Privacy Policy

1. Introduction

1.1 RK Petersen Investments Pty Ltd (ACN 671 401 077) (“we”, “us”, “our”) recognises the importance of protecting the privacy and rights of individuals in relation to their personal information.
1.2 This Privacy Policy sets out our commitment to protecting the privacy of your personal information and how it is collected—whether through our website (the “Site”), directly from you, or otherwise.
1.3 We respect your rights to privacy under the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and we manage the collection and disclosure of your personal information in accordance with these requirements.
1.4 If you are based in the European Union, we also uphold your rights under the General Data Protection Regulation (EU) (GDPR). Your GDPR rights are listed in clause 12.
1.5 You do not have to provide personal information to us; however, this may affect your use of the Site or any products and services offered on it.


2. What is your personal information?

2.1 “Personal information” has the meaning given in the Privacy Act and the GDPR.
2.2 In general, it is any information that can be used to personally identify you (e.g., name, address, telephone number, email address, profession/occupation).
2.3 If the information we collect personally identifies you, or you are reasonably identifiable from it, it will be considered personal information.
2.4 We may also collect information that is not personal (e.g., anonymous survey responses or aggregated Site usage data).
2.5 Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.


3. What information we may collect from you

3.1 We may collect: names; email addresses; telephone numbers; business management information; billing/mailing/business or residential address; business/company numbers and names; banking/credit card/online payment details; website and social media information; date of birth; identification; profession/occupation; employment status; primary language.
3.2 We collect, hold, use and disclose personal information to: provide our products/services; conduct business functions; keep records; understand user needs; process data; personalise your Site experience; send requested communications; answer enquiries; conduct research/marketing (including direct marketing); send promotional information (including about third parties we think may interest you); comply with laws or regulators; contact you; book appointments; and meet internal administrative/marketing/planning requirements.


4. How we collect your personal information

4.1 We collect information directly from you where reasonable, including when you: enquire about our products/services; complete online forms (including for downloads/bookings); access and use the Site (including registration); speak with our representatives or interact via social media; join mailing lists; become a client/customer; use our social media pages (including via analytics tools and cookies); visit links from our communications; participate in recorded calls; participate in interviews/focus groups/online or phone surveys; or via third-party providers where they have your consent to disclose for social/market research.


5. What happens if we can’t collect your personal information?

If you don’t provide the information: (a) we may not be able to provide products/services to the same standard or at all; (b) we may not be able to provide information about products/services or promotions; or (c) we may be unable to tailor Site content to your preferences.


6. Our Site

Site User Tracking Experience
6.1 We may use tracking software to review/improve your experience (e.g., Facebook Pixel, Infusionsoft, ActiveCampaign, Google Analytics, YouTube).
6.2 The Site server may log: server address; date/time of visit; pages accessed/documents downloaded; duration of visit; browser type; domain/IP, OS, browser type, screen resolution.
6.3 We may use products such as Google Analytics (including Demographics and Interest Reporting). Google Analytics may collect data via cookies/identifiers.
6.4 Data collected via Google products is not linked to personally identifiable information you submit on the Site. Opt out at: tools.google.com/dlpage/gaoptout.

Cookies
6.5 We may send cookies to your device to recognise you, remember viewed products/services (with consent) and improve your experience.
6.6 We use cookies to measure traffic/transaction patterns.
6.7 Cookies do not collect personal information. You can set your browser to refuse cookies. We may log IP addresses to analyse trends and administer the Site.
6.8 Embedded content/sharing tools from social networks may place their own cookies. We do not control these cookies—check each provider’s policy.

Security
6.9 As the Internet is inherently insecure, we cannot guarantee the security of transmissions to us.
6.10 Information you send online is transmitted at your own risk.

Links
6.11 We link to external/third-party sites we don’t control and are not responsible for.
6.12 Review the terms and privacy policies of any third-party sites before disclosing personal information.


7. Groups and forums

7.1 Information you share in forums/chat rooms/webinars may be broadly available to others with access. Opinions shared are those of the individual, not us.
7.2 Webinars/meetings may be recorded. By attending, you acknowledge recordings may be stored and shared with hosts/attendees. If you do not want to be recorded, please leave the session.


8. Who we disclose your information to

8.1 We may disclose personal information to: our directors/employees/agents/contractors/service providers (e.g., consultants, hosting, IT, mailing, couriers, payments, data entry, network admins, debt collectors, professional advisers); suppliers/third parties with whom we have commercial relationships (which may include overseas parties); credit agencies/courts/regulators/law enforcement as required; or any other organisation with your express consent.
8.2 We only disclose to third parties that agree to comply with standards in this Privacy Policy.
8.3 In a change of control/sale/assignment/transfer of our business/assets, we may transfer user databases (including personal information) to the extent permitted by law, subject to confidentiality.


9. Direct marketing materials

9.1 We may send direct marketing about our products/services (mail, SMS, email) in accordance with applicable laws (e.g., Spam Act 2003 (Cth)).
9.2 We’ll use your preferred communication method where practical.
9.3 You may opt-out at any time by contacting [email protected] or using opt-out links in our communications.
9.4 We do not provide your personal information to other organisations for their direct marketing.


10. Security and data quality

10.1 We take reasonable steps to protect personal information from misuse/loss/unauthorised access/modification/disclosure.
10.2 No Internet transmission is totally secure.
10.3 We take reasonable steps to protect data once received.
10.4 Staff and contractors are obliged to respect confidentiality.
10.5 We may hold information electronically or in hard copy. We destroy or de-identify personal information when no longer needed or legally required.
10.6 If a data breach occurs, we will promptly assess and take remedial action to prevent serious harm.
10.7 If we have reasonable grounds to believe an eligible data breach has occurred, we will promptly notify the Office of the Australian Information Commissioner (OAIC), AMSRO (if applicable), and affected individuals, consistent with the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth).


11. How long we retain your personal data

11.1 We retain personal data only as long as necessary for the purposes collected and to satisfy legal/accounting/reporting requirements.
11.2 Retention considers the amount/nature/sensitivity of data, risk of harm, purposes of processing, alternative means to achieve those purposes, and legal requirements.
11.3 By law, we must keep basic customer information for five years for Australian tax purposes.
11.4 In some circumstances you can ask us to delete your data (see clause 12).
11.5 We may anonymise data for research/statistics and use it indefinitely.


12. If I am based in the EU, what are my legal rights under the GDPR?

12.1 Your rights include:
(a) Right to be informed; (b) Right of access (data subject access request); (c) Right to rectification; (d) Right to erasure (“right to be forgotten”) in certain circumstances; (e) Right to restrict processing in certain circumstances; (f) Right to data portability; (g) Right to object (e.g., to direct marketing); (h) Rights regarding automated decision-making and profiling.
12.2 These rights are subject to applicable rules/conditions.
12.3 To exercise rights, contact [email protected].


13. How to access and correct your personal information

13.1 Request access at any time via [email protected].
13.2 Where you are entitled to access, we will provide suitable means (e.g., mail/email).
13.3 We may charge a reasonable administrative fee for providing access (not for making the request or corrections).
13.4 We may refuse access in limited cases (e.g., privacy of others/confidentiality). If refused, we will provide reasons.
13.5 If information is incorrect/incomplete/inaccurate, you may request correction. If we disagree, we will add a note stating you dispute it.


14. Withdrawing consent

14.1 You may withdraw consent to this Privacy Policy at any time by contacting our Data Protection Officer at [email protected]. We will delete/destroy/return data to the extent permitted by law (withdrawal may affect your use of the Site or our products/services).
14.2 You may restrict collection/use of your personal information, including changing your mind about direct marketing by contacting us.
14.3 To unsubscribe from emails or opt out of communications, contact us with “Unsubscribe” in the subject line.


15. Complaints about a breach of privacy

15.1 If you believe your privacy has been breached, contact us with details.
15.2 We will treat your complaint confidentially, investigate, and aim to resolve within a reasonable time and within the time required by the Privacy Act and/or the GDPR (if applicable).


16. Contacting us

16.1 Questions, concerns or complaints: [email protected].
16.2 We will treat your requests/complaints confidentially.
16.3 We will contact you within a reasonable time to discuss and outline resolution options.
16.4 We aim to resolve complaints in a timely and appropriate manner.


17. Changes to our Privacy Policy

17.1 All personal information we hold is governed by our most recent Privacy Policy, posted on our Site.
17.2 Changes may be advised by updating this page. Please check periodically for updates.


© Progressive Legal Pty Ltd (ACN 607 068 708) trading as Progressive Legal (2023). All Rights Reserved.