Privacy Policy

Last updated 27 February 2025

Our privacy policy is also available in PDF format here.

1.      Our Commitment to Privacy

 Clean TeQ Water Limited (Clean TeQ) recognises the importance of privacy and is committed to protecting the privacy of its shareholders, employees, and other related parties when handling your personal information. From the outset, it should be noted that all information or opinion about you as an identified, or reasonably identifiable, individual (that is in Clean TeQ’s control) is handled and managed with the utmost confidentiality by Clean TeQ.

2.      Purpose

This Privacy Policy explains how Clean TeQ and other companies in the Clean TeQ Group (collectively referred to as “Group”) collect, hold, use, disclose, protect and otherwise handle your personal information and credit information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and any applicable international privacy standards.

3.      Terminology

 In this policy the expressions ‘the Company’, ‘we’, ‘it’, ‘us’, and ‘our’ are a reference to Clean TeQ.

4.      What is Personal Information?

 The expression ‘personal information’ used in this policy relates to information or an opinion about you from which you can be reasonably identified;

• whether the information or opinion is true or not; and
• whether the information or opinion is recorded in a material form or

5.      What is Sensitive Information?

 The expression ’sensitive information’ relates to personal information about a person’s racial or ethnic origin, political opinions or affiliations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record or health, genetic, genomic and biometric information. Sensitive Information can be inferred from information which is not sensitive information.

6.      Why do we collect Personal Information?

 The Company only collects personal information when it is reasonably necessary for one or more of our functions, operations, or activities. or to comply with our legal obligations (Primary Purpose).

The types of personal information we collect and, how it is collected, stored, used and disclosed, will depend on the specific circumstances. We collect and process personal information to deliver our services and/or products, manage business operations, fulfill employment and contractor obligations, support emergency management, assess applications from prospective employees, contractors, or service providers and ensure compliance with applicable laws and regulatory requirements..

7.      What kinds of Personal Information do we collect?

 Depending on the circumstance, below are the types of personal information which Clean TeQ may collect and hold include, without limitation:

• Contact details: Name, address, telephone numbers, and email address;
• Identification details: Date of birth, current or previous addresses, and any other identifiers permitted under applicable laws;
• Business information: Australian Business Number (’ABN’), trade references, trade references, and other relevant business details;;
• Financial information: Tax File Number (‘TFN’) (collected and used in accordance with the Privacy (Tax File Number) Rule 2015), bank account details, billing and credit card information;
• Service-related information: Records of acquired or supplied products and services, including transaction history;
• Enquiry records: communications between you and the Company, including customer support or complaint records.

Generally, the Company does not collect sensitive information about you. If the Company needs to collect sensitive information, it will obtain your explicit consent when it collects this information and comply with the APPs and other relevant legislative requirements.

8.      Cookies and Website Data Collection

 When you visit our websites, we may automatically collect certain information through cookies or similar tracking technologies, including:

• IP address or server address;
• Top-level domain name (for example, .com, .gov, .au);
• Date and time of your visit to the site;
• Pages you accessed;
• Previous site you visited, before reaching our site (if applicable); and
• Browser type and device

We use cookies to:

• Enable essential website functionality and security;
• Improve website performance, functionality and user experience;
• Analyse site traffic, trends, user interactions for business insights; and
• Ensure compliance with our legal and regulatory

You can manage or disable cookies through your browser settings. However, restricting cookies may impact website functionality and your browsing experience. .

9.      How we collect Personal Information?

 Collecting information from you

 How the Company collects your personal information will largely depend on the nature of the information and whose information it is collecting. If it is reasonable and practicable to do so, the Company will collect personal information directly from you in a number of ways including:

• Direct interactions (e.g. employee inquiries, website forms, other direct communications:
• Third party- (e.g. contractors, recruitment service providers, share registry services); and
• Publicly available records (where applicable and permitted by law).

If we receive unsolicited personal information that is not necessary for our business purposes or legal obligations, we will take reasonable steps to de-identify or securely destroy it, in compliance with our data handling obligations.

Providing personal information is voluntary, but failure to do so may affect our ability to provide some or all of our goods or services to you.

When you provide the Company with personal information, you consent to the use, disclosure, and handling of your personal information in accordance with this Privacy Policy, applicable laws and any subsequent amendments.

Collecting information from visits to the Company’s website

 The Company may collect information based on how you use its website including through ‘cookies’, web beacons and other similar technologies.

Unsolicited information

 If the Company receives personal information that it has not requested, or it determines that the personal information received is not reasonably necessary to provide its services, the Company will take reasonable steps to de-identify or destroy that personal information.

10.   How we hold your Personal Information and Protect Your personal information

 The security of your personal information is of paramount importance to the Company and it takes reasonable steps to protect the personal information it holds about you from misuse, loss, unauthorised access, modification or disclosure.

The Company has a number of safeguards in place to protect the personal information we hold, including password protected databases, staff training, and system firewalls. The Company maintains password security and restricted access to all electronic documents containing personal information

Third-party data security: Our payroll is outsourced to a third-party provider, ADP Australia which limits data collection and use of necessary business purposes.

Personal Data is retained in accordance with the records retention schedules to ensure that records containing Personal Data are retained as needed to fulfill the applicable Business Purposes, to comply with applicable laws, or as advisable in light of applicable statutes of limitations.

The Company will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purpose for which the information was used or disclosed.

11.   How we use your Personal Information

 The Company will not use or disclose personal information that we collect for any purpose other than the primary purpose of collection unless:

• such use is related to the primary purpose and you would reasonably expect us to use or disclose the information for that other purpose;
• in the case of direct marketing not related to our core business activities – we have obtained your prior consent (unless it is not reasonably practicable to seek your consent, in which we will comply with the requirements of the Privacy Act, including your rights to opt-out); or
• the use or disclosure is otherwise permitted under the Privacy Act or required to comply with any relevant laws, regulations, codes or practice and court orders.

As a general rule, we do not engage in direct marketing activities. To the extent that we do engage in direct marketing in the future, however, you may at any time opt-out of receiving any further direct marketing communications by contacting us via the details set out below.

By using our website, you will be deemed to consent to us using your personal information collected by our website for the following purposes:

• notifying you about any changes to the information which currently exists on the website;
• notifying you in the future about new information relevant to our services; and
• monitoring your use of our website

12.   Disclosure of Personal Information

 The Company does not sell, rent or trade personal information to, or with, third parties.

The Company’s website may contain links to other websites. The Company does not share your personal information with those websites, and it is not responsible for their privacy practices.

In some circumstances, your personal information may be disclosed to service providers that perform a range of services on behalf of the Company including:

• mailing houses and printing companies;
• auditors, solicitors, and
• share registry providers;
• information technology vendors; and
• Government agencies when legally required.

Personal information may be disclosed to third parties within or outside of Australia.

When making public or disclosing information that was prepared using personal information, where practical we will de-identify, aggregate or anonymise the information to remove the personal information.

If the Company transmits your personal information over the internet (for example to third parties who hold data outside Australia) we will take reasonable steps to maintain the security of any personal information to prevent misuse and unauthorised access. Despite these protection mechanisms, you should be aware there are inherent risks associated with the transmission of data over the internet and we cannot guarantee any transmission will be completely secure.

Where the Company discloses your personal information to its service providers, it will take steps to ensure that they are authorised to only use personal information in order to perform the functions required by the Company or you and in accordance with the Privacy Act 1988 (Cth).

The Company may also disclose your personal information to law enforcement agencies, courts or government agencies where required to comply with specific legal requirements. In particular, the Corporations Act 2001 (Cth) requires certain information about you to be included in the Company’s registers which are able to be accessed by the public.

13.   Cross-border data transfers

 The Company will ensure that any transfer of personal information complies with the Privacy Act 1988 (Cth), including the Australian Privacy Principles, and, where applicable, international data transfer regulations. The Company will implement appropriate safeguards, including contractual obligations, encryption, access controls, and data minimization measures, to ensure the security and integrity of transferred data.

Our website is currently hosted in Australia. However, if website hosting or technical support services involve offshore providers, the Company will take reasonable steps to ensure that these providers comply with the Australian Privacy Principles and applicable data protection laws. This includes conducting due diligence, implementing contractual safeguards, and ensuring the secure handling of personal information.

14.   Data Security and Retention

 We take reasonable steps to protect the personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. Any personal information which is no longer required for its intended purpose or to meet legal or regulatory obligations, it will be securely destroyed de-identified in accordance with applicable laws.

The Company will also take reasonable steps to ensure that personal information shared with third- party service providers, such as ADP, has implemented reasonable technical, physical, and administrative safeguards to protect the sensitive personal information stored within their systems from unauthorised access, unlawful use, and unauthorized disclosure. Where relevant, the effectiveness of the safeguards and controls in place with third party providers will be reviewed, such as obtaining annual independent System and Organisation Control (SOC) reports or or equivalent assessments.

In the event of a data breach, will comply with our obligations under the Notifiable Data Breaches (NDB) scheme by promptly assessing the incident, notifying affected individuals if the breach is likely to result in serious harm, and reporting the matter to the office of the Australian Information Commissioner (OAIC) as required by law.

15.   Keeping Your Personal Information up to date

 It is important that the personal information we collect from you is accurate, complete and up to date.

During the course of our relationship with you, we will ask you to tell us of any changes to your personal information. You may contact us at any time to update or correct your personal information.

16.   Access, Correction and Further Information

 We will provide you with access to your personal information held by us, unless we are permitted under the Privacy Act to refuse to provide you with such access. Please contact us on the details below if you:

• wish to have access to the personal information which we hold about you;
• consider that the personal information which we hold about you is not accurate, complete or up to date; or
• require further information on our personal information handling

If you believe that the Company has not protected your personal information as set out in this privacy policy or has denied you access to your personal information in potential breach of the Privacy Act, you may lodge a complaint by writing directly to the Company. We will endeavour to respond to your request within 30 days. All such complaints will be handled with the appropriate discretion.

If you are not satisfied with the result of your complaint to the Company or if your complaint remains unresolved, you may access an external dispute resolution service or apply to the OAIC at www.oaic.gov.au to have the complaint heard and determined.

Further information on the Act and the Australian Privacy Principles, can be found at www.oaic.gov.au

17.   How to Contact Us?

 All correspondence should be directed to the Privacy Officer on:

Tel:              +61 3 9797 6700

E-Mail:         [email protected]

Mail: Clean TeQ Water Limited PO Box 227,  Mulgrave VIC 3170

18.   Disclosure

 From time to time, we may change our policy on how we handle personal information or the sort of personal information which we hold. Any changes to our policy will be published on our website www.cleanteqwater.com.

19.   Approved and Adopted

 This policy was reviewed, approved and adopted by the Board on 27 February 2025.

Revision Status: