Privacy Policy

1. Who We Are

Gullway Pty Ltd (ABN 92 701 365 835) is a diversified professional services business based in Perth, Western Australia. We provide a range of advisory, administrative and business support services to individuals, small businesses and organisations across the Perth metropolitan area and beyond.

In this policy, “we”, “us” and “our” refer to Gullway Pty Ltd. “Personal information” has the meaning given to it in the Privacy Act 1988 (Cth): information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether recorded in a material form or not.

2. Our Commitment to the Australian Privacy Principles

We are bound by the Australian Privacy Principles (APPs) set out in Schedule 1 of the Privacy Act 1988 (Cth). The APPs govern how we collect, use, disclose, store, secure and dispose of your personal information. This privacy policy describes how we comply with those principles in our day-to-day operations.

3. The Kinds of Personal Information We Collect

The personal information we collect depends on the nature of our engagement with you. It may include:

• Your name, and where relevant, the name of the business or organisation you represent;
• Your email address and other contact details you choose to provide;
• Information about your business needs, project requirements and preferences relevant to the services you have asked us to provide;
• Records of correspondence, including emails and messages you send to us;
• Billing and engagement information reasonably necessary for providing quotes and delivering our services; and
• Any other information you voluntarily provide to us through our website or in correspondence.

We do not ordinarily collect sensitive information (such as health information or information about racial or ethnic origin). If sensitive information is ever required for a lawful purpose, we will only collect it with your consent or where permitted by law.

4. How We Collect Personal Information

We collect personal information in a number of ways, including:

• Directly from you when you contact us by email, through our website forms, or in person;
• When you request a quote or engage us to provide services;
• Through your use of our website, including information automatically transmitted by your browser; and
• From third parties where you have consented to that collection, or where otherwise permitted by the APPs.

Where reasonable and practicable, we will collect personal information directly from you. If we receive information we did not solicit and it is not needed for our functions, we will deal with it in accordance with APP 11 (security of personal information) and, where appropriate, destroy or de-identify it.

5. Purposes for Which We Collect, Hold, Use and Disclose Personal Information

We collect, hold, use and disclose personal information for purposes including:

• Responding to your enquiries and providing requested quotes;
• Providing, managing and improving our professional services;
• Communicating with you about your engagement, including updates and follow-ups;
• Internal record keeping, accounting, and compliance with legal and regulatory obligations;
• Administering and improving our website and user experience; and
• Any other purpose disclosed to you at the time of collection, or to which you have otherwise consented.

We will not use or disclose your personal information for direct marketing purposes unless permitted under APP 7, and where we do so, we will provide a simple means for you to request not to receive further direct marketing communications.

6. Disclosure of Personal Information

We may disclose your personal information to:

• Professional advisers, contractors and service providers who assist us in operating our business (for example, hosting, IT, accounting or administrative providers), where reasonably necessary and subject to confidentiality obligations;
• Government bodies, regulators, courts or law enforcement agencies where required or authorised by law; and
• Any other person with your consent, or where otherwise permitted under the APPs.

We do not sell your personal information. We take reasonable steps to ensure that any third party to whom we disclose personal information handles it in a manner consistent with the APPs.

7. Data Quality, Security and Retention

We take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete, and to protect it from misuse, interference, loss and unauthorised access, modification or disclosure. Measures we use include access restrictions, secure storage practices and limitation of access to personnel who need the information to perform their duties.

We retain personal information only for as long as is reasonably necessary for the purposes for which it was collected, or as required by applicable law (including record-keeping obligations). Once information is no longer required, we take reasonable steps to destroy or de-identify it in a secure manner.

8. Cookies and Website Analytics

Our website may use cookies and similar technologies to support the functioning of the site and to understand how visitors use it. Cookies are small files stored on your device that help websites operate efficiently and remember your preferences. You can configure your browser to refuse cookies or to alert you when cookies are being used; however, some parts of the website may not function properly if cookies are disabled.

Any analytics information we collect is used in a de-identified or aggregated form wherever practicable, and is not used to identify individual visitors.

9. Access to and Correction of Your Personal Information

Under APP 12 and APP 13, you have a right to request access to the personal information we hold about you and to request corrections if you believe that information is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, please contact us by email at ceo@gullway.site. We will respond to your request within a reasonable period. We will provide access in the manner requested where it is reasonable and practicable to do so, and we will not charge a fee for a request to correct your personal information. In some circumstances permitted by the APPs, we may decline a request for access; if so, we will provide written reasons and information about how to seek a review of our decision.

10. Notifiable Data Breaches

We maintain practices aimed at identifying and responding to data breaches. If a data breach occurs that is likely to result in serious harm to individuals whose personal information is involved, we will comply with our obligations under the Notifiable Data Breaches scheme, including assessing the breach and, where required, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) as soon as practicable.

11. Overseas Disclosure

Where practicable, we store and process personal information within Australia. If, in the course of our operations, we disclose personal information to a recipient located overseas, we will take reasonable steps to ensure that the recipient does not breach the APPs in relation to that information, in accordance with APP 8.

12. Making a Privacy Complaint

If you have a complaint about how we have handled your personal information, please contact us by email at ceo@gullway.site with details of your complaint. We take privacy complaints seriously and will:

• Acknowledge your complaint within a reasonable period;
• Investigate the matter promptly and fairly; and
• Inform you of the outcome and any steps we propose to take.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) via its website at www.oaic.gov.au.

13. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, services or legal obligations. The current version will always be published on this page, together with the date of the most recent update. We encourage you to review this page periodically to stay informed about how we protect your personal information.

14. Contacting Us About Privacy

If you have any questions about this privacy policy, the personal information we hold about you, or how we handle privacy matters generally, please contact our nominated privacy contact:

Gullway Pty Ltd (ABN 92 701 365 835)
Perth, Western Australia
Email: ceo@gullway.site