Privacy Policy

Last updated: 23 August 2026

Bitstream Media (David Fabri, ABN 30 217 394 498) (“we”, “us”, “our”) respects your privacy. This policy explains how we handle your personal information, consistent with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

It covers this website, our web and software work for clients, our macOS software, CoMotionPlay, and GiftGambit. GiftGambit and CoMotionPlay each get their own section below, because a policy written in generalities would not tell you what either of them actually does. GiftGambit redirects here on purpose: there is one copy of this policy and this is it.

What we collect

Depending on how you interact with us, we may collect:

Contact and identity details — name, email, phone, business name.
Order and transaction details — what you purchased and related correspondence. Card payments are processed by our payment providers (Square for the online store, and Stripe for CoMotionPlay licences and GiftGambit); we don’t store full card numbers.
Project information — content, access credentials and materials you provide for web or software work.
Site usage data — IP address, device and browser information, and analytics about how you use the Site, collected via cookies and similar technologies (see our Cookie Policy). That Cookie Policy is about this website; GiftGambit runs its own cookieless analytics, described in its section below.

CoMotionPlay and camera input

CoMotionPlay is software for live events that reads a camera pointed at an audience in order to
measure how the crowd as a whole is moving. Because that involves a camera and an audience, we want to
be direct about what it does and does not do.

It does not identify individuals. There is no facial recognition, no biometric
matching, and no attempt to determine who anyone is.
What it derives is aggregate. The software measures how much of the frame is
changing, or how the overall shape of the room compares with a captured empty-room reference. It does
not track, count or follow individual people.
Video stays on the operator’s machine. The software runs locally. Video is
processed in real time on that machine and is not uploaded to Bitstream Media or to anyone else. We do
not receive, store or have access to it.
We do not receive audience data. Nothing about the people in the room reaches us.

If you are running an event, note that filming or recording your audience may carry obligations of
your own — signage, notice on tickets, venue policy, or the rules of the space you are in. Those
are yours to meet. We are describing what our software does; we are not giving legal advice about your
event.

GiftGambit

GiftGambit is our gift-list and gift-registry app, at giftgambit.com. It
holds more personal information than anything else we make, and much of it is about people other than the
person who typed it in. So it gets its own section, and this is the whole picture.

What we hold

Your account — email address, display name, and if you want them a photo or a chosen
avatar and a birthday. A birthday can be given without the year, and the year stays hidden unless you say
otherwise. You sign in by magic link, password or passkey. A magic-link request records the IP address and
browser it came from, so we can tell a real sign-in from an attack on your account.
Profile details, if you fill them in — clothing and shoe sizes, favourite colours and
brands, interests, things to steer clear of (people often use this for allergies), and a postal address for
thank-you cards. All optional. The address is only ever shown to someone you have actually given a gift to.
Lists and gift ideas — titles, notes, prices, links and pictures, on your own list and
on lists you keep for other people.
Claims — who is getting what, for whom.
Circles — which people share lists with which other people, and family links (partner,
mum, dad) if you set them.
Events — birthdays, Christmas, a wedding, a name draw or a gift swap.
Chat — messages between circle members about a gift.
Registries — the public page you build, and the postal addresses it collects.
Notification settings, and a push subscription if you turn push notifications on.
Bank or PayID details, if you organise a group cash gift. These are encrypted in our
database and deleted once the collection is over. It is the only phone number the app ever stores.
Payment records — see below.

Lists kept for people who have no account

Some of the people in GiftGambit never signed up and never will. A child or an elderly parent can be a
managed member, created and looked after by an adult. A pet can be a member. And a
private list can be kept for someone who is in no circle at all and is never told the list
exists — which is the honest shape of buying presents for somebody who doesn’t use the app.

We want to be straightforward about that: we hold information about people who did not give it to us. So we
hold as little as a gift needs, the adult who entered it controls it and can delete it at any time, and a
private list is built so that its subject can never have an account attached to it — not as a setting,
but as a rule the database enforces. Nothing can put that list in front of the person it is about.

Claims stay secret. That is the promise, not a feature.

When you claim a gift for someone, they do not see it. Not in the app, not in an email, not in a
notification, not in a total or a count. It stays hidden until the event is finished and whoever runs the
circle reveals it. Chat about a gift is never shown to the person the gift is for.

This is the thing GiftGambit exists to do, and we treat any failure of it as a serious incident rather than
a cosmetic bug. Registries are the deliberate exception, and they say so on the page: a couple checking what
has been bought for their wedding is the normal use of a registry, not a spoiled surprise.

Registries are public pages

A published registry is a public web page. Anyone with the address can read it — no account, no sign-in, no invitation. That includes the names of the people it is for, your headline and message, and the gifts on it with their descriptions, sizes and prices. Registries are not listed in search engines — the address you hand out is the only way in. Please treat it like anything else you put on the open web.

What the public page does not show is who has claimed what. Visitors see only how many of each gift are still needed — never a claimer’s name, and never a guest’s. Those names are recorded for the people the registry is for, so they can write thank-you notes, and are shown to them alone.

Two things soften that. A registry’s postal address is shown only to guests who have actually claimed
something, unless you change it. And you pick a date on which every address the registry holds — yours
and your guests’ — is deleted. Deleted, not hidden: there is no copy and we cannot bring it back
from a support ticket, which is the point of promising it.

Guest claims

Somebody with a share link can claim a gift by giving a name, and nothing else. No account, no email, no
password. If they choose to leave an email address so they can be thanked, we delete it a year later, or on the
registry’s expiry date if one has been set.

The name stays. It is the recipient’s record of who gave them what, and replacing it with
“a guest” would damage their record rather than protect the giver’s privacy. A guest is
recognised on later visits by a random token kept in their own browser; it identifies a browser, not a person,
and once the email is gone it points at nobody.

Children and managed profiles

You must be 18 to create a GiftGambit account.
Children appear as managed profiles, created and controlled by an adult member. A managed
profile cannot sign in: it has no email address and no usable password.
What we hold about a child is what a gift needs — a name, and optionally a birthday, sizes, interests,
things to avoid, and a photo or avatar the adult chose or uploaded.
The adult who created the profile can change or delete it at any time, and deleting it removes the
photograph from our storage as well as the record.
If you believe a child’s information is on GiftGambit and should not be, email us and we will remove
it.

Payments

Payments go through Stripe. We never see or store card numbers. What we keep is what Stripe tells us: which
plan you are on, when it renews, the amount, and an invoice record. Financial records outlive an account
deletion because we are required to keep them — see below.

The GiftGambit browser extension

The extension does one thing: it adds a product you are looking at to a GiftGambit wishlist.

What it reads. The title, image and price of the page you are on — and only when you
click its button or use its right-click menu. It cannot read pages in the background. It has no access to your
browsing history, your other tabs, or any page you have not asked it about.
Where that goes. To GiftGambit, to become an item on a list. Nowhere else. If the page
cannot be read in the browser, the extension can send the page address to GiftGambit so our own server can try
to fetch it instead.
What it stores. An access token for your own GiftGambit account, in the browser’s own
extension storage. The app hands it over when you click Connect, so there is no secret for you to copy and paste
anywhere. You can revoke it at any time in My Account → API tokens, and the extension
forgets it the moment it stops working.
What it displays. To ask who the gift is for, it fetches the names of people in your own
circles from your account. That is held in the popup while it is open and is not stored or sent anywhere else.
What it does not do. It contains no analytics, no tracking and no advertising. It talks to no server other than GiftGambit. We do not sell any of this data, we do not use it for any purpose other than adding items to your list, and we do not use it for creditworthiness or lending. It contains no remote code: everything it runs ships inside the package.

Limited Use. GiftGambit’s use of information received from the extension, and from any Google API, adheres to the Chrome Web Store User Data Policy, including the Limited Use requirements. Data the extension collects is used solely for its single purpose — adding products you choose to a wishlist in your own GiftGambit account. It is not transferred to anyone except as needed to provide that feature, not sold, not used for advertising or any personalised or retargeted purpose, and not used to determine creditworthiness or for lending. If our handling of extension data ever changes, we will say so here and tell users in the extension before the change takes effect.

Analytics

GiftGambit uses Matomo, which we host ourselves on our own hardware in Australia. Cookies are switched off in
it, so it puts no analytics cookie on your device and there is nothing to consent to. It records which page was
viewed, and a short list of feature events — the dice was rolled, the timer was used, a list was reordered
— with no names, no item titles and nothing about a particular person. The numbers never leave our own
infrastructure and never reach an advertising company.

Cookies in the app

The app sets a sign-in session cookie and a security token. Those keep you signed in; without them it cannot
work. Guest claiming uses a random value stored in your own browser rather than a cookie.

When something breaks

If the app fails in your browser it sends us the error message, the technical stack trace, the address of the
page you were on, and your browser version. That goes to our own logs and an email to us — not to any
third-party error-reporting service. Some page addresses contain a registry address or an internal id, so we
treat these reports as personal information.

Generated pictures

If you ask GiftGambit to generate an avatar or an event banner, the description you type is sent to Replicate
(United States), which runs the image model. Nothing about your account, your lists or your circles goes with it.
Nothing requires it: there are 120 built-in avatars and you can upload your own picture instead.

Where it lives, and who else touches it

GiftGambit runs on servers we control in Australia. Your lists, claims, circles, chat, registries and
analytics stay there. The services that necessarily see some part of it are:

Stripe — payments. Card details go to them, not to us.
Google Workspace — the mail relay that delivers GiftGambit’s email, so your
address and the contents of those messages pass through it.
Cloudflare — sits in front of the app and carries the traffic to it.
Replicate — only when you generate a picture, and only the description you typed.
Your browser’s push service (Google, Apple or Mozilla, depending on your device)
— only if you turn push notifications on, and only to deliver them.

What we never do

This is unusual enough in this category that we would rather say it than leave it implied.

No affiliate links. We take no commission on anything bought through GiftGambit, from any
retailer.
No sponsored placements. Nothing appears on a list, a search or a suggestion because
somebody paid for it to be there.
No cut of what you are given, on any tier, including registries.
We do not sell personal information, and we do not share it with advertisers or data
brokers. Not on the free tier, not on Pro, not ever.

Every other product in this category is funded by retailers. We are funded by the people who pay for Pro.
That is the whole reason Pro costs money.

Deleting your account, and what survives

You can delete your GiftGambit account yourself, immediately, in My Account → Delete
account. You do not have to email us and we do not ask you why.

What deletion removes:

Your account, your profile and everything on it, your password, your passkeys and your API tokens.
Your uploaded profile photograph, off our storage — not just the link to it.
The profile photograph of any pet whose only remaining manager was you, and pictures generated under your
account that nothing else is using.
Your link to every circle you were in, and your email address in those circles.

It also cancels any live subscription first. If we cannot cancel it, we do not delete anything and we tell
you so — a deleted account that is still being charged is worse than one that would not delete.

What survives, and why:

Your place in each circle, unlinked and inactive. Other people’s claims, name draws
and gift history hang off it. Removing it would destroy their records, not yours.
Gifts other people recorded giving or receiving, including claims made on your list and any
receipt attached to one. A receipt belongs to the gift, and the person who received it may still need it to
exchange something.
Wishlist items and their pictures on that unlinked row, so that other people’s claims
still make sense rather than pointing at nothing.
Messages you wrote in a circle chat, in the conversation they belong to.
Financial records — invoices and purchases, and the email address they were billed to.
We are required to keep those and they have to reconcile against Stripe.

Things that delete themselves, without anyone asking:

Guest email addresses after a year, or on a registry’s chosen expiry date.
Every postal address a registry holds, on the date its creator picked.
Bank and PayID details for a group cash gift, thirty days after the collection closes.
Read notifications after 90 days, and all notifications after 180.
Used and expired sign-in links after 7 days.
The edit history behind lists, circles and claims after a year.

Guest names are deliberately not deleted. They are the recipient’s record of who gave them a gift.

Seeing and correcting your GiftGambit information

Most of it you can see and change yourself in the app: your profile, your lists, your claims, your circles and your notification settings.

You can also download a copy of your data from My Account — your account and profile, the circles you belong to, your own lists, the gifts you claimed for other people, your messages and your payment records. We build it and email you a link. Gifts other people have claimed for you appear once the event has been revealed, so that asking for an export can never be a way to spoil a surprise, and other members’ personal details are theirs rather than yours and are not included.

Thank-you ledgers and registry address lists download as a spreadsheet. If something you expected is missing, email [email protected] and we will get it to you.

How we collect it

We collect personal information directly from you (when you contact us, place an order, or engage us for a project), and automatically through the Site and analytics tools. Occasionally we may receive information from third parties such as our payment or analytics providers.

Why we use it

We use personal information to:

provide and support our products and services, and process orders and payments;
communicate with you about your orders, projects and enquiries;
improve our Site, products and services;
send you marketing communications where you’ve agreed to receive them (you can opt out at any time — see below); and
meet our legal and regulatory obligations.

Disclosure

We disclose personal information only as needed to run our business — for example to service providers who help us operate (payment processing, hosting, analytics, email), and where required or authorised by law. We don’t sell your personal information, and we don’t share it with advertisers or data brokers.

Overseas disclosure

Some of our service providers store or process information outside Australia. The ones that matter, and what reaches them:

Stripe — payment details and billing records, for anything you buy from us.
Square — payment details for the online store.
Google Workspace — our email, including messages we send you and messages you send us.
Cloudflare — carries traffic to our sites and to GiftGambit.
Replicate (United States) — the description you type when you ask GiftGambit to generate a picture, and nothing else.

Where this occurs we take reasonable steps to ensure your information is handled consistently with the APPs. GiftGambit itself — the lists, claims, circles, chat, registries and analytics — runs on servers we control in Australia.

Marketing and the Spam Act

We only send marketing emails where you’ve consented, and every marketing message includes an unsubscribe option. You can opt out at any time by using that link or by contacting us.

Security

We take reasonable steps to protect personal information from misuse, loss, and unauthorised access or disclosure. Traffic is encrypted in transit, bank and PayID details are encrypted in the database, and we delete personal information on a schedule once its purpose has run out rather than keeping it indefinitely.

No system is completely secure. If a data breach happens that is likely to cause you serious harm, we will tell you and notify the Office of the Australian Information Commissioner, in line with the Notifiable Data Breaches scheme.

The Australian Privacy Principles

We handle personal information in line with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy
Principles. Here is where each of them lands for us.

Open and transparent management. This policy, kept current on this page and linked from every
product we run.
Anonymity and pseudonymity. You can read a shared GiftGambit list or claim a gift on a
registry as a guest, giving only a name — no account, no email. Your display name does not have to be your
real name. Some things genuinely need to identify you: paying, signing in, and being a member of a circle.
Collection of solicited information. We collect what a product needs in order to work, and
no more. Birthdays, photographs, sizes and postal addresses are all optional.
Unsolicited information. If we receive personal information we did not ask for and do not
need, we delete it.
Notification of collection. This policy is that notice. Where information is entered about
somebody who is not in front of us — a managed member, a pet, a private list — the adult who entered
it is the person who knows about it, and the GiftGambit section says so plainly.
Use and disclosure. We use personal information for the purpose it was given for, and
disclose it only as set out under Disclosure above. We do not sell it.
Direct marketing. Marketing email only where you have consented, always with an unsubscribe
link. GiftGambit’s own notifications are about your circles and events, and every one of them can be turned
off individually.
Cross-border disclosure. Set out under Overseas disclosure above, with each provider
named.
Government identifiers. We do not collect or use them. No tax file numbers, no Medicare
numbers, no driver licence numbers.
Quality of personal information. You can correct your own details in the app or by emailing
us, and we would rather you did than leave something wrong.
Security. See Security above. This principle also requires destroying information once it is
no longer needed, which is what the scheduled deletions described in the GiftGambit section are for.
Access. Ask and we will give you what we hold. Most GiftGambit information you can already see for yourself in the app, and you can download a copy of it from My Account without asking us at all.
Correction. Ask and we will fix it.

Access, correction and complaints

You can ask to access or correct the personal information we hold about you by emailing [email protected]. We’ll respond within a reasonable time, and we don’t charge for it. If we can’t give you something — because it would reveal someone else’s information, for instance, which in a shared gift app it sometimes would — we’ll tell you why.

GiftGambit members can see and change most of it directly in the app, and can delete the whole account without asking us.

If you have a privacy complaint, please contact us first so we can try to resolve it. If you’re not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by phone on 1300 363 992.

Changes

We may update this policy from time to time. The current version is always on this page, with the “Last updated” date revised accordingly.

Contact

Bitstream Media — [email protected]
Suite 58, Shop 13 Level 3, 200 Gilchrist Dr, Campbelltown NSW 2560