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Privacy Policy

Puzzle Box Pty Ltd (“we”, “us” or “our”) is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

1. Personal Information Collection

We do not collect personal information directly through this Website (for example, through forms, accounts or registrations).

However, if you choose to contact us via:

  • email (via the “Email Me” link), or
  • LinkedIn (via the “Connect on LinkedIn” link),

we may receive personal information you voluntarily provide, such as your name, email address, organisation and the nature of your enquiry. The only website data that we will use will be aggregated data to measure website analytics and performance. We will not be using data to personally identify users.

2. What is Personal Information?

The Privacy Act 1998 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.

Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.

Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive Information will be used by us only:

  • for the primary purpose for which it was obtained;
  • for a secondary purpose that is directly related to the primary purpose; and
  • with your consent or where required or authorised by law.

3. Website Analytics and Cookies

As per paragraph 1 no personal information is collected via our website. We may collect cookies from your computer which enable us to tell when you use the Website and also to help customise your Website experience. Any information used will be aggregated data.

4. If  you contact us

If you contact us, we may use your personal information to:

  • respond to your enquiry
  • communicate with you about potential advisory or engagement opportunities

We do not use your information for direct marketing unless you have expressly requested or consented to receive such information.

  • We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained in, we will take reasonable steps to destroy and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for a maximum of 7 years to fulfill our record keeping obligations.
  • The Australian Privacy Principles:
    • permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
    • allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
  • Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.

5. Disclosure of Personal Information

We do not sell, rent or trade personal information.

We may disclose personal information under section 4:

  • where required by law; or
  • where reasonably necessary to respond to your enquiry
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6. Data Storage and Security

Any personal information you provide (for example via email) is stored securely and protected from unauthorised access, misuse or disclosure.

7. Access and Correction

You may request access to, or correction of, personal information we hold about you by contacting us using the details below.

8. Third-Party Platforms

If you contact us via LinkedIn or other external platforms, your information will also be subject to the privacy policies of those platforms.

We are not responsible for the privacy practices of third-party services.

9. Overseas Disclosure

Your Personal Information will not be disclosed to recipients outside Australia.

10.Complaints Procedure

If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us as on the contact details set out at the bottom of this policy. All complaints will be considered by Devini Goonetilleke and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).

11. Contact

For privacy enquiries:

📧 devinipg@googlemail.com