We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au

This privacy notice explains how we may collect, use and disclose information, and describes the rights you may have in respect of your own personal information.

Clients

This notice applies to the individual client contacts with whom we deal, including prospective clients. It applies to personal information that is collected as part of our client on-boarding process and disengagement, as well as to the information gathered during the course of a client relationship.

It also applies to the personal information of employees at client entities whose details we may receive as part of the provision of legal services. In these circumstances our main client contact is responsible for ensuring that all affected individuals are made aware that their personal details will be provided to us and of the purposes for which we will use that information, for example by showing them a copy of this notice.

Business contacts

In addition, this notice covers the personal information of individuals who are not existing or former clients but who engage with the firm by signing up to receive communications such as email alerts and publications, or who attend events run by the firm (either alone or in conjunction with partner organisations).

Personal information

Personal information is any information (electronic or written) or an opinion, that could identify an individual. Personal information will vary, depending on whether a person can be identified or is reasonably identifiable in the circumstances.

Personal information may include:

• Name, signature, address, phone number or date of birth
• Sensitive information, such as, racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information and some aspects of biometric information
• Credit information
• Employee record information
• Photographs
• Internet protocol (IP) addresses
• Voice print and facial recognition biometrics (because they collect characteristics that make an individual’s voice or face unique)
• Location information from a mobile device (because it can reveal user activity patterns and habits)

The Privacy Act 1988 doesn’t cover the personal information of someone who has died.

Information that we collect

We collect information about you when you provide it to us, when you use our website and when other sources provide it to us.

Information you provide to us

AME is committed to collecting and using only the personal information that is necessary for the provision of research or consulting services to our clients; to establish and/or maintain its business relationship with business and/or firm contacts; and to keep individuals informed of services and events which it reasonably considers may be of interest to them and/or which they have otherwise confirmed their preference to receive from the firm.

In some cases, it will be mandatory for you to provide personal information to the firm to enable us to provide services to you (or your employer), engage with you or to comply with the firm’s legal obligations.

Due diligence

AME collects a variety of information about clients and client contacts as part of our new client on boarding process. The checks may include the following:

• Identity verification:proof of name and address
• Ultimate beneficial ownership of corporate and other legal entities
• Confilcts checks:to avoid a conflict of interest with any other client
• Anti-money laundering, proceeds of crime and terrorist financing checks

These checks are made for legal, regulatory, or business reasons and may need to be repeated during the course of our engagement. It is important that you provide us with all necessary information and documents requested or this may affect our ability to provide services.

Providing research or consulting services

AME may collect or generate additional details about you during the course of our engagement, for the purpose of providing research or consulting services. As part of this we may collect information about employees of client organisations, for example when advising on a business sale, relocation programme or share scheme.

Information we collect from our website

We use Google Analytics, a reporting service provided by Google, Inc. (‘Google’) and its subsidiaries. Google Analytics uses ‘cookies’ to help us analyse how users navigate the website. The information generated by cookies about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity.

Google may also transfer this information to third parties, where required to do so by law or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note, however, if you do this you may not be able to use the full functionality of this website.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more details visit Google Analytics Terms of Service. To learn how to opt out of Google Analytics visit https://tools.google.com/dlpage/gapotout .

Information from other sources

As part of your business or other commercial dealings with the firm, we may collect or generate details about you. We may use this personal information to administer our relationship and maintain contractual relations, for accounting and tax purposes and to comply with our regulatory obligations.

Information collected at our premises

If you visit our premises, your image may be captured on CCTV systems operated by the firm or the entity which manages our premises. Building access control systems may also capture the location, time and date of your entry and exit to our offices.

How we use your data

How we use your information depends on which services you use and how you use them as well as any preferences you have communicated to us.

We may use your personal information to administer our relationship and maintain contractual relations for:

Client Support

AME may use your information to respond to and queries, technical issues and requests for assistance.

Marketing and business development

AME collects information for marketing and business development purposes and as part of the general administration of client relationships. We may use some personal information for client entertainment purposes, including recording your interests and preferences. We may use your personal details to send you information by email or post, or using social media or social networking sites, about our services, developments in law and practice, brochures, press releases, invitations to seminars and talks. You can select the practice areas and subjects you are interested in when you sign up on our website. You may update your preferences or opt out at any time.

Accounting and tax purposes

AME will use your personal data where necessary for internal administrative purposes related to our services - such as our accounting and records.

Compliance with the firm’s regulatory obligations

In some cases, we may have a legal obligation to use or keep your personal data.

Establishing, exercising or to defend legal rights

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

Historical and statistical purposes

AME collect information to gather broad demographic data about our website visitors in general. This information does not contain anything that can identify individuals.

Sharing your Personal Information

AME may disclose your personal information in certain circumstances such as:

• if required by applicable law;
• in connection with a reorganisation or combination of our firm with another firm;
• if we believe that such disclosure is necessary to enforce or apply terms of engagement and other agreements or otherwise protect and defend AME’s rights, property or safety;
• in order to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or government inquiry;
• with your consent.

Third party recipients of personal information relating to clients, business and firm contacts may include:

• Tax and Customs & Excise authorities
• Regulatory and other professional bodies
• Stock exchange and listing authorities
• Public registries of company directors and shareholdings
• Providers of identity verification services
• Credit reference agencies
• The courts, police and law enforcement agencies
• Government departments and agencies
• Auditors and professional advisers (including professional indemnity insurers and advisers)

AME will use all reasonable efforts to disclose the minimum personal information necessary in each case.

Transfer of Information Internationally

AME is an international company and as such we collect information globally and may transfer, process, and store your information outside of your country of residence (which includes transfers outside the European Economic Area) to our centralised operations.

Data Retention

We will retain your personal information only for as long as it is needed for the purpose it is collected or if we are legally required to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes). Please be aware that retention periods will vary in different jurisdictions. The retention period for client files is detailed in our Engagement Letters.

Where possible and practical, personal information will be rendered anonymous through the removal, substitution or blocking of details which enable individuals to be identified. Once the data retention period is over, we will delete the personal data.

Cookies

To learn more about the cookies that AME use on our website, as well as to manage your cookie settings, please read our Cookie Policy.

Responsibility for External Sites

Our website may contain links to other websites. Some of those may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others.

We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave our website, we recommend that you review each website's individual privacy notices and make your own conclusions regarding the adequacy of these.

Your Rights

You have the legal right to:

• Request a copy of the personal information held by AME about you, make corrections if it is incomplete or incorrect or sometimes ask us to delete it
• Restrict or object to the processing of your personal information in certain circumstances and subject to applicable law
• Withdraw your consent where you have provided personal information voluntarily, or otherwise consented to its use
• Opt out of receiving marketing communications at any time
• Complain to the Australian Information Commissioner by visiting oaic.gov.au or to the data protection regulator in the country where you are.

Contact Us

If you have a query about this notice or wish to exercise your rights, please feel free to contact us

Changes to this Privacy Notice

This privacy notice may be updated from time to time, you’ll always be able to find the most recent version on this site.

Last updated: 15 February 2022

Thank you for reading this privacy notice.