Privacy Policy

This Privacy Policy explains how Aquirian Limited and its subsidiaries (collectively, the “Aquirian Group”, “Aquirian”, “we”, “us” or “our”) collect, hold, use and disclose personal information.

We manage personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

“Personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is recorded in a material form or not.

This Privacy Policy applies to Aquirian Limited and each of its subsidiaries that adopts or refers to this Privacy Policy.

1. Privacy Protection

Aquirian Limited and its subsidiaries recognises the importance of privacy. We are committed to protecting the personal information of our clients, customers, suppliers, employees, applicants and website visitors.

In this Privacy Policy, references to “you” or “your” mean an individual whose personal information we collect, hold, use or disclose.

2. Collection of Personal Information

a. How we collect personal information

Aquirian Limited and its subsidiaries may collect personal information from you in several ways, including when:

• you communicate or interact with us electronically, by telephone, in writing or in person;
• you access or use a website operated by a member of the Aquirian Group;
• you enquire about, purchase or use our products or services;
• we provide products or services to you or to an organisation with which you are associated;
• you provide feedback or update your communication preferences;
• you apply for employment or another position with us; or
• you otherwise conduct business with us.

b. Purposes of collection

Aquirian Limited and its subsidiaries collects and holds personal information that is reasonably necessary for our functions and activities, including to:

• provide and administer our products and services;
• communicate with clients, customers, suppliers and other stakeholders;
• respond to enquiries, requests and complaints;
• process payments and administer accounts;
• develop, improve and promote our products and services;
• manage our business operations;
• assess employment applications;
• maintain the security of our systems and premises; and
• comply with our legal, regulatory and contractual obligations.

c. Types of personal information collected

The types of personal information we collect and hold depend on the nature of our relationship with you and the products or services you request. Personal information may include:

• information you provide when you contact us, make an enquiry or request a product or service, including your name, telephone number, residential or business address, email address, payment information and financial details;
• information about individuals that we collect while providing products or services to our clients or customers;
• information about your employment, occupation, employer or business activities;
• records of communications and correspondence between you and us;
• information provided through forms, applications, surveys or feedback processes; and
• other information reasonably necessary for our functions and activities.

d. Additional information

We may collect additional information at other times. This information may not constitute personal information where it does not identify you or make you reasonably identifiable.

This may include information collected when you:

• visit or interact with our websites;
• provide feedback;
• update your contact details or communication preferences; or
• apply for employment through one of our websites.

e. Websites, cookies and third-party links

When you visit a website operated by Aquirian Limited or one of its subsidiaries, we may collect information including:

• your Internet Protocol address;
• the date and time of your visit;
• the pages or sections of the website you access;
• your actions and interactions on the website;
• the website from which you accessed our website;
• your device and operating-system information; and
• the type of browser you use.

We may use this information to analyse how visitors use our websites, maintain website security, troubleshoot technical issues and improve our websites, products and services. Where appropriate, information may be aggregated or de-identified before it is analysed.

We may also use cookies and similar technologies on our websites. Cookies are small files stored on your device that allow a website to recognise your browser, remember certain preferences and collect information about your use of the website.

Cookies are not malicious programs and do not independently access or damage your device. Most browsers automatically accept cookies, but you can adjust your browser settings to reject or delete them. Disabling cookies may prevent you from using some features of our websites.

Our websites may contain links to websites operated by third parties that are not owned or controlled by the Aquirian Group. These links are provided for convenience only and do not constitute sponsorship, endorsement or approval of those third-party websites or their operators.

The Aquirian Group is not responsible for the content, security or privacy practices of third-party websites. We recommend reviewing the privacy policy of each third-party website you visit.

f. Information about third parties

Where practical, we will collect personal information directly from the individual to whom the information relates. However, we may also collect personal information about you from a third party.

We may require you to provide personal information about another person. Before providing us with another person’s personal information, you must ensure that:

• you are authorised to provide the information;
• the person has been informed that their personal information may be provided to us;
• the person has been informed about the purposes for which we may collect, use and disclose their information; and
• where appropriate, the person has been directed to this Privacy Policy.

Where we receive personal information about a third party from you, we may assume that you have complied with these requirements.

g. Anonymity and pseudonyms

Where practical and lawful, you may interact with us anonymously or by using a pseudonym.

However, in many circumstances it may not be practical for us to provide products or services without collecting information that identifies you. We may also be required or authorised by law to deal only with individuals who have identified themselves.

h. Consequences of not providing personal information

You are not required to provide us with personal information. However, if you do not provide the information we reasonably require, we may be unable to:

• respond to your enquiry;
• provide a requested product or service;
• process a payment or transaction;
• enter into or administer a contractual relationship with you;
• consider an employment application; or
• otherwise deal with you as requested.

3. Use and Disclosure of Personal Information

a. Primary purposes

Aquirian Limited and its subsidiaries may use and disclose personal information for the purposes for which it was collected, including to provide, administer and support our products and services.

We may also disclose personal information to other members of the Aquirian Group where reasonably necessary for our corporate, administrative and business purposes.

b. Related purposes and communications

We may use your personal information to:

• communicate with you;
• administer our relationship with you;
• inform you about new or additional products, services, information, updates and opportunities;
• improve our products, services and business processes;
• conduct research and analysis; and
• better understand the needs of our clients and customers.

Where required by law, we will obtain your consent before sending direct marketing communications. You may unsubscribe from marketing communications at any time by using the unsubscribe function included in the communication or by contacting us.

c. Legal and regulatory requirements

We may use or disclose your personal information where reasonably necessary to comply with a legal, regulatory or contractual requirement, including:

• in response to a court order, subpoena, warrant or other lawful request;
• during legal or regulatory proceedings;
• in response to a request from a law-enforcement or regulatory agency;
• where required or authorised by Australian law; or
• where necessary to establish, exercise or defend a legal claim.

d. Protection of rights and safety

We may use or disclose personal information where reasonably necessary to protect the legal rights, intellectual property, systems, property, health or safety of:

• Aquirian Limited and its subsidiaries or another member of the Aquirian Group;
• our employees, officers, clients or customers;
• members of the public; or
• another third party.

e. Service providers and advisers

We may disclose personal information to our:

• employees and officers;
• insurers and insurance brokers;
• professional advisers, including lawyers, accountants and auditors;
• agents and representatives;
• information-technology and cloud-service providers;
• payment and financial-service providers;
• suppliers and contractors;
• marketing and communication providers;
• recruitment and employment-service providers; and
• other service providers or subcontractors.

We will only disclose personal information to these parties to the extent reasonably necessary for them to provide services to us or perform functions on our behalf.

f. Outsourced services

We may outsource some of our business functions to external service providers. Personal information may be provided to those service providers where reasonably necessary for them to perform the relevant services.

g. Handling by third parties

Where appropriate, we take reasonable steps to require third parties that receive personal information from us to protect that information and handle it consistently with applicable privacy laws and their contractual obligations.

4. Security of Personal Information

a. Security measures

Aquirian Limited and its subsidiaries is committed to protecting the personal information we hold.

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These steps may include physical, electronic, technical and administrative security controls.

Our security measures may include:

• access controls and authentication measures;
• network and system security controls;
• secure storage arrangements;
• confidentiality obligations;
• staff awareness and training;
• monitoring and security reviews;
• data backup and recovery arrangements; and
• secure destruction or de-identification of information that is no longer required.

b. Electronic transmission

The transmission of information over the internet and through electronic communication systems carries inherent risks. While we take reasonable steps to protect information transmitted to and from us, we cannot guarantee the security of information during transmission.

Once personal information is received, we take reasonable steps to protect it in accordance with this Privacy Policy and applicable law.

c. Retention and disposal

We retain personal information for as long as reasonably necessary for our business functions and activities, or as required by law.

When personal information is no longer required for a permitted purpose, we will take reasonable steps to destroy it securely or permanently de-identify it, subject to applicable legal and record-keeping obligations.

5. Overseas Recipients of Personal Information

Aquirian Limited and its subsidiaries does not currently disclose personal information to recipients located outside Australia.

If our overseas-disclosure practices change, we will update this Privacy Policy to identify the countries in which overseas recipients are likely to be located, where it is practicable to do so.

6. Access to and Correction of Personal Information

a. Access requests

You may request access to personal information that we hold about you by contacting us at:

Email: admin@aquirian.com

We may require you to verify your identity before providing access.

We will respond to access requests within a reasonable period. We may charge a reasonable fee for costs associated with locating, retrieving and providing access to the requested information. We will notify you of any proposed fee before processing your request.

b. Refusal of access

We may refuse to provide access to personal information in circumstances permitted by the Privacy Act.

If we refuse an access request, we will provide written reasons for the refusal and information about available complaint mechanisms, unless it would be unreasonable or unlawful to do so.

c. Correction requests

You may ask us to correct personal information that you believe is inaccurate, out of date, incomplete, irrelevant or misleading.

Where appropriate, we will take reasonable steps to correct the information. If we refuse to make a requested correction, we will provide written reasons and information about available complaint mechanisms, unless it would be unreasonable or unlawful to do so.

7. Privacy Complaints

If you have a question or complaint about this Privacy Policy or our handling of personal information, please contact us at:

Email: admin@aquirian.com

Please provide sufficient information for us to understand and investigate your complaint.

We will acknowledge, review and respond to your complaint within a reasonable period after receiving it.

If you are dissatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner:

• Telephone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Website: www.oaic.gov.au

8. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes to our business operations, systems, legal obligations or privacy practices.

Any amended Privacy Policy will take effect when it is published on an Aquirian Group website or otherwise made available by us.

We recommend reviewing this Privacy Policy periodically to remain informed about how we manage personal information.