Effective Date: 1 July 2026
We recognise the importance of protecting the privacy of information collected about visitors to our sites, in particular information that is capable of identifying an individual (“personal information”). This Internet Privacy Policy governs the manner in which your personal information, obtained through the website, will be dealt with. This Privacy Policy should be reviewed periodically so that you are updated on any changes.
Your personal information
Personal information about visitors to our sites is collected only when knowingly and voluntarily submitted. For example, we may need to collect such information to provide you with further services or to answer or forward any requests or enquiries. It is our intention that this policy will protect your personal information from being dealt with in any way that is inconsistent with applicable privacy laws in Australia.
How we collect personal information
In the course of providing our services, we collect personal information in a variety of ways. For example, information is collected when:
- We collect identification and other personal information from you, and where permitted by law from third parties, to verify your identity and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
- You ask to be placed on one of our mailing lists
- You apply for a job with us
- You make an enquiry about our services
- You visit our website
- You become a client or debtor of the company
- You provide personal information directly to us for a specific purpose.
How we use the information we collect
Personal information that visitors submit to our sites is used only for the purpose for which it is submitted unless we disclose other uses in this Internet Privacy Policy, or at the time of collection. Copies of correspondence sent from the web site, that may contain personal information, are stored as archives for record-keeping and back-up purposes only. You should be aware that we may use your email address to contact you in the future.
We do not sell your information. We may collect, use and verify your personal information to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”). This may include verifying your identity, assessing and managing money laundering, terrorism financing and other financial crime risks, conducting customer due diligence, ongoing monitoring of business relationships and transactions, and maintaining records as required by law.
Anti-Money Laundering and Counter-Terrorism Financing
As part of providing our services, we may be required by law to collect and verify your identity and other personal information. This may include collecting identification documents such as a driver’s licence, passport or other government-issued identification, as well as information relating to the source of funds or source of wealth where required.
We may also conduct electronic identity verification using trusted third-party providers.
Where required by law, we may retain records of this information for the period prescribed under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), even if you cease to be our client.
In some circumstances, we may be prohibited by law from notifying you that information has been collected, used, disclosed or reported to the relevant authorities under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Use of the information for a secondary purpose
We may sometimes use the personal information we collect for a secondary purpose, that is, for use in a way different from the original reason for collection.
We will only do this in the following circumstances:
- where you have consented.
- where the secondary purpose is directly related to the primary purpose, and you would reasonably expect us to use or disclose the information in such a way, or
- where we are permitted or required by law, or it is in the interests of public safety to do so.
Correcting information
You may request access to, or correction of, your personal information. We will take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. In some circumstances, we may be unable to delete personal information where we are required by law to retain it, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
Disclosure
We may disclose your personal information where required or authorised by law. This may include disclosure to government agencies, regulators (including AUSTRAC), law enforcement bodies, identity verification providers, financial institutions and other third-party service providers where necessary to comply with our legal obligations.
We do not sell your personal information to third parties.
Security
We strive to ensure the security, integrity and privacy of personal information submitted to our site. We take reasonable steps to protect personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure. However, we will endeavour to take all reasonable steps to protect the personal information you may transmit to us or from our online products and services. Once we do receive your transmission, we will also make our best efforts to ensure its security on our systems. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us. However, we will not be held responsible for events arising from unauthorised access to your personal information.
Links to other sites
We provide links to Websites outside of our website, as well as to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that websites and its privacy statement.
Further privacy information
For more information about privacy, visit the Office of the Australian Information Commissioner (OAIC) website. Information about Australia’s anti-money laundering laws is available from AUSTRAC.