1.0 Introduction

In addition to respecting the privacy and security of your Personal Information, Dugan & CO PTY LTD ACN 613 036 016 and its affiliated companies (collectively referred to as “DUGAN & CO”, “us” or “we”) also comply with the requirements of the Australian Privacy Principles (“APP”) under the Privacy Act 1988 (Cth) and the New Zealand Information Privacy Principles (IPP) under the Privacy Act 2020 (collectively referred to as “the Act”).

The use of our websites, the use of our services, or the provision of your Personal Information to us (or authorizing someone else to provide it to us) constitutes your agreement to the collection and use of your Personal Information.

2.0 What Personal Information do we collect and hold?

Personal Information is defined under the Act as information or opinions about an identifiable individual, or an individual who can reasonably be identified, in whatever form and regardless of whether they are true. Besides health records, racial or ethnic origin, religious beliefs, and criminal records, the Act also defines sensitive information as Personal Information.

As part of our service provision, we may also collect and hold sensitive information such as health and criminal records. You consent to the collection and handling of any sensitive information you provide us with in accordance with this Privacy Policy if you provide it to us.

3.0 How we collect Personal Information

In the course of dealing with us over the telephone, sending us correspondence (whether by letter, fax or email), visiting our websites or completing hard copy or online forms, we may collect Personal Information about you directly.

However you acknowledge that, by agreeing to the disclosure of your Personal Information to these entities outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with the Act in relation to your Personal Information and we will not be liable to you for any breach of the Act by these overseas recipients. On this basis, you consent to such disclosure.

7.0 Access, update and correction of Personal Information

Although we take reasonable steps to ensure that the Personal Information we hold about you is accurate, complete, and up-to-date, you are also responsible for informing us of any changes to your Personal Information. It is your responsibility to ensure that your Personal Information is accurate, complete, relevant, and up-to-date if you are able to access it by logging on to an account you have with us.

You can request access to your Personal Information, including to correct or update that information, unless otherwise required or permitted by law.

There is no charge for making the request or giving the access to your Personal Information. We will deal with your request within a reasonable period after the request is made.

Upon refusal of access, we will provide you with a written notice outlining the reasons for the refusal and the complaint mechanisms.

If you wish to access the Personal Information we hold about you or to update or correct it, you can either log on to your account (if you have one) or contact us by using [email protected] or the contact details provided below. Upon submitting your request, you will need to verify your identity and specify what information you need.

8.0 Security of Personal Information

We take reasonable steps to protect any Personal Information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. As an example, we use IT security procedures such as password protection, firewalls, and site monitoring to protect your Personal Information.

It is, however, impossible to guarantee the security of your Personal Information despite the measures we have taken. In the event that you become aware of any security breaches, you should inform us as soon as possible. You should take care to protect your Personal Information (for example, by protecting any usernames and passwords). Under the Act, we follow the Notifiable Data Breaches (NDB) Scheme when a data breach is likely to cause serious harm to an individual.

9.0 Direct Marketing

The choice is yours when you register as a member on our website whether you wish to receive newsletters, announcements, and e-mails about our latest news, products, or services, as well as e-mail communications. In cases where local law requires us to obtain your consent, we will only send you such messages if you opt-in. Please contact our Privacy Officer using the channels prescribed below if you do not wish to receive direct marketing calls or materials. In addition, if you are a registered member, you can change your choice at any time by accessing your registered account. We will stop using your Personal Information for direct marketing if you request it.

10.0 Privacy on our websites

We may include links to other entities’ websites. When you click on these links, you will be transferred to the websites of these entities. We are not responsible for the privacy practices of these entities. If you visit these entities’ websites, you should read their privacy policies to find out how they handle your Personal Information.

11.0 What if you have a complaint?

Please provide us with sufficient details regarding your complaint and any supporting evidence if you wish to make a complaint about a breach of this Privacy Policy or the Act.

The Privacy Officer will investigate the issue and determine the steps we will take to resolve your complaint. We will contact you if any additional information is needed and notify you in writing when the investigation is complete.

Alternatively, you can contact the Australian Privacy Commissioner via www.oaic.gov.au if you are not satisfied with our determination.

12.0 Privacy & Site changes

You are deemed to have accepted this revised Privacy Policy if you continue to use our websites or services, request our assistance, or provide us with further Personal Information after this Privacy Policy has been revised.

13.0 Our contact details

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details:

14.0 More information

For more information about the Act in Australia and protecting your privacy, visit the www.privacy.gov.au (external link) website.