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Privacy Policy

Privacy Act: Privacy Statement

This Privacy Statement explains how Luna Partners Pty Ltd ACN 663 041 156 (Luna Partners) and each of  its related bodies corporate (we, us, our) handle personal information.

What is Personal Information and how do we collect it?  

For the purposes of this Privacy Statement, the term ‘personal information’ has the same meaning as  provided in the Privacy and Data Protection Act 2014 (Cth), that being information or an opinion about an  individual whose identity is apparent, or can reasonably be identified, from the information or opinion.  Depending on the circumstances, we may collect personal information from the individual in their capacity  as a client, contractor, stakeholder, job applicant or in some other capacity. 

In the course of providing products and services we may collect and hold:  

  • Personal Information including names, addresses and other contact details; dates of birth; and  financial information. 
  • Sensitive Information including government identifiers (such as TFN), nationality, country of birth,  professional memberships, family court orders and criminal records. As part of our recruitment processes for employees and contractors, we may collect and hold: 
  • Personal Information including names, addresses and other contact details, dates of birth, financial  information, citizenship, employment references, regulatory accreditation, media, directorships,  property ownership and driver’s licence information. 
  • Sensitive Information including government identifiers (such as TFN), nationality, country of birth,  professional memberships, family court orders and criminal records.  

Generally, we will seek consent from the individual in writing before we collect their sensitive  information.

Collection of Personal Information 

The collection of personal information depends on the circumstances in which Luna Partners is  collecting it. If it is reasonable and practical to do so, we collect personal information directly from the  individual.  

Solicited Information 

We have, where possible, attempted to standardise the collection of personal information by using  specifically designed forms. However, given the nature of our operations we often also receive personal  information by email, letters, notes, via our website, over the telephone, in face-to-face meetings and  through financial transactions.  

We may also collect personal information from other people (e.g. a third-party administrator, referees  for prospective employees) or independent sources. However, we will only do so where it is not  reasonable and practical to collect the personal information from the individual directly.  

We may collect information based on how individuals use our website. We use ‘’cookies’’ and other data  collection methods to collect information on website activity such as the number of visitors, the number  of pages viewed and the internet advertisements which bring visitors to our website. This information is  collected to analyse and improve our website, marketing campaigns and to record statistics on web  traffic. We do not use this information to personally identify individuals.  

Individuals who access their accounts online through a secure area of our website, will have their  personal information collected using cookies. This is designed to track the use of our website and to  allow individuals to effectively access their account information. This information is collected for  security purposes and to protect the integrity of account details.

Unsolicited information 

We may be provided with personal information without having sought it through our normal means of  collection. This is known as “unsolicited information” and is often collected by: 

  • misdirected postal mail – Letters, Notes, Documents; 
  • misdirected electronic mail – Emails, electronic messages; 
  • employment applications sent to us that are not in response to an advertised vacancy; or 
  • additional information provided to us which was not requested. 

Unsolicited information obtained by us will only be held, used and or disclosed if it is considered as  personal information that could have been collected by normal means. If that unsolicited information  could not have been collected by normal means then we will destroy, permanently delete or de-identify  the personal information as appropriate.

Collection and Use of Sensitive Information  

We only collect sensitive information if it is: 

  • reasonably necessary for us to provide our products, services or perform our functions or  activities, and we have the individuals consent; 
  • necessary to lessen or prevent a serious threat to life, health or safety; or 
  • reasonably required in another permitted situation. 

We may share sensitive information to other entities in our company group, but only if necessary for us  to provide our products or services.  

How do we use and store Personal Information?  

We only use personal information that is reasonably necessary for one or more of our functions or  activities (the primary purpose) or for a related secondary purpose that would be reasonably expected  by the individual, or for an activity or purpose which the individual has consented. 

Our uses of personal information include, but are not limited to: 

  • providing one or more of our financial services or products;
  • assessing an application for a financial product or service; and/or 
  • communicating with the individual about the products and services that we offer. 

We may also need to collect personal information to comply with our legal obligations, such as under  the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act and AML/CTF  Rules).  

It may be necessary for us to disclose personal information to certain third parties in order to assist us  with one or more of our functions or activities. This may include organisations providing: 

  • fund administration services; and/or 
  • custodial services. 

We may share personal information with other bodies corporate within our company group, but only if  necessary for us to provide our products or services.  

Storage and Security of Personal Information 

We store personal information in a variety of formats including, but not limited to:

  • databases; 
  • hard copy files; 
  • personal devices, including laptop computers; 
  • third party storage providers such as cloud storage facilities; and 
  • paper based files. 

We take all reasonable steps to protect the personal information we hold from misuse, loss,  unauthorised access, modification or disclosure. 

These steps include, but are not limited to: 

  • restricting access and user privilege of information by staff depending on their role and  responsibilities; 
  • ensuring staff do not share personal passwords; 
  • ensuring hard copy files are stored in lockable filing cabinets in lockable rooms. Staff access is  subject to user privilege;  • ensuring access to our premises is secured at all times; 
  • ensuring our IT and cyber security systems, policies and procedures are implemented and up to  date; 
  • ensuring staff comply with internal policies and procedures when handling the information; 
  • undertaking due diligence with respect to third party service providers who may have access to  personal information, including customer identification providers and cloud service providers, to  ensure as far as practicable that they are compliant with the Australian Privacy Principles or a  similar privacy regime; and 
  • the destruction, deletion or de-identification of Personal Information we hold that is no longer  needed, or required to be retained by any other laws. 

Our public website may contain links to other third-party websites outside of Luna Partners. We are not  responsible for the information stored, accessed, used or disclosed on such websites and we cannot  comment on their privacy policies.  

Responding to data breaches 

We will take appropriate, prompt action if we have reasonable grounds to believe that a data breach  may have, or is suspected to have occurred. Depending on the type of data breach, this may include a  review of our internal security procedures, taking remedial internal action, notifying affected individuals  and the Office of the Australian Information Commissioner (OAIC). 

If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.

Disclosure of Personal Information 

Personal Information is used for the purposes for which it was given to us, or for purposes which are  directly related to one or more of our functions or activities. 

Personal information may be disclosed to government agencies, related entities and other recipients  from time to time, if the individual: 

  • has given consent; or 
  • would reasonably expect the personal information to be disclosed in that manner. 

We may disclose personal information without consent or in a manner which an individual would  reasonably expect if:  

we are required to do so by law; 

  • the disclosure will lessen or prevent a serious threat to the life, health or safety of an individual  or to public safety; 
  • another permitted general situation applies; or 
  • disclosure is reasonably necessary for a law enforcement related activity. 

Disclosure of your personal information to overseas recipients 

Personal information about an individual may be disclosed to an overseas organisation in the course of  providing our services, for example when storing information with a “cloud service provider” which  stores data outside of Australia. It is not practicable for us to specify what those overseas countries are  at this time. 

We will however take all reasonable steps not to disclose an individual’s personal information to  overseas recipients unless: 

  • we have the individual’s consent (which may be implied); 
  • we have satisfied ourselves that the overseas recipient is compliant with the Australian Privacy  Principles, or a similar privacy regime;  
  • we form the opinion that the disclosure will lessen or prevent a serious threat to the life, health  or safety of an individual or to public safety; or 
  • we are taking appropriate action in relation to suspected unlawful activity or serious  misconduct. 

The Quality of Personal Information  

We take all reasonable steps to ensure the Personal Information we hold, use and disclose is accurate,  complete and up-to-date, including at the time of using or disclosing the information.  

If we become aware that the Personal Information is incorrect or out of date, we will take reasonable  steps to rectify the incorrect or out of date information. 

Access and Correction of Personal Information 

Individuals may submit a request to us to access the Personal Information we hold, or request that we  change the personal information. Upon receiving such a request, we will take steps to verify the  individual’s identity before granting access or correcting the information.  

If we reject the request, you will be notified accordingly. Where appropriate, we will provide the  reason/s for our decision. If the rejection relates to a request to change personal information, an  individual may make a statement about the requested change and we will attach this to their record.

Complaints  

An individual can make a complaint about how we manage personal information by notifying us in writing as soon as possible. We will respond to the complaint within a reasonable time (usually no longer than 30 days), and we make seek further information in order to provide a full and complete response. 

We do not charge a fee for the handling of complaints. 

If the individual is not satisfied with our response, they may refer the complaint to the OAIC. A complaint can be made using the OAIC online Privacy Complaint form or by mail, fax or email. 

A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted. 

How to Contact Us 

We can be contacted about this Privacy Policy or about Personal Information generally, by: 

  • emailing luna@lunapartners.com.au; or  
  • writing to our Privacy Officer at Luna Partners, L 8 1-7 Castlereagh St, Sydney, NSW 2000.

If practical, you can contact us anonymously (i.e. without identifying yourself) or by using a pseudonym. However, if you choose not to identify yourself, we may not be able to give you the information or provide the assistance you might otherwise receive if it is not practical to do so. 

Changes to our privacy and information handling practices 

This Privacy Policy is subject to change at any time. Please check our Privacy Policy on our website  (www.lunapartners.com.au) regularly for any changes. 

This Privacy Policy was last reviewed: 17 February 2023

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Sydney • Melbourne

luna@lunapartners.com.au

Copyright © Luna Partners 2025
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