an owed refund to deter escalation. ## 5. Accessibility Statement Cleano aims to make its website and cleaning enquiries accessible to people with disabilities, using WCAG 2.1 Level AA as its target. This is not a certification of full conformance or a guarantee against discrimination claims. Testing is incomplete, including assistive-technology and legacy/external booking journeys. The modern site includes semantic page landmarks, image descriptions, a skip link, labelled enquiry fields and keyboard-operable navigation. The current changes add visible focus treatments, closed-menu keyboard isolation, accessible consent controls and clearer submission feedback. Automated and manual review must continue, including contrast, reflow, magnification and screen-reader testing. If you encounter a barrier, email info@cleanoservices.com.au or call 0434 274 784. Please describe the page, task, browser/assistive technology if comfortable, and a preferred way to respond. You do not need to disclose a diagnosis. Telephone or email enquiry is available as an alternative. Cleano should arrange a suitable communication method, investigate reported barriers and explain any available workaround and remediation plan. No unverified response-time commitment is made. The statement should be updated after material website changes and further testing. Third-party services may introduce barriers, but their presence does not remove Cleano's responsibility to assess an accessible service journey.