Effective date: 9 September 2026
1. Who we are
Humble Trail is operated by The Ordinary Trade Pty Ltd (we, us or our). This policy explains how we handle personal information in connection with humbletrail.com.au, including its articles, advertising, comments and communications with readers. Other websites operated by our company have their own notices unless expressly included here.
For privacy questions, requests or complaints, contact:
Privacy Officer — The Ordinary Trade Pty Ltd
Email: privacy@humbletrail.com.au
Post: 179 Maroondah Hwy, Ringwood VIC 3134, Australia
Where European or UK data protection law applies to our processing, we are a controller of the personal data we collect for our own purposes. Advertising partners may also act as independent controllers for their processing, as explained below.
This policy explains our practices. Reading the website or this policy does not, by itself, give consent to optional tracking or advertising use of your information.
2. Information we collect
Personal information includes information that identifies you or can reasonably be linked to you, your browser or device. An advertising identifier or hashed email address can still be personal information even though it does not display your name.
| Category | Examples and sources |
|---|---|
| Information you provide | Your name or chosen display name, email address, comment or message, and other information you choose to submit. A form may request a postcode or other information; required and optional fields are identified on that form. |
| Visitor and session identifiers | Identifiers assigned to your browser or browsing session, cookie identifiers, page-instance identifiers and advertising click identifiers. These are collected through our website and tracking tools. |
| Browsing and engagement | Pages and articles visited, referral URLs, visit times, time spent reading, active time, scroll depth, article order and interaction with website features. |
| Advertising and attribution | Ads requested, filled or viewable; campaign, ad-set and ad identifiers; URL parameters such as UTMs and Facebook click identifiers; and events used to measure advertising performance. |
| Device and network information | IP address, browser/user-agent information, viewport dimensions, device pixel ratio, timezone and approximate location or network information derived from your connection. This does not necessarily identify your precise location. |
| Identity-matching information | A transformed, hashed version of an email address provided through an enabled website feature, and identifiers used to connect advertising or engagement events. See section 4 for this separate use. |
| Request and compliance records | Correspondence about privacy, records used to verify a request, and records of how a request was resolved. |
We obtain information directly from you, automatically from your use of the website, and from providers that help operate, secure, measure or monetise the website. Providers may supply performance reports and device or advertising signals associated with your visit.
You do not need to submit a comment or subscribe to communications to read our articles. If you do not supply a required field for a requested feature, we may be unable to provide that feature or respond to your enquiry. Please do not include private information about other people or sensitive information in public comments.
3. How we use information
We use information to publish and operate the website, respond to readers, manage comments, protect our services, understand readership, measure advertising and improve our content and advertising performance.
The following identifies the legal basis where EU or UK data protection law requires one. A legitimate-interest basis does not remove a separate requirement to obtain consent for device storage or access.
| Purpose | Information involved | Legal basis where applicable |
|---|---|---|
| Deliver pages and maintain security | Network/device information and operational logs | Legitimate interests in operating a reliable website, preventing abuse and protecting readers; legal obligation where a specific obligation applies. |
| Respond to enquiries and manage comments | Submitted details, message/comment and relevant technical information | Legitimate interests in responding to readers and managing a public discussion. Where genuinely necessary to provide a service under a contract with you, performance of that contract. |
| Measure article engagement and advertising outcomes using our own technologies | Visitor/session IDs, browsing, engagement, attribution and technical information | Consent for non-exempt tracking and related consent-based processing. Any limited measurement relying on a different basis must be separately assessed and explained. |
| Deliver personalised advertising and share advertising events with Meta or advertising partners | Advertising identifiers, browsing/engagement events, technical information and eligible identity signals | Consent where required, together with applicable regional sale/sharing and targeted-advertising choices. |
| Use a submitted email for advertising identity matching | Hashed email and associated advertising identifiers/events | Specific, informed consent where required, separate from the purpose of posting a comment or sending a requested communication. |
| Send optional email updates, if you subscribe | Email address, preferences and subscription records | Consent or another basis expressly permitted for the particular communication under applicable law. |
| Handle rights requests, legal requirements and disputes | Relevant correspondence, verification and compliance records | Legal obligation; legitimate interests in establishing, exercising or defending legal claims where appropriate. |
4. Our advertising measurement and identity tools
Our measurement technologies
We use our own technologies, together with service providers, to measure readership, engagement and advertising performance. These technologies collect browsing, interaction, device and campaign information described in this policy. Records may be linked to a browser, visitor or session identifier.
We process this information through our service providers and reporting systems to understand and improve our content and advertising. We may share relevant events and identifiers with advertising partners, including Meta, for attribution and advertising optimisation, subject to applicable privacy requirements and choices.
Meta Pixel and Conversions API
Our configured Meta integrations can send page visits and advertising-engagement events from your browser or our servers. Depending on the event and your applicable choices, these can include the page URL, event time, browser and click identifiers, IP address, user agent, a transformed visitor identifier, and a hashed email address when available for an authorised matching purpose.
Server-side delivery is another way of sending an event; it does not remove applicable privacy choices. Meta processes information under its own terms and Privacy Policy.
Email matching
An enabled identity feature can transform an email address into a hash and provide that hash to Mediavine’s identity service or attach it to Meta advertising events. Partners can use matching identifiers to recognise or associate a browser with information they already hold. Hashing does not make the information anonymous.
Where an enabled comment or subscription feature supplies an email address to our identity tools, a hashed version may be used for the advertising matching described above. You can contact us to object to this use, withdraw any consent you have given, or request deletion where applicable. The legal requirements for this additional use apply separately from posting a comment or sending a requested communication.
Mediavine advertising
Humble Trail works with Mediavine to manage display advertising. Mediavine and its advertising partners may collect identifiers, device information and activity information to deliver and measure advertising, including personalised advertising where permitted. Their processing is explained in Mediavine’s Legal and Privacy Center and partner disclosures.
Mediavine Programmatic Advertising (Ver 1.1)
The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.
First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.
Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.
The Website collects the following data using a cookie when serving personalized ads:
- IP Address
- Operating System type
- Operating System version
- Device Type
- Language of the website
- Web browser type
- Email (in hashed form)
Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.
If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.
For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.
5. Cookies, browser storage and your choices
Cookies and similar technologies can store or access information on your device. Our technologies also use localStorage, which can persist between visits, and sessionStorage, which normally lasts for a browsing session/tab. These technologies are not all essential simply because they use our domain.
| Technology | Purpose | Browser storage duration |
|---|---|---|
| Our visitor identifier cookie | Recognise a returning browser and link measurement events | Our technology sets a 365-day expiry. Browser restrictions may shorten it. |
| Our session identifier in sessionStorage | Associate events within a browsing session | Browser session/tab lifetime. |
_fbp cookie |
Meta browser identification and event matching | Our technology sets a 90-day expiry when creating it. |
_fbc cookie |
Associate events with a Facebook ad click | Our technology sets a 90-day expiry when creating it. |
| Our email-matching hash and timestamp in localStorage | Store an email hash and timestamp for identity matching | No automatic expiry is set by this feature; the stored value can remain until it is removed or browser storage is cleared. |
| Mediavine, Meta and other provider technologies | Advertising delivery, preferences, measurement and matching | Durations vary by technology and provider. See Mediavine’s advertising disclosure and the relevant provider’s privacy information. |
These browser durations do not describe how long related server records are retained; see section 8.
Mediavine may present a consent notice or privacy control according to your region. Use the controls presented to manage the advertising permissions they cover. Mediavine’s controls do not necessarily manage Humble Trail’s separate measurement or Meta processing. You can also contact privacy@humbletrail.com.au to withdraw consent or exercise applicable privacy rights. Where the law requires consent for optional tracking, that consent is required separately from accepting these terms or reading this policy.
For visitors with applicable US rights, you can request Do Not Sell or Share My Personal Information and opt out of covered targeted advertising by contacting privacy@humbletrail.com.au. If a provider presents a corresponding opt-out control, you can also use it for the processing it covers. A provider or browser-level choice may apply only to that provider, browser or device. Contact us for help with an identifiable email-based record or our separate tracking.
Browser cookie settings can provide additional controls, but they do not replace applicable consent requirements or privacy requests and may not control server-side activity or every form of browser storage. Clearing storage can remove a saved preference. Global Privacy Control (GPC) communicates an opt-out preference and is distinct from the older Do Not Track signal. Applicable law may require a business to honour GPC; browser settings alone should not be assumed to stop all collection described in this policy.
6. Who receives information
We disclose information where needed for the purposes described above to:
- Technology providers supporting website hosting, content delivery, security, event collection, reporting and communications. Our event collection infrastructure uses Cloudflare.
- Mediavine and its advertising partners for their advertising services, and Meta for configured advertising measurement and matching.
- People reading public comments: your displayed name and submitted public content can be viewed, copied or indexed. Your submitted email is not intended to be displayed as part of a comment.
- Professional advisers, authorities and other parties when reasonably necessary to comply with law, address fraud or security incidents, or establish, exercise or defend legal claims.
- A prospective or actual successor in a business transaction, subject to appropriate confidentiality and data-protection arrangements. A transaction does not itself override your privacy rights or authorise unrelated new uses.
Some advertising disclosures can constitute a sale, sharing, or targeted advertising under US privacy laws even if no money is paid for a particular record. Applicable opt-outs are explained in sections 5 and 10.
Embedded videos, social features and external links may involve other providers. Their notices explain their independent processing; this does not remove our responsibility for our own collection or disclosures.
7. International processing
We are based in Australia. Our service and advertising providers may process information in other countries, including the United States.
Where Australian cross-border disclosure requirements apply, we take the steps required by those requirements in relation to overseas recipients. Where EU or UK restricted-transfer rules apply, the relevant transfer must have an applicable lawful safeguard. Merely continuing to use this website is not an agreement to waive those protections.
8. Retention and security
We retain personal information only for the period justified by its purpose and applicable requirements. Retention considers whether an enquiry remains open, whether a comment remains published, whether an identifier is still needed for an authorised purpose, and whether records are necessary for a legal obligation or claim. When no longer needed, information is deleted or genuinely anonymised, subject to applicable requirements.
We use appropriate technical and organisational safeguards for the information we hold. No online service can guarantee absolute security. If an incident creates a legal duty to notify affected people or a regulator, we will make the required notification.
9. Your requests and Australian privacy rights
Contact privacy@humbletrail.com.au to ask about our handling of your information, request access or correction, ask for deletion where available, or make a complaint. Explain the request and provide enough information for us to locate relevant records. Please do not initially send identity documents or sensitive information unless we explain why they are needed.
We may use proportionate verification to protect information from disclosure to the wrong person. We will not demand unrelated information. Some browser records may not be identifiable from your name alone; we will explain what additional information, if any, can reasonably help locate them.
We handle requests within the time required by applicable law and explain any lawful refusal or extension. We do not charge for submitting a request. Any legally permitted access charge will be explained before you incur it; no fee will be charged where applicable law requires a free response.
For complaints, we aim to acknowledge receipt promptly and provide a substantive response within 30 days, or explain any delay. This aim does not extend a shorter legal deadline. If you remain dissatisfied, you may contact the Office of the Australian Information Commissioner where it has jurisdiction. You do not need to give up other available remedies.
10. Additional rights in the EEA, UK and United States
EEA and UK
Where applicable, you can request access, correction, erasure, restriction and portability of your personal data. These rights have conditions and exceptions. You can withdraw consent at any time without affecting the lawfulness of earlier consent-based processing.
You may object to processing based on legitimate interests on grounds relating to your situation. You may object at any time to processing for direct marketing, including profiling related to that marketing.
We normally respond to GDPR rights requests within one month. Where the law permits an extension, we will tell you within the initial month and explain why. You may complain to your relevant EEA supervisory authority or the UK Information Commissioner’s Office, including without first completing our complaint process.
United States
Depending on where you live and whether the relevant law applies to our business and processing, rights may include knowing/accessing information, obtaining a portable copy, correcting inaccuracies, deleting information, opting out of sale/sharing or targeted advertising, and rights relating to sensitive data or qualifying automated decisions. We will not unlawfully discriminate against you for exercising a privacy right.
Use any applicable advertising opt-out control presented to you, or email privacy@humbletrail.com.au to make a request, including a request to opt out of sale, sharing or targeted advertising. An authorised agent may submit a request where permitted; reasonable evidence of authority and legally permitted verification may be required. Where your state provides a right to appeal our decision, email the same address with “Privacy appeal” and we will review the decision and explain the outcome and available escalation route within the applicable deadline.
11. Children, profiling and editorial information
Our services are intended for a general adult readership, not directed to children under 13. Please contact us if you believe we have collected a child’s information inappropriately so we can investigate and take appropriate action. A stated age restriction does not override protections applicable to older children or adolescents.
Our advertising tools use engagement and attribution signals to estimate visit value and help optimise advertising. Matching and advertising profiles are described in section 4.
Articles may refer to people, businesses and publicly available information. If you have a privacy concern about published content, email us with the article URL and explanation. We assess requests with regard to applicable law, freedom of expression and other relevant rights; an advertising opt-out does not itself remove editorial content.
12. Changes to this policy
We update this policy when our practices or relevant requirements change and revise the effective date. Where appropriate, we provide a prominent notice of material changes. If a new use requires consent, we obtain that consent before beginning the use. A revised policy does not retrospectively create permission for earlier processing.
