This policy sets out how Infigency Pty Ltd (ABN 21636682141) handles personal information. It covers this website and the professional services we provide.
Infigency's annual turnover is below the $3 million threshold in the Privacy Act 1988 (Cth), and we do not currently fall within any of the exceptions in sections 6C to 6EA. We are therefore not an APP entity and are not bound by the Australian Privacy Principles.
We observe them anyway, as a matter of practice. Where this policy describes what we do, we mean it as a commitment we hold ourselves to, not as a claim about legal status.
What we collect through this website
This site has no contact form, no account system, no analytics and no cookies. We do not track visitors, and we do not build profiles of people who read these pages.
Two things happen automatically that involve your device:
- Hosting logs. Our hosting provider records standard server information including IP address, browser type, pages requested and timestamps. This is generated by the provider for security and operational purposes, and we do not use it to identify individuals.
- Web fonts. The typefaces on this site load from Google Fonts, which means your browser makes a request to Google's servers and Google receives your IP address. If you would prefer this not to happen, most browsers allow you to block third-party font requests.
What we collect when you contact us
If you email us, we hold whatever you choose to send: your name, email address, organisation, role, and the content of your message. We use it to answer you and, where a conversation leads to work, to scope and deliver that work.
During an engagement we may also hold names, roles and contact details of your staff, and information about your systems, suppliers and controls. We treat engagement material as confidential and handle it under the engagement agreement.
What we do not do
- We do not sell, rent or trade personal information.
- We do not use engagement material to train AI models, and we do not put client information into third-party AI tools without written agreement about which tools and on what terms.
- We do not send marketing to people who have not asked for it, beyond direct professional correspondence permitted under the Spam Act 2003 (Cth).
- We do not name clients publicly without written permission.
Who we disclose information to
We disclose personal information only where it is needed to run the business or deliver the work:
- Service providers who support our operations, including our hosting provider, email provider, accounting software and professional advisers.
- Our insurer and legal advisers, where a claim or potential claim requires it.
- A regulator, court or law enforcement body, where we are required or authorised by law.
Some of these providers store data outside Australia, including in the United States. We select providers with published security practices, and we take reasonable steps to satisfy ourselves that information is handled appropriately before we use them.
Security and retention
We hold information on encrypted devices and in accounts protected by multi-factor authentication. Access is limited to people who need it to do the work, which in most engagements means one person.
We keep engagement records for seven years after an engagement closes, which reflects limitation periods and professional indemnity requirements. Enquiries that do not lead to work are deleted within twelve months. When information is no longer needed, we destroy it or de-identify it.
Automated decision-making
We do not use automated systems to make decisions about individuals. No algorithm decides whether we take on your work, what we charge, or what we find. Where we use software to assist analysis during an engagement, a person reviews and is accountable for every conclusion we deliver.
Access, correction and complaints
You can ask us what personal information we hold about you, ask us to correct it, or ask us to delete it. Email info@infigency.com.au and we will respond within 30 days. There is no charge.
If you are unhappy with how we have handled your information, tell us first and we will investigate. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au, which will determine whether it is able to consider the matter.
Data breaches
If we become aware of unauthorised access to or disclosure of information we hold, we will assess it promptly. Where the incident is likely to result in serious harm, we will notify the people affected and the Office of the Australian Information Commissioner, and we will tell any client whose engagement material is involved regardless of whether the threshold is met.
Changes to this policy
We review this policy annually and when our practices change. The effective date and version number at the top of this page tell you which version you are reading. Material changes will be noted here rather than made silently.
Contact
Infigency Pty Ltd, ABN 21636682141, Sydney NSW.
Email: info@infigency.com.au