1 INTRODUCTION

Stirling & Rose Pty Ltd (“Stirling & Rose”, also “we” and “us”) is committed to respecting and ensuring the privacy of information provided to us and information about visitors to this website. This Privacy Policy explains how we collect and use information that we obtain about you. It sets out how we collect and treat your personal information when you interact in various ways with us.

This Policy was made on 17 May 2023. We review it regularly and may revise it from time to time to keep up to date with developments in the law or technology practices. You may contact us in writing for further information about this Privacy Policy. By using this website, you acknowledge and agree to the terms of this Privacy Policy.

Capitalised terms in this Privacy Policy unless otherwise defined have the meaning given to them in the Terms of Use for our website which can be found here.

2 OUR COMMITMENT TO PRIVACY, SECURITY, AND RESPONSIBLE DATA STEWARDSHIP

Stirling & Rose is committed to be a leader in the field of data stewardship. We take seriously our obligation to ensure that your data is handled in accordance with the principles of accountability, privacy and security, and fair value exchange. We understand data stewardship as achieving a balance between the interests of data subjects, innovative entities such as Stirling & Rose who gather and aggregate data, and the common good.

Fundamentally, we will not collect data about you that we do not need for some legitimate purpose. We will seek to collect only that data which is needed for the purpose we collect it, and will not use it for other purposes. Insofar as possible, and where reasonable, access, control, and benefits from your data will remain with you under the principle of data self-sovereignty. Exceptions to this include authorised requests by competent authorities as set out in this policy.

3 SCOPE

This Privacy Policy applies when we receive any personal information from you, including:

a. when you visit this website;

b. when you request information from us or provide information to us;

c. when you engage our Services;

d. when you are a counterparty, or provide services to a counterparty, of one or more of our clients;

e. as a result of your relationship with one or more of our clients, including when you or the organisation you work for is a regulator, government agency, court, tribunal or other law enforcement agency;

f. when you apply for a role or work placement opportunity, open day or recruitment event with us;

g. when you complete forms on this website;

h. when you register for and attend one of our events (such as a webinar);

i. when we conduct searches on you in connection with our business acceptance or business development processes; and

j. when you are entered onto our mailing lists to receive publications and other informational, educational, or marketing emails.

If you are an individual who works for an organisation, we may receive personal information about you when your organisation is a client user or a counterparty or otherwise transmits information to Stirling & Rose.

4 INFORMATION COLLECTION

We may collect personal information directly from you, from our clients or their authorised representatives. We may also collect personal information from third parties including:

a. regulatory authorities;

b. your employer;

c. other orginsations with whom you have dealings;

d. government agencies;

e. credit reporting agencies;

f. recruitment agencies;

g. information or service providers;

h. publicly available records; and

i. other third parties as set out or implied in this Privacy Policy.

We may collect current and historical personal information including:

a. your name (including name prefix or title);

b. contact details (such as your postal address (including country), email address and phone numbers);

c. information about you such as your nationality, identification, gender, organisation, business interests, employment, positions held;

d. special categories of data (such as race and ethnicity, trade union membership, information about health or information, political opinions or religious beliefs);

e. billing and financial information (such as billing address, bank account and payment information); and

f. enquiry/complaint details.

We may also collect personal information about your other dealings with us and our clients, including any contact we have with you in person, by telephone, email or online.

When you use our Services, we may collect:

a. information you provide by completing subscription, registration and application forms (including when you submit material or request further services (including the Services));
b. details of visits made to our Services such as the volume of traffic received, logs (including, the IP address and location of your device and other identifiers about the device and the nature of the visit) and the resources accessed; and
c. information provided to us when you contact us to report a problem or raise a query or comment.

If you are an individual who works for an organisation, we may collect personal information about you when your organisation is a client or a counterparty or otherwise transmits information to Stirling & Rose.

5 USE OF YOUR INFORMATION

We use your personal information where such use is:

a. necessary for the performance of a contract with you (or your organisation);

b. necessary in connection with a legal or regulatory obligation;

c. with your consent;

d. pursuant to a legitimate interest of Stirling & Rose which is not overridden by your rights or interests; or

e. otherwise required or authorised by law (for example, for a fraud detection purpose).

We may use your information to:

a. provide and improve our Services (including auditing and monitoring use of those Services and products);

b. maintain and develop our relationship with you and our clients;

c. monitor and analyse our own business or facilitate our business operations;

d. fulfil our legal, regulatory, accounting, reporting, risk management or professional obligations;

e. identify services you may be interested in;

f. send you updates, publications, marketing and details of events we offer; or

g. protect, establish, exercise or defend legal rights; or

h. process and respond to requests, enquiries or complaints received from you; and

i. any other thing that is reasonably required to provide legal services.

We will work to retain your personal information only so long as reasonably necessary. If you wish to know more, please contact us.

6 INFORMATION DISCLOSURE

Excluding any confidential client user information (unless you as the client user have otherwise agreed), we may share your information with third parties including:

a. Our clients, your professional advisers and your employers or place of business;

b. third parties involved in the provisions of Services to clients including barristers, local counsel and other professional advisers;

c. our affiliates, professional advisers, auditors and insurers;

d. third party service providers to whom we outsource services (including the Services), for example archival, auditing, reference checking, professional advisory (including legal, accounting, financial and business consulting), IT support, mailing house, delivery, website, social media, research, banking, payment, contact, data processing, insurance, forensic, litigation support, data room, marketing and security services;

e. third party technology organisations, including cloud service providers, such as data storage platforms;

f. third parties with whom we have co-promotional arrangements (such as jointly sponsored events);

g. third parties who carry out research and analyses of our Services and products on our behalf; or

h. regulatory authorities, courts, tribunals, government agencies, law enforcement agencies and other third parties.

Some of your personal information may be stored with and managed by a cloud service provider located outside of Australia. Your personal information may be accessed by third parties whose laws provide various levels of protection for personal data which may be higher or lower than the level of protection stipulated in Australia. Where we transfer your information internationally, we will take reasonable steps to ensure that your information is treated securely and that the means of transfer provides adequate safeguards. If you have any questions in relation to the transfer of your personal information, please contact us by email at info@stirlingandrose.com

7 SECURITY

We take reasonable steps to hold information securely and to prevent unauthorised access, modification or disclosure. Our information security policy is supported by a number of security standards, processes and procedures. We require our third party data storage providers to comply with appropriate industry standards. All partners and staff and third party providers with access to confidential information are subject to confidentiality obligations.

The transmission of information via the Internet is never completely secure. We cannot guarantee the security of your data transmitted to our Services. By using these Services, you accept the inherent risks of transmission.

8 COOKIES

Cookies are small text files that are stored on your device by the websites you visit. They are used in order to make websites work and to improve their efficiency, as well as to provide website usage information to the website owner.

This website may use “cookies”, where we do so, Stirling & Rose enables and respects “Do Not Track” requests and will limit the cookies we use to the following:

a. Strictly necessary cookies to protect the Website against DDoS attacks.

b. Strictly necessary cookies to facilitate user logins and protect the Website against attempts to inject malicious code into registration forms.

c. Performance cookies to provide us with analytical information about the use of the website with your consent.

You can remove cookies from your browser and prevent new cookies from being placed on your device by going to the privacy settings of your browser. You can choose to block all cookies or only cookies from specific websites. Please note that blocking cookies will not automatically remove cookies that are already stored on your device.

Please be aware that by blocking and/or deleting cookies, this website (and possibly other websites) might not function properly. With every new session, new cookies will be placed unless you have blocked the use of cookies. If you choose to block cookies, but also want this website to function properly, please go to the privacy settings of your browser and ensure that it allows cookies from this website.

9 THIRD PARTY SITES

Our website may contain links to other sites controlled by third parties, which may also use cookies over which we have no control. We recommend that you check the relevant third party’s privacy policies for information about any cookies which may be used. Although we provide the links for informational or convenience purposes, we do not accept responsibility for their use of information about you.

10 YOUR RIGHTS

The privacy laws of some jurisdictions may give you the right to access, amend or erase your personal information or, in some circumstances, to restrict or object to the processing of your personal information.

If you would like to request a copy of your data, or would like to take steps to exercise any of your rights please contact us by email at info@stirlingandrose.com

Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the rights to withdraw your consent for that specific processing at any time.

Information we hold about you should be up-to-date and accurate. Please advise us in writing of any changes to your information.

Where relevant, you can withdraw your consent for us to send marketing, informational, and educational materials to you by using the “unsubscribe” option included in the email or other material.

11 CONTACT AND FURTHER INFORMATION

It is important to us that you understand how your personal information is collected, stored, used, and disclosed. If you have any questions about this Privacy Policy, or want to submit a suggestion or complaint to us about how we handle your personal information, please contact us.

Stirling & Rose Pty Ltd

Attention: Privacy Officer

Telephone: +61 478 488 938

Email: info@stirlingandrose.com