Privacy Policy

1. Scope

This Privacy Policy applies to all personal information we collect through our website, via email, telephone communications, in-person interactions, forms, and any other channels used in the course of conducting our business activities.

By providing your personal information to us, or by accessing or using our website or services, you confirm that you have read, understood, and accepted the terms of this Privacy Policy.

2. What Information We Collect

We are committed to protecting the privacy of the personal information entrusted to us and any information we are required to collect under applicable laws.

We collect personal information that is reasonably necessary to operate our business, deliver our services, and comply with our legal obligations. The nature of the information collected will vary depending on how you interact with us and may include:

• your name;
• contact details, including your email address, telephone number, and postal or mailing address;
• employment or business information, where relevant;
• details relating to vessels, ports, and vessel agents;
• records of your communications and correspondence with us;
• information you provide when completing forms on our website, making enquiries, or subscribing to our newsletters or mailing lists;
• any other personal information you choose to provide to us; and
• credit-related personal information (excluding sensitive information), including information that constitutes "credit information", "credit reporting information", "credit eligibility information", or "regulated information" as those terms are defined in the Privacy Act 1988 (Cth).

In some circumstances, we may collect sensitive information, but only where permitted by law and, where required, with your consent.

3. How We Collect Information

We primarily collect personal information directly from you through your interactions with us. This may occur when you:

• contact us by telephone, email, through our website, or by other communication channels;
• communicate or correspond with us in writing, including as part of our "Know Your Customer" (KYC) procedures using letters, emails, online chat, Google Forms, Microsoft Forms, or similar platforms;
• request information about, or purchase, our products or services;
• use our website, products, services, or other features we make available;
• engage, collaborate, or communicate with us in connection with our business activities; or
• correspond with us regarding an existing or prospective business relationship or engagement.

In some circumstances, we may also collect personal information from third parties, including contractors, service providers, business partners, authorised representatives, or other sources where it is reasonably necessary for our business operations, where you have authorised the collection, or where otherwise permitted or required by applicable law.

4. Why We Collect Information

We collect, hold, use, and disclose personal information where it is reasonably necessary to carry out our business activities, provide our products and services, and meet our legal and regulatory obligations. The purposes for which we collect personal information include:

• providing, delivering, and managing our products and services;
• responding to enquiries, requests, and other communications;
• maintaining customer records and managing our relationship with you;
• processing orders, transactions, and customer accounts;
• administering our business, including payment processing, billing, accounting, auditing, credit assessments, and the provision of customer support services;
• conducting statistical analysis, business planning, and improving our products, services, website, and internal operations;
• sending important administrative communications, service updates, and other notices relevant to our relationship with you;
• assessing creditworthiness, managing credit-related matters, and resolving complaints or disputes; and
• complying with applicable laws, regulations, contractual obligations, and other legal requirements.

Where we collect personal information directly from you, we will take reasonable steps to provide you with any notifications required under applicable privacy laws, including who we are, why we are collecting the information, whether the collection is required or authorized by law, the consequences of not providing the requested information, and the categories of third parties to whom we may disclose it.

5. Use and Disclosure

We use and disclose personal information for the purpose for which it was collected, as well as for related purposes that you would reasonably expect, or where otherwise permitted or required by applicable law.

This may include using or disclosing information for:

• provide, administer, and improve our products and services;
• respond to your enquiries, requests, and correspondence, including providing information, publications, or services you have requested;
• communicate with you about our products, services, business updates, or changes to our operations;
• maintain our business records and manage our relationship with you;
• investigate and resolve complaints, disputes, or other requests;
• provide technical support, administer our information systems, and maintain our website and digital services;
• conduct internal administration, compliance, governance, risk management, auditing, and legal functions;
• assess creditworthiness and manage credit-related matters, where applicable;
• enable our insurers to assess or provide insurance in connection with commercial credit or other business activities;
• undertake market research, business analysis, and statistical reporting to improve our products and services; and
• send you marketing communications or promotional material relating to our products and services, where permitted by law. You may opt out of receiving direct marketing communications at any time.

We may disclose your personal information to our employees, directors, officers, contractors, and authorized representatives; third-party service providers (IT, hosting, payment, analytics, marketing); professional advisers including insurers, auditors, and legal advisers; credit providers or credit reporting bodies where authorised; government agencies or regulatory authorities where required by law; and any other person where you have given your consent.

6. Permitted Disclosures

In addition to uses and disclosures for the primary purpose of collection, we may use or disclose personal information where permitted or required by law, including circumstances where:

• you have consented to the use or disclosure;
• we reasonably believe the use or disclosure is necessary to lessen or prevent a serious threat to life, health, or safety;
• we reasonably suspect unlawful activity and the use or disclosure is necessary for investigation or reporting purposes;
• the use or disclosure is required or authorised by law, including under a court order, subpoena, warrant, or other legal process; or
• the use or disclosure is reasonably necessary for law enforcement or other authorised bodies in connection with crime prevention, investigation, prosecution, punishment, or related proceedings.

7. Direct Marketing

We may use your personal information to provide you with updates, information about our products and services, promotional communications, and other marketing material where permitted under applicable privacy laws.

You may choose not to receive direct marketing communications from us at any time by using the unsubscribe facility provided in our communications or by contacting us directly. We will take reasonable steps to process your request and update our records accordingly.

8. Data Quality

We take reasonable measures to ensure that the personal information we hold, use, and disclose is accurate, complete, relevant, and current, having regard to the purpose for which the information is collected and maintained.

Where appropriate, we rely on you to provide accurate and up-to-date information and encourage you to notify us if any of your personal information changes or if you believe the information we hold about you is inaccurate, incomplete, or outdated.

9. Security and Retention

We are committed to protecting the personal information we hold and take reasonable steps to safeguard it against misuse, interference, loss, unauthorised access, alteration, or disclosure. These measures may include access controls, secure storage, internal policies, and staff training.

Personal information is retained only for as long as reasonably necessary for the purposes for which it was collected or as otherwise required by law. When information is no longer required, we will take reasonable steps to securely destroy or de-identify it, where lawful and appropriate.

10. Access and Correction

You have the right to request access to the personal information we hold about you, subject to any limitations or exceptions permitted under applicable privacy laws. We will consider and respond to your request within a reasonable timeframe and in accordance with our legal obligations.

If you believe that any personal information we hold about you is inaccurate, incomplete, outdated, irrelevant, or misleading, you may request that we update or correct the information. We will take reasonable steps to review your request and ensure that the information is corrected where appropriate.

11. Cookies and Analytics

Our website may use cookies and similar tracking technologies to enhance website functionality, improve user experience, analyse website usage, and better understand how visitors interact with our website.

Cookies are small data files stored on your device that help us recognise returning visitors, remember preferences, monitor website performance, and gather statistical information about website traffic and usage patterns.

You may choose to manage or disable cookies through your web browser settings. However, please note that restricting or disabling cookies may affect the availability, functionality, or performance of certain features of our website.

12. Third-Party Links

Our website may contain links to websites, applications, or services operated by third parties. These third-party sites are independent from us, and we do not control or accept responsibility for their content, privacy practices, security measures, or the way they collect, use, or handle personal information.

We recommend that you review the privacy policies and terms of use of any third-party websites or services you access through links on our website before providing any personal information.

13. Overseas Disclosure

In certain circumstances, we may disclose personal information to overseas recipients, including third-party service providers, where necessary for our business operations or the provision of our services.

Where required under applicable privacy laws, we will take reasonable steps to ensure that any overseas recipient handles personal information in accordance with appropriate privacy standards and obligations.

The countries in which overseas recipients are located may vary depending on the service providers and technologies we use from time to time.

14. Complaints

If you have any concerns or wish to make a complaint regarding the way we have collected, used, stored, or handled your personal information, please contact us using the contact details provided below.

We will acknowledge, investigate, and respond to your complaint within a reasonable timeframe and in accordance with our obligations under applicable privacy laws.

If you are not satisfied with our response or the way we have handled your complaint, you may have the right to refer the matter to the Office of the Australian Information Commissioner (OAIC) or another relevant regulatory authority for further consideration.

15. Changes to This Policy

We may update or amend this Privacy Policy from time to time to reflect changes to our business practices, services, legal requirements, or privacy obligations. The revised version will be published on our website, and the "Last updated" date will be changed accordingly.

We reserve the right to make changes to this privacy policy from time to time. We encourage you to review this Privacy Policy periodically to stay informed about how we manage and protect your personal information.