In circumstances where we handle personal information differently from that described in this policy because the Privacy Act does not apply, we will provide you with relevant privacy policies which apply in place of this policy.
This policy is not intended to cover categories of information that are not covered by the Australian Privacy Act 1988 (Cth) (“Privacy Act”).
Collection of personal information
Custos Advisory collects personal information from clients, contractors, service providers, suppliers, employees, job applicants, website users, online contacts, attendees at seminars and other functions, and other individuals. The personal information we collect may be provided in meetings, email messages, telephone conversations, mobile messaging apps, registrations for subscriptions, forms filled out or submitted in paper form or online, agreements entered into with us, or when you use our website or engage in social media with us, or by third parties. We may keep a record of your contact with us. We may also collect personal information about you from third parties, including from government agencies, regulatory and industry bodies, law enforcement bodies, rating agencies, recruitment agencies, previous employers and referees, and publicly available sources.
Depending on the circumstances under which Custos Advisory collects and holds personal information, the main types of personal information relate to:
Names, contact details, job titles, organisational roles, financial information and other personal information of actual and prospective clients;
Personal information of other individuals collected from clients in connection with products and services that we provide;
Personal information collected from contractors, service providers or suppliers in connection with our engagement with them;
Personal information collected from employees in connection with employment relationships;
Personal information collected from individuals in connection with job applications received;
Personal information collected from individuals as a result of seminars or other events conducted, organised or attended by us;
Personal information collected from website users or online contacts through our websites; and
Personal information collected from individuals who communicate with us.
In some instances, we may collect sensitive information such as health information, religious beliefs or criminal records.
We may take screenshots, photographs or videos of individuals at events or seminars conducted, organised or attended by us, or in some other circumstances.
If you provide personal information of your directors, employees or other individuals, we rely on you having the right to do so.
If you choose not to provide personal information to us where requested (or provide inaccurate or incomplete information), we may not be able to provide services to you, respond to your requests or communicate with you.
Use of personal information
We collect, hold and use personal information primarily for the purposes of providing our services, conducting and promoting our business, and other purposes, which may include:
to provide our products and services;
to administer and develop relationships with clients, potential clients, contractors, service providers and contacts;
to respond to an individual's request;
to market our services or organise events;to contract out some of our functions to external service providers and suppliers;
for general management and reporting purposes, such as invoicing and account management;
for recruitment purposes and assessment of job applicants;
for purposes related to the employment and management of our personnel and providing internal products and services to our staff;
for assessment of prospective suppliers, service providers and contractors;
for business or industry statistics or analytics purposes, for research, planning, service development, security and risk management;
for further investigation of information collected by us;
other purposes related to our business; and
where required or permitted by law, regulation, or rule.
This policy or part of it may not apply to the handling by Custos Advisory of our employee information and records as they are not generally subject to the Privacy Act. Please contact us directly for information about our practices relating to employee information.
Business development and marketing communications
We may use personal information to send marketing communications to clients and other contacts by post, email or other electronic means, to inform them of industry developments and to market our products and services (including seminars and other events). This may include products, services and offers provided by our business partners.
If you do not wish to receive marketing material from us, please contact our Privacy Officer at the details set out in this policy. For electronic communications, you can click on the unsubscribe function in communications. Please allow 28 business days for your request to be processed.
If you do not consent to receive, or unsubscribe from receiving, marketing communications from us, we may still contact you for the other purposes described in the “Use of personal information” section above.
Disclosure of personal information
Custos Advisory does not sell personal information to third parties.
We do not routinely disclose personal information to other parties, unless:
you give your consent or direction; in connection with the uses permitted by this policy;
in connection with a product or service we provide;
to Custos Advisory’s personnel, professional advisors, contractors and business collaborators;
to protect the rights, property or personal safety of a customer of Custos Advisory or the interests of Custos Advisory or any member of the public;
in connection with the transfer or proposed transfer of some or all of the assets or operations of Custos Advisory or the formation of alliance or referral arrangements; or
to government, regulatory or industry bodies or agencies; or
disclosure is required or permitted by law, regulation, or rule.
Your personal information may be shared for business-related purposes with our related entities, our agents and third-party suppliers, service providers or business collaborators. This means that individuals and organisations outside of Custos Advisory will have access to personal information held by us and may collect or use it from or on behalf of Custos Advisory. This may include independent contractors and consultants, information technology providers, business collaborators, event managers, mail houses, off-site security storage providers, credit managers and debt collecting agencies.
We may also share non-personal or de-identified information with third parties for research, development, analytics or promotional purposes.
Disclosure of information outside Australia
In addition to disclosures permitted under this policy, we may disclose your personal information to entities located overseas that are owned or managed by Custos Advisory.
We may also disclose personal information to overseas facilities, contractors or business collaborators to provide certain products or services to us in connection with the operation of our business, such as marketing services and data storage. We will observe the Privacy Act including disclosure of personal information to recipients located overseas. Please note that such overseas recipients may not be bound by the Privacy Act. By submitting your personal information to us you agree that you do not object to any such transfer, processing or storage.
Our websites and online applications
In addition to personal information, you provide to us directly, we may collect personal information via our websites, including ‘custos.ltd’, electronic publications and online applications including mobile applications. We may also collect other information such as the webpages you access on our site or the documents you download.
To facilitate management of our websites and applications, we may log certain statistics about the users of the facilities, for example the users' domains and browser types. Such information is used solely to facilitate navigational experience for website users and does not specifically identify an individual.
Cookies are used on some Custos Advisory websites. Cookies are small text files that are stored on your computer by the websites that you visit. They are widely used to help analyse how users use the website which may improve functionality or tailor website visitors’ online experience. They also provide information to the owners of the site. You can change the cookies settings in your browser, for example by deleting cookies from your ‘browser history’ (cache) when you leave the site.
We may also use other technologies or tools, such as web beacons and Googles Analytics, to automatically collect certain types of information and to monitor users of the Custos Advisory website. More information about the use of Googles Analytics can be found at https://www.google.com/analytics/terms/us.html.
Information collected via cookies and other technologies may be used by us for development or analytics purposes.
If a login is set up on a Custos Advisory’s website, the user will be identified by a user name and password for logging into our website or applications. Information collected about use of our websites by these users may be used in assisting to resolve any technical difficulties and for measuring use and performance.
As the internet is inherently insecure, we give no assurance of the security of transmission of information supplied to us online or via our websites. We also cannot guarantee that information supplied to us online will not be intercepted while being transmitted over the internet.
Security of personal information
Custos Advisory will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether in hardcopy or electronically. We will also request third-party service providers which hold your personal information to abide by applicable laws concerning protection of personal information. We require our employees to respect the confidentiality of any personal information held by Custos Advisory and be bound by this policy.
Access to information
You may request access to personal information about you that we hold or request its correction if you believe that information we hold about you is incorrect, incomplete or out of date. Your request should be made in writing to our Privacy Officer.
In some cases, we may request an administrative fee to cover the cost of access or refuse to give you access to personal information we hold about you in accordance with the Privacy Act.
Inquiries and complaints
Contact Details of Privacy Officer
Please address all inquiries and complaints relating to this policy or how we manage personal information, and requests for access of personal information, in writing to the Privacy Officer:
through our website under ‘Contact Us';
via mail to Custos Advisory, PO Box R821, Royal Exchange, NSW 1225.
We will require you to prove your identity as the person to whom the information relates.
Please allow 28 business days for your request to be processed.
Agreement and effect of policy
This policy was last updated 1 September 2022.