Privacy Policy.
At NextLevelCorporate (“we” or “us” or “our”), we care about and are committed to respecting the privacy of your information.
We treat all personal information in accordance with obligations that are binding on us under the Privacy Act 1988 (Cth) (“Privacy Act”) including the Australian Privacy Principles (“APPs”).
The Privacy Act regulates how we can collect, store, verify, use and disclose personal information we hold about you and the conditions under which your information may be accessed and corrected and how you can make a privacy complaint.
The purpose of this Privacy Policy (“Policy”) is to ensure that we provide open and transparent advice to our clients about the way in which any personal information that is collected and held by us is appropriately managed.
This Policy states our approach to the above, under 7 key headings.
1. What is personal information?
2. How and when we collect personal information.
3. How we may use and disclose personal information.
4. How we may store, secure, remove and de-identify your information.
5. How you can access your personal information.
6. How you can correct your personal information.
7. How you can make a privacy complaint.
1. What is personal information?
Personal information held by us may include your:
name and date of birth;
residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
computer and connection information including your Internet Protocol (“IP”) address; and
any information that you otherwise share with us.
Anonymity and Pseudonymity.
Before becoming a client, you have the option of not identifying yourself or using a pseudonym, when communicating with us.
However, we are required to collect and hold personal information under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”) and to report certain information or actions to AUSTRAC, which is Australia's financial intelligence agency with regulatory responsibility for AML/CTF.
As a consequence, it is necessary for us to identify you in order to undertake business with you. Therefore, you acknowledge and agree that we will be unable to do business with you if you wish to remain anonymous.
2. How and when we may collect your personal information.
From our clients.
Wherever possible and practicable we will collect your personal information directly from you.
We only collect personal information that is necessary for us to perform our functions that we are licensed to provide under our Australian Financial Services License. In addition, we are required to collect and hold personal information under the AML/CTF Act and report certain information AUSTRAC.
The kinds of personal information we collect and hold will depend on the services you request from us. However, it may include but may not be limited to:
information from public records and third party sources;
information you give us when which may be necessary for us to perform our services to you; administer, further and complete our advice or services to you and comply with any legal obligations;
information about individuals and organisations which we collect in the course of providing services to you; and
communications between us and you such as forms you fill out, face-to-face meetings, e-mail messages you send us, via our website, or during telephone conversations, and if you contact us, we may keep a record of that contact.
From our Website and Email.
Through our website, we only collect personal information that is necessary for us to function and conduct our business.
We and/or our web host, Squarespace, may collect personal information that you provide to us about you when you use our website, including but not limited to when you:
add comments in any elements of our website that permit user-generated content;
register for access to our newsletter, NextPerspective; or
complete our online contact form to contact us.
When you visit our website, we and/or our web host makes a record of your IP address, and Squarespace Analytics records:
the pages you visited of our website;
the date and time that you visited our website; and
the kind of browser you used to visit our website.
At NextLevelCorporate, we may from time to time choose to de-identify your personal information. This is done by disabling our website activity log along with all Analytics and Performance cookies used by Squarespace Analytics, which means that we would no longer receive information that we consider might be necessary to provide us with insights which may assist us to provide you with a more tailored and better experience.
If you receive our newsletter, our email newsletter host makes a record of when, from where and how often you opened our newsletter and if and which links you clicked. However, to disable these analytics would require us to disable all website Analytics and Performance cookies given the integrated nature of the Squarespace email platform. Our primary reason for consulting this analytical data is to ensure that you have received our newsletter and to better understand which items are of more or less interest to you and our readers so that we can provide a better and more tailored experience to readers.
If you do not accept this and do not wish to be tracked, you can opt out of our newsletter at any time by using the unsubscribe button in the newsletter. If you do this, you will no longer receive information from us that we consider might be valuable to you.
If you provide information to us by corresponding with us via electronic mail or through our enquiry form, our and/or our host’s mail server makes a record of:
your full e-mail address and the full recipient address; and
the time and size of your e-mail.
From Cookies.
A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer.
Cookies may improve your browsing experience because they help websites remember preferences and understand how people use different features. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.
By default, our web host uses cookies to run our site and allow you to navigate and use features on our site (these are Functional and Required cookies) and obtain information about you for web analytics purposes (these are Analytics and Performance cookies utilised by Squarespace Analytics).
>Analytics and Performance Cookies (these may be disabled, from time to time).
We use Squarespace Analytics to help us understand website traffic, web page usage and to provide other insights which may assist us to provide you with a more tailored and better experience. If we choose to de-identify your information, we do this by disabling Analytics and Performance cookies utilised by Squarespace Analytics, so that:
we do not place Analytics and Performance cookies, which we regard as non-essential, on your browser; and
we do not collect or see your IP address or other personal data.
>Functional and Required Cookies (opt-in via our cookie banner).
We display a cookie banner, so that you can opt into your use of the Functional and Required Cookies to improve your browsing experience.
Our website uses Functional and Required cookies (which are listed below) to:
remember your preferences for using our website;
show relevant notifications; and
remember details of data that you choose to submit to us (e.g., through our online contact form) or dismiss (such as announcements and banners).
Many of these cookies are removed or cleared when you log out (these are session cookies), but some may remain so that your preferences are remembered for future sessions (these are persistent cookies).
Typically, a persistent cookie is entered by your web browser into the "cookies" folder on your computer and remains in that folder after you close your browser and may be used by your browser on subsequent visits to our website.
Persistent cookies used at our website include but may not be limited to:
squarespace-popup-overlay which prevents a promotional pop-up from displaying if you dismiss it; and
squarespace-announcement-bar which prevents the announcements bar from displaying if you dismiss it.
A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer.
Session cookies used at our website include but may not be limited to:
Crumb, which Prevents cross-site request forgery (“CSRF”) which is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in;
Locked, which prevents the password-protected screen from displaying if a visitor enters the correct site-wide password; and
RecentRedirect, which lasts for 30 minutes and prevents redirect loops.
>Third party cookies.
In some cases, third parties may place cookies through our website or our newsletter.
third party social media applications (e.g., LinkedIn, etc.) may use cookies in order to facilitate a social media button/plug-in on our website; and
our email newsletter host uses cookies and similar technologies to track the delivery of our newsletter to you and how and in which way you open and interact with it, over time.
We are unable to control third party processes and policies, however you can configure your internet browser to deal with cookies in a number of ways, such as accept all cookies, reject all cookies or notify you when a cookie is sent.
>Google Analytics.
Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. For example, if you want to opt-out of Google Analytics cookies, you can install the Google Analytics Opt-Out Browser, by reading the instructions here.
>Opt-out of all cookies to the extent your browser or device permits.
Please refer to your internet browser’s instructions to learn more about blocking, deleting and disabling cookies functions and how you can effectively opt-out of all cookies to the extent your browser or device permits.
>Linked websites.
Our website may offer links to other websites, over which we have no control. Those websites may also collect your personal information (including information generated through the use of cookies) when you visit them.
Whilst links may be provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours.
You should review any privacy notices on those linked websites before providing them with your personal information.
We are not responsible for any linked websites.
From third party sources.
We may also collect information from third party sources including your business card or vCard, referees, and publicly available sources including the press, court judgments and social media platforms.
In some cases, we may collect your personal information from a third party, such as a marketplace, client, broker, bank, receiver/manager, administrator or the like.
From unsolicited personal information.
To the extent we receive, on an unsolicited basis, personal information concerning you that is not contained in a Commonwealth record and that we could not have otherwise collected, we will as soon as practicable destroy the information or ensure that it is de-identified.
Sensitive information.
Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
At this time, we do not collect any sensitive information although on occasion we may be required to collect information about your criminal record where this is necessary to comply with the AML/CTF Act.
3. How we may use and disclose personal information.
Any personal information which we collect about you will be used and disclosed by us so that we can provide you with the services that you have requested, or otherwise to enable us to carry out our functions as an efficient corporate advisory.
It may also be used and disclosed for the further purposes for which it was collected, including those listed below or for secondary lawful purposes related to those purposes. We collect personal information to:
provide you with advisory services along with invoices for our services;
verify your identity, conduct appropriate checks and make reports if and where required under AML/CTF Act;
manage relationships with suppliers, contractors and other parties;
undertake searches, including but not limited to searches about corporations, directorships and from time to time, personal property;
prevent and detect any misuse of, or fraudulent activities involving our website;
prepare general statistics on the usage of our website and our NextPerspective newsletter;
respond to or contact you (including via electronic messaging such as SMS, email and social media or by mail, facsimile, phone or in any other lawful manner);
provide advice to a client in relation to a matter which involves you, your related entities and/or your investments; and
develop and improve our services.
We may also provide you with information in our NextPerspective newsletter unless you unsubscribe, or in any other case you ask us in writing, not to do so.
We will not pass on the personal information you give us to anyone without first asking your permission, unless we are required or permitted to do so under the AML/CTF Act or by a Court or tribunal or by the operation of law.
Other circumstances in which we may use and disclose your personal information include:
where you have consented, expressly or impliedly or where consent can be inferred, to the disclosure or use;
to third party service providers (including IT services providers, insurance providers, lawyers, consultants, messaging service providers, marketing list providers);
where the use or disclosure is authorised or required by or under an Australian law or order of a Court or tribunal or is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of ASIC, APRA, AUSTRAC or some other enforcement body;
to conduct research and development in respect of our services and to gain an understanding of your needs or obtain feedback or views about our services in order for us to improve them;
to implement our terms of service and to protect the rights, property or personal safety of another one of our clients, any member of the public or ourselves;
to maintain and develop our business systems and infrastructure, including testing and upgrading those systems; and
for any other purpose reasonably considered necessary or desirable by us in relation to the effective operation of our business and to provide you with the services and information you have requested.
Your personal information may also be collected so that we can tailor services to you to keep you informed about information we believe you will find valuable and may continue after you cease to engage our services.
In providing our services to you we may need to disclose personal information to a third party.
This will be done to the extent that it is permitted by law and set out in this Policy.
Direct Marketing.
We may from time to time, use or disclose your personal information for the purpose of direct marketing.
You give your express and informed consent to us to use your personal information for the purposes relating to enquiries, the provision of corporate advisory services and the provision of marketing services to provide you with information and tell you about our services, updates about economic, financial and other related developments and publications which we consider may be of interest to you.
From time to time we may email you our NextPerspective newsletter. Our email newsletter host provides integrated analytics cannot be turned off separately. Our primary reason for reviewing analytical data in that context is to ensure that you have received the newsletter and to understand which articles are are of more or less interest to our readers, so that we can provide our readers with a better and more tailored experience.
If you would prefer not to receive this type of information, you may unsubscribe from our NextPerspective newsletter using the unsubscribe button within the NextPerspective newsletter.
If you follow our process for unsubscribing, we will no longer send you those communications.
If you do not wish to receive other direct marketing communications from us please contact us via the details provided below.
How we may provide your personal information to overseas recipients.
We may provide personal information we and/or our web host have collected about you (as described above) to third party overseas service providers and other entities, such as our web host which is located in United States of America and/or Ireland, or other service providers or contractor recipients.
You:
consent to your personal information being disclosed to a destination outside Australia, including but not limited to the United States of America and Ireland, for these purposes; and
consent to the inherent risks of international transfers of personal information and the difficulties you may face in seeking redress in overseas jurisdictions; and
understand and acknowledge that APP 8.1 will not apply to such disclosures of your personal information.
Government Identifiers.
We do not collect Government Identifiers.
4. How we may store, secure, remove and de-identify your information.
We are committed to maintaining the confidentiality of the information that you provide us and we will take all reasonable precautions to protect your personal information.
At NextLevelCorporate, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy paper file form and we take steps to protect this information from misuse, loss, unauthorised access, modification or disclosure.
Anti-virus software as well as passwords, protect electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
Unfortunately, no data transmission over the Internet (or otherwise) can be guaranteed as 100% secure. This means we cannot guarantee that someone else will not read the information you choose to give us when you transmit or send it.
Therefore, any information you send to us over the Internet or otherwise is transmitted or sent at your own risk.
Once any personal information comes into our possession, we will take reasonable steps to protect that information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We may be required by law to maintain records for a significant period of time. However, when we consider information is no longer required or relevant and any legal obligations that may apply to the information held have been met, we will remove detail that identifies you or we will securely destroy the records.
We exclude all liability (including, without limitation, in negligence) for the consequences of any unauthorised access to your personal information, except to the extent liability cannot be excluded due to the operation of statute.
5. How you can access your personal information.
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
We may charge a fee for our costs of retrieving and supplying the information to you, depending on its location and volume and the manner in which you have asked us to supply such information (to the extent such method is reasonable and practicable).
We will deal with all requests for access to personal information as quickly as possible. Depending on the type of request that you make we will usually respond to you within 14 days of receiving your request. We may need to contact other entities to properly investigate your request.
In some cases, consistent with the APPs, we may refuse to give you access to personal information we hold about you. This includes, without limitation, circumstances where giving you access would:
be unlawful;
have an unreasonable impact on another person’s privacy;
prejudice negotiations we are having with you;
be likely to prejudice the taking of appropriate action in relation to suspected unlawful activity or misconduct of a serious nature, that relates to our functions or activities; or
be likely to prejudice enforcement related activities carried out by, or for, an enforcement body.
If we refuse to give you access to personal information, we will provide you with reasons for our refusal.
6. How your information can be corrected.
We will take all reasonable steps to ensure that the personal information you provide us is accurate and up to date.
You may ask us to correct or remove information which you think is inaccurate. If you would like to amend any of your details or the information you have provided to us, you can contact us using our contact details provided in this policy.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information.
If appropriate and after having regard to the purpose for which the information is held, we will correct the information at the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request.
Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
If we refuse to correct personal information, we will provide you with our reasons.
We encourage all requests for access to or correction of your personal information to be directed to the Managing Director by e-mail: mike@nlcorporate.com.au or by writing to NextLevelCorporate, c/- PO Box 194, Northbridge Private Boxes, Northbridge WA 6865.
Contacting us about privacy.
If you would like more information about the way we manage personal information that we hold about you, please contact us using the above addresses.
7. How you can make a privacy complaint.
Complaints regarding a breach of privacy should be addressed to the Managing Director (using the contact details provided above) who will contact you with a view to resolving the complaint.
If we become aware of any ongoing concerns or problems concerning our privacy practices, we will contact you about the issue, investigate the issue, and take all reasonable steps to work with you to resolve the issue.
If you are still not satisfied you can contact the Office of the Australian Information Commissioner in writing, who may investigate your complaint further.
Office of the Australian Information Commissioner (“OAIC”).
Phone: 1300 363 992 | Mail for complaints (to be in writing): Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW, 2001 | Website: www.oaic.gov.au.
Acknowledgements.
By using our website, engaging us for corporate advisory and related services, submitting an enquiry, subscribing to NextPerspective or interacting with us (where you have been provided with a copy of this Policy or had a copy of this Policy reasonably available to you such as for example hosted on this public website), you are acknowledging and agreeing:
to provide the consents given by you in this Policy; and
that you have been informed of all the matters in this Policy; and
nothing in this Policy (or a linked or cross-referred document, website or other source) gives rise to any contractual obligations on NextLevelCorporate.
Modifications to our Policy.
From time to time, it may be necessary for us to revise this Policy.
Any changes will be made in accordance with any applicable requirements under the Privacy Act and the APPs and our notification about changes to this Policy will by made by posting an updated version of the Policy on this site.
If you require any further information about the Privacy Act and the APPs, you can visit the OAIC’s website, here.