Privacy Policy

1. Purpose

CSO Group Pty Ltd (referred to as CSO, “we”, “us”, “our” including any related bodies corporate) respects and is committed to protecting everyone’s right to privacy. CSO takes steps to protect personal information in accordance with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs).

This Policy:

Applies to the personal information we collect and the protection of your privacy when you interact with CSO, and in particular while you use our website(s).
Does not apply to personal information collected or otherwise obtained by CSO in relation to current and former employees of CSO which directly relates to the employment relationship. It does however apply to prospective employees who are subsequently not employed by CSO (for example: unsuccessful job applicants).

This Policy contains important information about:

how and why we collect, use, store and share personal information;
your rights in relation to personal information; and
how to contact us in the event you have a query or complaint.

2. Open and transparent management of personal information

CSO aims to ensure we manage personal information in an open and transparent manner. We take all reasonable steps to implement appropriate practices, procedures and systems relating to our functions or activities to ensure compliance with the APPs and enable us to deal with inquiries or complaints.

We collect information from you to provide you with our services, information and updates. We may also make you aware of new products, services and opportunities available to you. This includes marketing communications about CSO events and partner/vendor products, services and events.

If you are unable to access this Policy and require a copy in another format, please contact us at: [email protected] and we will arrange a copy in an alternative format, where possible.

3. Anonymity and pseudonymity

In most cases, it will be impractical for CSO to deal with individuals anonymously or those using a pseudonym. However, if there are circumstances where it is lawful and practicable to do so, CSO will provide you with the option of not identifying yourself or using a pseudonym.

4. What information do we collect and why?

4.1 – What we collect

CSO may collect, store and use personal information you provide to us whether through our website, provided directly to us, or through other interactions with us.

Personal information is any information that can be used to identify you and may include:

Your full name, address, occupation, contact details (address, telephone number, email address);
Your company information (job title, geographic location);
Information about your dealings with us or any of our clients;
Other information required for the purposes of billing;
Your interests regarding our services;
Your employment information;
Other personal information you may disclose to us when you request a product or service from us.

Where relevant, we may also ask you for other information, for example, qualifications, employment history, date of birth and emergency contact details if you are applying for employment with us.

Please note that we may collect additional personal information at other times when interacting with us.

4.2 – Purpose of collection

CSO collects information from you for the primary purpose of conducting and supporting its business functions and activities.

We may also collect, store, use or disclose your personal information:

in relation to an application for employment;
to contact you, if required;
for direct marketing;
to address enquiries, complaints or feedback; and
where we are otherwise required or authorised by law to do so.

CSO will not use your personal information for a secondary purpose (being any other purpose than a primary purpose of collection), unless:

you consent to the use or disclosure, or it is reasonably expected that we would use it for a secondary purpose and the information is related to the primary purpose;
the use or disclosure is required or authorised by an Australian law or court order; or
the use or disclosure is otherwise permitted as reasonably necessary for a law enforcement related activity.

5. How we collect your personal information

5.1 – Generally

We will usually collect personal information in the following ways:

Location of collection	Example
Directly from you	In person, via email, in documents (including web forms), event registration forms, or via the CSO website.
Third parties	For example – your business associates or employer.

5.2 – Website, Cookies & similar technologies

Website

When you use the CSO website, our server may automatically record certain information such as your IP address, broad geographic location, browser type, operating system, internet address, domain name, date and time of your visit to our website. This information is used in an aggregated manner to analyse how people use our site, and how we can improve our services.

A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Such technologies can be used to track users’ actions and activities and to store information about them. We may use these cookies and/or similar technologies on the CSO website.

This information helps us to understand our users and is used for internal purposes only, including statistical purposes. We will not be able to identify you individually from this information.

Please note that in some cases, our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.

You always have the option to opt-out of using cookies at any time, or you can set your browser not to accept cookies. Please note that some of our website features may not function as a result.

Web Beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your device. It assists us in gathering information about visitors to our websites. This information includes, but is not limited to, browser type, time of access and cookies. We may use web beacons from time-to-time as a measure of the effectiveness of third-party websites which provide us with marketing services or to collect aggregate visitor statistics and manage cookies.

When cookies are disabled, you can make certain web beacons unusable. It may still anonymously record visits from your IP address, but there will be no recording of cookie data.

Third party websites

We may, from time-to-time, have links to other websites which are not owned or controlled by us. They are for your convenience only.

The links do not constitute sponsorship, endorsement or approval of the third-party websites and CSO is not responsible for those websites’ practices. Please ensure you read the third-party website’s privacy policy.

Pixels

We reserve the right to use pixels in accordance with the policies of different social media sites. Pixels allow visitors to outside websites to be tracked by social media sites to tailor advertising messages that users see while visiting that social media site.

6. Who we may disclose or share your information with

We may disclose your personal information to:

our employees, contractors and officers internal to CSO (including related bodies corporate);
third party service providers, including, for example – customer relationship management providers, communications and marketing providers, maintenance and technical support providers, cloud hosting providers, analytics companies, payment providers and security and fraud detection providers;
CSO’s professional advisors and similar service providers who may, from time-to-time, be engaged to carry out, advise or assist with the business activities of CSO;
vendors, suppliers and partners; and
government agencies or other similar entities as required or permitted by law.

Where required for business purposes, we may also share your personal information with insurers, professional advisors or agents. We may also be required to disclose personal information to comply with a legal requirement.

7. Direct marketing

Unless you request otherwise, we may use your personal information, that we collect directly from you, for marketing purposes to send you for example – news, information about our activities, promotional material, events and offers, which we believe may be of interest for you.

At any time, you can request to no longer receive direct marketing communications from us. There will be a link available to opt out or unsubscribe.

8. Sensitive information

Some personal information is considered ‘sensitive information’ for the purposes of the Act and the APPs. Generally, we will not seek sensitive information from you. Sensitive information includes, but is not limited to: health information, an opinion about your health, membership of a professional or trade association and criminal record.

In some instances, we may be required to collect sensitive information from you. We will only collect sensitive information from you if you consent and it is reasonably necessary for one or more of our functions or activities. An example of this is for collecting sensitive information from prospective employees.

9. Cross-border disclosure of your information

Our business is based in Australia.

However, the information we collect and store, may in some circumstances, be stored, process or transferred between parties located in the European Union, United Kingdom, United State of America and New Zealand.

We will take reasonable steps in the circumstances to ensure the overseas recipient does not breach the APPs unless one of the following situations exist:

we have a reasonable belief that:
a. the overseas recipient is subject to a law or binding scheme that is, substantially similar to the protections under the APPs; and
b. there are mechanisms that you can access to take action to enforce that protection of the law or scheme; or
we expressly inform you that if you consent to the disclosure the requirements in APP 8.1 do not apply and you consent;
APP 8.3 applies where the overseas recipient is:
a. subject to the laws; or
b. a participant in a binding scheme,
that is prescribed by the regulations; or
there is a permitted general situation, or the information is required or authorised by law to make the disclosure.

10. Security of your personal information

CSO takes all reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. We have implemented security measures and use technological and organisational measures to keep your information secure. However, we cannot guarantee the security of any information that you provide us.

Where legally permissible, CSO will take reasonable steps to destroy or de-identify your personal information when it is no longer needed.

By using this website, you acknowledge and agree to the terms of this Policy and accept that no transmission of information of data via the internet, or the electronic storage of data is completely secure. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit it to us at your own risk. However, we do take the protection and storage of personal information seriously.

In the event of a suspected data breach, we will notify you and any applicable regulator(s) where we are legally required to do so.

11. Access, updates and correction of your personal information

CSO is committed to ensuring that any of your personal information that we hold is accurate and up-to-date. We will take reasonable steps to keep your personal information as accurate, complete and up-to-date as possible.

You have the right to request access to any of your personal information which we hold, and to update or correct it, in accordance with APPs 12 and 13.

Please see section 12 below for details on how to contact us.

12. How to contact us

We take customer satisfaction very seriously. If you have an enquiry or complaint in relation to the handling of your personal information, we will use our best efforts to handle it efficiently and fairly.

If you do have a complaint, you may contact us via:

Email:	info@csogroup.com.au
Address:	Level 3, 309 George Street, Sydney NSW 2000

13. Changes to this policy

CSO reserves the right to amend, vary or update this Policy from time-to-time.

The updated version will be available on our website as soon as practicable following the amendment. We encourage you to check the Policy at www.csogroup.com.au from time-to-time.

This policy is effective from July 2025.