Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from [client-site] (the “Site”).

PERSONAL INFORMATION WE COLLECT
We collect personal information to effectively operate our business, provide our services, and meet our legal and contractual obligations. We limit the collection of information to what is directly necessary and relevant for these defined purposes.

a) Information Collected Automatically (Usage Data)
When you access or interact with our website, we automatically collect certain electronic data concerning your interaction. This data may include:

• IP Address and Location Data: Internet protocol addresses and general geographical location information.
• Device and Browser Information: Details about the device (e.g., operating system) and browser you use.
• Website Activity: Information regarding the pages you access, content you view, and the referring website or source.
• Clickstream Data: Data related to your browsing behavior and patterns on our website.

b) Information You Voluntarily Provide (Directly Collected Data)
We collect personal information that you provide to us directly when engaging our services, completing forms, or communicating with us. This may include:

• Identifiers and Demographics: Your first and last name, date of birth, and gender.
• Contact Information: Email address, telephone number, and residential/business or mailing address.
• Financial Details: Payment information necessary for processing transactions, which may be linked to your current billing address.
• Service-Related Information: Any personal information, documentation, or details provided by you relating to your inquiry or service request (e.g., information pertinent to an investigation or legal matter).

c) Information Received from Third Parties
In the course of providing our services, we may lawfully obtain personal information about you from various external sources, including:

• Service Engagers: Legal professionals or clients who engage us to perform services related to you.
• Public and Open Sources: Public records, commercially available databases, and information accessible through open-source platforms.
• Governmental Agencies: Information provided by government entities and regulatory authorities, where such disclosure is legally required or permitted.
• Operational Partners: Licensed investigators, subcontractors, or third-party service providers who assist in our business operations.

HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the collected information for specific, legitimate business purposes, primarily to fulfill our contractual obligations and support our core business activities.

The purposes for which we process your information include:

• Service Delivery: To provide, operate, and manage the specific services requested, such as debt collection, skip tracing, field calls and process serving as well as related consulting.
• Account Management: For the administration of client accounts, maintenance of service records, and management of our business relationship with you.
• Financial Processing: To process payments, issue invoices, and manage billing for services rendered.
• Communication: To respond to your inquiries, address complaints, and provide necessary updates regarding our services.
• Legal Compliance: To ensure adherence to relevant legal and regulatory requirements, including financial record keeping and reporting obligations.
• Business Improvement: For conducting internal analytics, market research, and testing to continually evaluate and enhance our service offerings and operational efficiency.
• Marketing: For communicating promotional materials or information about our services, strictly where you have provided consent or where we have a legitimate basis to do so (e.g., existing clients).
• Protection of Rights: To protect our legal rights, enforce our terms and conditions, and prevent fraudulent, illegal, or harmful activity.

We will not use your personal information for purposes materially unrelated to those outlined above without first obtaining your explicit consent.

DISCLOSURE AND SHARING OF PERSONAL INFORMATION
We disclose personal information only when necessary to fulfill our service obligations, operate our business, or comply with legal requirements. We commit to transparency regarding how your data is shared.

Recipients of Disclosure
We may disclose your personal information to the following categories of recipients:

• Clients and Engagers: The specific legal professionals, businesses, or clients who have engaged our services (e.g., investigations, skip tracing) relating to your information.
• Operational Personnel and Partners: Our internal staff, licensed investigators, contractors, and subcontractors who require access to the information to perform their duties. All such personnel are bound by strict contractual and statutory confidentiality obligations.
• Legal and Regulatory Authorities: Government bodies, regulatory authorities, or law enforcement agencies, but only when we are legally compelled or authorised to do so by a warrant, court order, or similar legal requirement.
• Judicial and Legal Venues: Courts, tribunals, or other parties involved in legal proceedings where disclosure is required to defend or enforce our legal rights, or as mandated by law.
• Professional Services: External professional advisors (such as auditors, legal counsel, or accountants) and third-party service providers (such as hosting, cloud infrastructure, and data analytics providers) who support our business operations and are under appropriate data processing agreements.

Commitment to Non-Sale of Data
We do not sell, rent, trade, or otherwise monetise your personal information to any third parties under any circumstances.

COOKIES AND WEBSITE ANALYTICS
Our website (the “Site”) utilses cookies and similar tracking technologies to gather limited data on website usage and enhance your user experience. Cookies are small text files placed on your device.

Categories of Cookies We Use:

Your Cookie Choices
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note that disabling cookies may affect the functionality and features available on our Site.

DATA RETENTION POLICY
We retain your personal information only for as long as is strictly necessary to fulfill the purposes for which it was collected, including for the purpose of satisfying any legal, accounting, or reporting requirements.

• Retention Period: We maintain personal information for a minimum period of five (5) years following the completion of the services, or for a longer period if mandated by law (e.g., specific contractual or regulatory obligations).
• Secure Disposal: When the personal information is no longer required for any legitimate purpose, we ensure it is either securely destroyed or permanently de-identified so it can no longer be associated with you.

SECURITY OF YOUR PERSONAL INFORMATION
We are committed to protecting the personal information we hold against loss, misuse, unauthoriSed access, or disclosure. We apply a strict range of technical and organisational security measures, including:

• Encryption: Utilising industry-standard encryption protocols for data both in transit (e.g., via SSL/TLS) and at rest (stored data).

• Access Controls: Implementing strong authentication, role-based access controls, and least-privilege principles to ensure data is only accessed by authorised personnel.

• Confidentiality: Enforcing strict confidentiality agreements and training for all staff, contractors, and subcontractors.

• Secure Environments: Utilising secure infrastructure and reliable cloud environments with advanced security features.

• Monitoring and Auditing: Conducting regular security audits, risk assessments, and vulnerability scanning.

• Incident Response: Maintaining defined incident response protocols to rapidly address and manage potential security breaches.

While we maintain best-practice protections consistent with our legal obligations, no system of data transmission or storage can be guaranteed to be 100% secure. Accordingly, we cannot guarantee the absolute security of information.

USER RESPONSIBILITIES FOR DATA SECURITY
While we maintain robust security measures, your vigilance is also crucial in safeguarding your personal information. You have a responsibility to:

• Protect Credentials: Maintain the confidentiality of your login details, passwords, and access credentials for any services we provide.
• Exercise Caution: Avoid disclosing sensitive personal information to unauthorised third parties and exercise due care when sharing information online or via unsecured channels.

We are not responsible for the security or protection of information that you voluntarily disclose to parties outside of our direct control.

ACCESS, CORRECTION, AND DELETION RIGHTS
You have the right to request access to and correction of the personal information we hold about you. You may also be entitled to request the deletion of your personal data or withdraw consent where consent forms the legal basis for processing.

Your Rights Include:

• Right of Access: To request a copy of the personal information we hold about you.
• Right to Correction: To request the correction of any information you believe is inaccurate, incomplete, or outdated.
• Right to Deletion (Erasure): To request the deletion of your personal data, subject to certain legal limitations (e.g., we may be required to retain data for legal compliance).
• Right to Withdraw Consent: To withdraw consent to the processing of your personal information where processing is based on your consent.

Making a Request:
Please direct all requests regarding your personal information to:

We will acknowledge and respond to all access and correction requests within 30 days of receipt, subject to any legal exceptions or requirements.

DATA BREACH NOTIFICATION PROTOCOL
In the unlikely event of a data breach that is likely to result in serious harm to any affected individuals, we will adhere strictly to our data breach response protocols and our legal obligations under the Notifiable Data Breaches (NDB) scheme in Australia.

Our protocol involves:

• Investigation and Assessment: Immediately investigating the scope and severity of the breach.
• Notification to Regulator: Notifying the Office of the Australian Information Commissioner (OAIC) where required by the NDB scheme
• Notification to Individuals: Notifying affected individuals and providing clear guidance on steps they can take to mitigate any risks of harm.

PRIVACY COMPLAINTS
We are committed to resolving any complaints regarding our handling of your personal information fairly and efficiently.

Internal Complaint Resolution
If you are dissatisfied with our compliance with this Policy or the way we have handled your personal information, you should first lodge a formal complaint by contacting our designated Privacy Officer (details provided in Section ‘Contact and Privacy Officer Information’ below).

We will investigate your complaint and endeavour to provide you with a response within a reasonable timeframe.

External Complaint Resolution
If you are not satisfied with the outcome of your internal complaint, you have the right to seek external review from the relevant regulatory body:

• Office of the Australian Information Commissioner (OAIC)

  • Website: www.oaic.gov.au

  • Phone: 1300 363 992

CHANGES TO THIS PRIVACY POLICY
We reserve the right to review and amend this Privacy Policy periodically to reflect changes in our business practices, technology, or legal obligations.

The most current version of this Policy will always be published on our website and will be effective immediately upon posting. We encourage you to review this Policy regularly. For any significant changes that affect your rights or the way we process your data, we may also notify you via email or through prominent notices on our website.

CONTACT AND PRIVACY OFFICER INFORMATION
For any questions, requests (including access, correction, or deletion), or complaints related to this Privacy Policy or our handling of your personal information, please contact our Privacy Officer: