Privacy policy

1. Who we are

Zhuge Holdings Pty Ltd is an Australian proprietary company registered in Victoria. In this policy, "we", "us" and "our" mean Zhuge Holdings Pty Ltd, and "personal information" has the meaning given to it by the Privacy Act 1988 (Cth) (the Privacy Act).

We are committed to handling personal information in accordance with the Privacy Act and the thirteen Australian Privacy Principles (APPs) contained in Schedule 1 to that Act.

2. What personal information we collect

We only collect personal information that is reasonably necessary for our functions and activities as a holding company. In practice, that is:

• Enquiry details — the name, email address, organisation and message content you provide when you write to us or use the contact form.
• Counterparty and transaction information — the names, roles and contact details of directors, shareholders, advisers and representatives of businesses we are in discussion with or hold an interest in.
• Records required by law — information we must keep under the Corporations Act 2001 (Cth) and tax law, such as details recorded in statutory registers.

We do not seek sensitive information as defined in the Privacy Act, and we ask that you do not send it to us unless we have specifically requested it for a lawful purpose.

3. How we collect it

We collect personal information directly from you wherever it is reasonable and practicable to do so — from your email, the contact form on this website, or in the course of a meeting or transaction. Where we collect information about you from a third party, such as your accountant, lawyer or broker, we take reasonable steps to make sure you are aware of that collection.

4. Why we collect and use it

We use personal information to:

• respond to your enquiry and correspond with you;
• assess, negotiate, complete and administer transactions and holdings;
• meet our governance, record-keeping, tax and reporting obligations; and
• manage the entities and assets we hold, including insurance and compliance matters.

We do not use personal information for direct marketing, we do not send unsolicited commercial messages, and we do not sell, rent or trade personal information to anyone.

5. Cookies and website analytics

This website is a static site. It does not set cookies, does not run analytics or tracking scripts, and does not embed third-party content, advertising or social media widgets. Nothing you do on these pages is profiled or tracked by us.

Our hosting provider may record standard server log information, such as IP address, request time and page requested, for the purpose of delivering the site securely and diagnosing faults. We do not use that data to identify individuals.

6. Who we disclose it to

We may disclose personal information to:

• our professional advisers — accountants, auditors, lawyers, insurers and brokers — where necessary for the matter concerned;
• entities within the group we hold, where the disclosure relates to that entity;
• service providers who host our email and website, under obligations of confidentiality; and
• a government agency, court or regulator where we are required or authorised by law to do so.

7. Overseas disclosure

Our email and website hosting providers may store data on servers located outside Australia. Before disclosing personal information to an overseas recipient, we take the steps reasonable in the circumstances, as required by APP 8, to ensure the recipient does not breach the APPs in relation to that information.

8. Storing and securing personal information

We hold personal information in electronic form in access-controlled systems, and in paper form where a signed original is required. We take reasonable steps to protect it from misuse, interference, loss and unauthorised access, modification or disclosure, including access restrictions, reputable providers and regular review of who holds what.

No method of transmission or storage is completely secure. Email in particular is not a secure channel, so please consider what you send us by email.

9. How long we keep it

We keep enquiry correspondence only for as long as it is useful for the matter it relates to, and we destroy or de-identify it when it is no longer needed and we are not required to retain it. Transaction and corporate records are kept for the periods required by the Corporations Act 2001 (Cth) and tax law — generally at least seven years — after which they are securely destroyed.

10. Accessing and correcting your information

Under APP 12 and APP 13 you may ask us for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Write to [email protected]. We will respond within a reasonable period, normally 30 days. We do not charge for making a request; if a fee applies to giving access, we will tell you what it is before we proceed. If we refuse access or correction, we will tell you why in writing and explain how to complain.

11. Anonymity and pseudonymity

Under APP 2 you may deal with us anonymously or under a pseudonym where it is lawful and practicable. In most cases we will need your name and contact details in order to respond usefully to an enquiry or to complete a transaction.

12. Complaints

If you believe we have breached the Privacy Act or the APPs, please complain to us first at [email protected], setting out what happened. We will acknowledge your complaint, investigate it and respond in writing within a reasonable period.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC), the independent regulator for privacy in Australia, at oaic.gov.au, by telephone on 1300 363 992, or by writing to GPO Box 5218, Sydney NSW 2001.

13. Notifiable data breaches

If we have reasonable grounds to believe an eligible data breach has occurred that is likely to result in serious harm, we will notify affected individuals and the OAIC as required by the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.

14. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or the law. The current version is always the one published on this page, with the date it was last updated shown above.

15. Contact us

Privacy enquiries, access requests and complaints should be sent to [email protected], marked for the attention of the Privacy Officer, Zhuge Holdings Pty Ltd, VIC 3145, Australia.