Introduction
Koustas & Co and those entities controlled by Koustas & Co are committed to collecting, handling and disclosing personal information lawfully and fairly and to taking reasonable steps to protect and safeguard personal information.
Koustas & Co is bound by the Privacy Act 1988 (Cth) (Privacy Act) and the ten National Privacy Principles set out in that Act.

This privacy policy:
• Sets out how Koustas & Co collects, stores, uses and discloses personal information
• Relates to personal information collected by any means and by any technology
• Outlines how Koustas & Co makes the personal information it holds available for access to and correction by an individual.

If you have any questions about this policy, please direct them to the Privacy Officer (see contact details below).

Collection of personal information
Koustas & Co will, where it is reasonable or practicable to do so, collect personal information directly from an individual using a number of different methods, including collection via Koustas & Co’s websites, electronic transmission (e.g. email), post, telephone, in person or portable devices. We may also collect personal information from third parties, including clients, contractors, service providers and other individuals.
Koustas & Co will only collect personal information that is necessary to promote its business, to provide its services or to conduct its activities (Primary Purpose of Collection).

These activities include:
• To provide products and services to clients
• To receive products and services from service providers and contractors
• To maintain and promote relationships with clients, service providers and contractors
• To provide clients and prospective clients with information on our services and products, economic and industry developments, and seminars and events that may be of interest to them
• To recruit and maintain relationships with staff
• To complete internal administration functions (e.g. invoicing clients).

The type of personal information collected may include names, date of birth, gender, marital status, addresses, contact details, job titles, account details and financial information.

Use of personal information
Koustas & Co will use the personal information it collects in connection with the Primary Purpose of Collection.

Additionally, Koustas & Co may use the personal information it collects for a purpose (Secondary Purpose) that is related to the Primary Purpose of Collection and in circumstances where an individual would reasonably expect us to use personal information for a Secondary Purpose.

Where Koustas & Co uses personal information to market our products and services to clients and prospective clients, recipients can contact us at any time if they no longer wish to receive this marketing information. Alternatively, individuals will be given the opportunity to ‘opt out’ from receiving marketing communications from us by clicking on an unsubscribe link at the end of the email.

Disclosure of personal Information
Koustas & Co may disclose personal information to third parties, such as contractors, agents and service providers, to assist us with our activities and the provision of products and services to our clients. In doing so, we will take reasonable steps to ensure that these organisations are bound by obligations of confidentiality and privacy in order to protect personal information in accordance with the Privacy Act.

We may also send personal information to organisations outside Australia in connection with the provision of our products and services to clients and the performance of administrative functions.

If we transfer personal information overseas, we will only do so in compliance with this privacy policy and the Privacy Act. Furthermore, we will take reasonable steps to aim to ensure that the overseas organisation receiving the information will handle that information in accordance with the Privacy Act.

Other than as outlined above, Koustas & Co will not disclose personal information to any other third party unless Koustas & Co has:
• Reasonable grounds to believe that the disclosure is required by law
• Reasonable grounds to believe that the disclosure is necessary to prevent a serious and imminent threat to a person’s life, health or safety
• The consent of an individual to do so.

Access, data quality and correction
Koustas & Co will provide access to personal information about an individual upon request by that individual (although there are some exceptions to granting access e.g. where providing access would be unlawful under the Privacy Act). If Koustas & Co denies access to an individual’s personal information, it will provide reasons in writing.

The procedure for gaining access is as follows:
• An individual will need to make a request for access in writing, addressed to the Privacy Officer (see contact details below)
• An individual must provide sufficient details of the information requested
• Koustas & Co will need to verify the identity of that individual
• Koustas & Co may need to charge an administrative fee to cover the cost of access (however, there is no fee for lodging a request for access). Koustas & Co will notify the individual of the proposed fee before proceeding
• Koustas & Co will respond to a request as soon as reasonably practicable but by no later than 30 days of receipt of the request
• Koustas & Co may deliver the requested information either by mail or by email.

Koustas & Co will take all reasonable measures to aim to ensure that the personal information it holds is accurate, complete and up to date. Please contact the Privacy Officer if you believe that the information we have about you is not accurate, complete or up to date.

Information security
Koustas & Co has in place generally accepted standards of technological security for the purpose of protecting personal information from misuse, loss, corruption or destruction. Only authorised personnel have access to personal information. Such personnel are required by Koustas & Co’s policies and employment contracts to maintain the confidentiality of this sensitive data.

Where personal information we hold is identified as no longer needed for any purpose for which the information may be used or disclosed under the Privacy Act, we will take reasonable steps to destroy such information e.g. by shredding in the case of paper records and other means in the case of electronic records.

Online privacy matters

Our websites
Koustas & Co takes care to protect the personal information given to us on our website e.g. our websites have electronic security systems in place.

Cookies
For statistical purposes, we may collect information through the use of ‘cookies’ on website activity (including the number of users who visit our websites, the date and time of visits, the number of pages viewed, navigation patterns, the country and systems through which users have accessed the website).

Cookies are data that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies can facilitate a user’s ongoing access to and use of a website and may be necessary to access features such as online transactions.

Cookies on their own do not identify an individual but they do provide us with statistics that can be used to analyse and improve our websites.

Changes to our privacy policy
Koustas & Co may amend this privacy policy from time to time by posting an updated version on our website. We encourage you to visit our website periodically in order to remain up to date.

The amended privacy policy will supersede this version and will apply between us whether or not we have given you specific notice of any change.

What to do if you have a question or issue
If you have any queries about this privacy policy, or if you have any issues you wish to raise with Koustas & Co about privacy, please contact us at:

Business Manager
Koustas & Co
14/412 St. Kilda Road
Melbourne VIC 3004
Enquiry@koustas.com.au

If you believe that Koustas & Co has not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner whose contact details are as follows:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
1300 363 992
enquiries@oaic.gov.au

Additional information
For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.
Policy review
Reviewed on: January 2012.