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.
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:
Generally, we will seek consent from the individual in writing before we collect their sensitive 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.
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.
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:
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.
We only collect sensitive information if it is:
We may share sensitive information to other entities in our company group, but only if necessary for us to provide our products or services.
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:
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:
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.
We store personal information in a variety of formats including, but not limited to:
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:
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.
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.
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:
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;
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 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.
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.
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.
We can be contacted about this Privacy Policy or about Personal Information generally, by:
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.
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