Last updated: 1 January 2025. New Riverbell Pty Ltd (ABN 91 703 567 800) is committed to protecting the privacy of individuals whose personal information we hold. This policy explains how we manage personal information in accordance with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles (APPs).
1. Who we are
New Riverbell Pty Ltd provides professional business and consulting services to clients across Australia. We operate from Melbourne VIC and, for the purposes of the Privacy Act 1988 (Cth), we are an "APP entity" bound by the Australian Privacy Principles.
2. The kinds of personal information we collect
Depending on the nature of our engagement with you, we may collect:
- Your name, job title, and the name of the organisation you represent;
- Contact details such as your email address and business address;
- Information you provide when submitting an enquiry, quote request or feedback form;
- Records of our communications with you, including emails and meeting notes;
- Billing and payment administration details relevant to engagements;
- Website usage data such as pages visited, browser type and device information.
Where practicable, we collect personal information directly from you. We do not collect sensitive information (such as health, racial or religious information) unless it is reasonably necessary for a specific purpose and you have consented.
3. How we collect personal information
We collect personal information through our website forms, email correspondence, telephone and in-person meetings, engagement letters, and publicly available sources where it is unreasonable or impracticable to obtain the information directly from you. We only collect personal information by lawful and fair means (APP 1.3).
4. Purposes for which we collect, hold, use and disclose
We collect, hold, use and disclose personal information so that we can:
- Respond to enquiries and prepare quotations for prospective clients;
- Provide consulting, advisory and related business services to our clients;
- Administer engagements, invoicing and accounts;
- Manage our business operations, including record keeping and quality assurance;
- Comply with our legal and regulatory obligations, including taxation and corporate record-keeping obligations.
We will not use or disclose personal information for a secondary purpose unless an exception under the Australian Privacy Principles applies, or you have consented to that secondary use or disclosure.
5. Disclosure of personal information
We may disclose personal information to:
- Professional advisers engaged to assist with your engagement, such as external accountants, lawyers or specialist consultants, where the disclosure is necessary for the services;
- Service providers who host our website, email and document management systems;
- Government agencies, regulators or law enforcement bodies where we are required or authorised by law.
We do not sell personal information. Where we engage third-party service providers, we take reasonable steps to ensure they handle personal information in a manner consistent with the Australian Privacy Principles.
6. Overseas disclosure
Some of our service providers, including cloud hosting and email providers, may store or process data on servers located outside Australia. Where personal information is disclosed to an overseas recipient, we take reasonable steps to ensure the recipient does not breach the Australian Privacy Principles, in accordance with APP 8.
7. Data quality and security
We take reasonable steps to ensure that the personal information we collect is accurate, complete and up to date (APP 10). We also take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure (APP 11). These steps include:
- Access controls limiting personal information to staff and contractors who need it;
- Secure storage systems for electronic records and locked storage for physical files;
- Secure destruction or de-identification of personal information once it is no longer required for a lawful purpose, subject to our record-keeping obligations.
8. Access to and correction of your personal information
You may request access to the personal information we hold about you, and request correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading (APP 12 and APP 13). We will respond to such requests within a reasonable period. There is no charge for making a request, although a reasonable fee may apply for providing a copy of the information. In some circumstances permitted by the Australian Privacy Principles, we may decline a request; if we do, we will provide written reasons and information about complaint mechanisms.
9. Anonymity and pseudonymity
Where it is lawful and practicable, you have the option of dealing with us anonymously or under a pseudonym, for example when making a general enquiry about our services. However, we generally require identified information to provide business and consulting services, prepare quotations or manage an engagement.
10. Cookies and website analytics
Our website may use cookies and similar technologies to improve functionality and understand how visitors use the site. This information is generally de-identified and is not used to personally identify you. You can configure your browser to reject cookies; some website features may not function fully as a result.
11. Direct marketing
We may use personal information to send you updates about our services where you would reasonably expect this and you have not opted out. Every marketing communication will include a simple way to opt out of future communications, and we will act promptly on any opt-out request in accordance with APP 7.
12. Complaints and enquiries
If you have a question about this policy, or you believe we have breached the Australian Privacy Principles, please contact us in writing. We take privacy complaints seriously and will acknowledge your complaint promptly, investigate it fairly, and respond within a reasonable period.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
13. Contacting our privacy contact
All privacy enquiries, access requests and complaints should be directed to:
Privacy Contact — New Riverbell Pty Ltd
Email: ceo@newriverbellau.website
ABN: 91 703 567 800 · Melbourne VIC
14. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The current version will always be published on this page, and material changes will be noted by an updated "last updated" date.