Respecting Your Privacy

Progue is committed to supporting the Australian Privacy Principles for all fair handling of Personal Information which set clear standards for the collection, use, disclosure, storage of and access to Personal Information collected during the course of business operations and compliance with the Privacy Act 1988 (Commonwealth) and its amendments(the Act), and the Australian Privacy Principles (APPs) set out in that Act. You can see the full text of the APPs online at the Office of the Australian Information Commissioner’s website at:

https://www.oaic.gov.au/privacy/australian-privacy-principles

Personal Information means your name, mailing or residential address, telephone number, email address and other transaction and registration details including the company you work for and your role and financial information, including credit card information and information collected from credit reporting agencies. Where we are required to identify you, conduct customer due diligence or meet our obligations under anti-money laundering and counter-terrorism financing law or taxation law, Personal Information may also include your date of birth, identity documents (such as a passport, driver licence or other government-issued identification), tax file number, information about beneficial owners and controllers of an entity, source of funds or wealth, and information obtained from sanctions, politically exposed person and other screening checks. Some of this information is “sensitive information” under the Act and is collected and handled only where permitted by law and, where required, with your consent.

Our respect for your rights to the privacy of your personal information is paramount.  We have policies and procedures in place to ensure that all personal information, no matter how or where it is obtained, is handled sensitively, securely and in accordance with the APPs.

This Privacy Policy sets out:

• What sort of personal information is collected and stored;
• How information is collected and used;
• What happens if you choose not to provide the required information; and
• How you can request access to the personal information we hold about you.

From time to time it may be necessary for Progue to review and revise this Privacy Policy. We reserve the right to change our policy at any time. Amendments or replacements of the Privacy Policy will be posted on our website.

Collection of Your Personal Information

We only collect personal information relevant to our business relationship with you so that we can provide our services and products. We may collect your personal information:

• directly from you including via telephone, email or facsimile;
• when your register on our website or client portal;
• when you place an order or service request with us;
• where you access and interact with our website;
• from other sources including a third party such as credit reporting; and
• any correspondence we receive from you.

Is Your Personal Information Secure?

Where you submit personal information, we manage it by using up-to-date techniques and processes that meet current industry standards to ensure that your personal information is kept secure and confidential. We also take measures to destroy or permanently de-identify personal information if it is no longer required. Some information is retained for periods fixed by law – for example, records connected with anti-money laundering and counter-terrorism financing obligations are generally kept for at least seven years – and is destroyed or de-identified once those periods expire and the information is no longer required.

Use and Disclosure of Personal Information

You acknowledge and consent that by providing your personal information to us that we may use and disclose your personal information for the purpose for which it was collected or for a related or ancillary purpose such as:

• supply of our services and products to you in accordance with our Terms and Conditions and any agreement entered into with you, to facilitate, process, carry out and respond to your request;
• to our third party service providers to assist us in providing and improving our services and products to you and developing, improving and marketing our services and products to you;
• for regulatory reporting and compliance with our legal obligations, to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
• to meet our obligations under anti-money laundering and counter-terrorism financing law, including verifying your identity and that of beneficial owners, conducting customer due diligence and ongoing monitoring, screening against sanctions and politically exposed person lists, and where required by law making reports to the Australian Transaction Reports and Analysis Centre (AUSTRAC) and other regulators. Where the law requires us to report a matter, we may be prohibited from telling you that a report has been made;
• to the seller or supplier of any products to you for the purpose of ascertaining and obtaining any information required to perform our services for you;
• to identify you and conduct appropriate checks, including credit checks;
• set up, administer and manage our services and products and systems, including the management and administration of an account;
• to train and develop our staff to better provide services to you;
• to operate, support and improve our services using technology tools, which may include artificial intelligence (AI) tools, as described in the section “Our use of artificial intelligence” below;
• to contact you; and
• to our successors and/or assigns.

What Happens If You Do Not Want To Disclose Personal Information?

You have no obligation to provide any personal information requested by us, but if you choose to withhold personal information, we may not be able to provide you with the products and services that depend on the collection of that information.

Removing Your Personal Information

You may contact us at any time in writing and request that we remove and delete your stored personal information.

Providing Personal Information About Another Person

You represent to us that where you provide personal information to us about another person, you are authorised to provide that information to us, and that you will inform that person who we are, how we use and disclose their information, and that they can gain access to that information.

Disclosure Of Personal Information Overseas

Some of the service providers and technology tools we use to store information or deliver our services may be located, or may store or process information, outside Australia. Where this occurs, we take reasonable steps to ensure the information is handled consistently with the Australian Privacy Principles and is protected by appropriate contractual and security safeguards. By providing your personal information to us, you acknowledge that it may be disclosed to or accessed from overseas for these purposes. If you would like to know the countries in which our key service providers are located, you can contact us using the details at the end of this policy.

Our Use Of Artificial Intelligence

We use a range of technology tools to help us deliver our services efficiently, including artificial intelligence (AI) tools. These may be tools provided within software we already use, or separate third-party AI tools. We use AI to assist with tasks such as drafting, research, analysis, document review and administration. We apply the following principles when we use AI:

• a qualified person reviews AI-assisted work, and AI is not used as the sole basis for advice or decisions that affect you;
• we take care with confidential and personal information, and we do not enter sensitive identifiers such as tax file numbers into publicly available AI tools that do not offer appropriate confidentiality, security and data-handling protections;
• we prefer AI tools that provide appropriate security, confidentiality and data-handling terms, including terms that do not permit your information to be used to train the provider’s models without authorisation; and
• we remain responsible and accountable for our work and our professional obligations, including our duty of confidentiality, regardless of the tools we use.

Some AI tools may store or process information outside Australia; where this occurs, the section “Disclosure of personal information overseas” applies. If you have questions about how we use AI in connection with your engagement, please contact us.

Anti-Money Laundering And Counter-Terrorism Financing

Where we provide services that are regulated under Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) laws, we are required to collect and verify information about you and, where relevant, about beneficial owners, controllers and others connected with your matter. From 1 July 2026, these obligations are extended to professional services such as ours. To comply, we may:

• collect identity and verify information, including from identity documents and from third-party verification, credit reporting and screening providers;
• screen you and related persons against sanctions lists and to identify politically exposed persons, and carry out ongoing monitoring of the business relationship;
• make reports to AUSTRAC and other authorities where required by law, including suspicious matter reports and threshold transaction reports; and
• retain related records for the period required by law (generally at least seven years).

The law may prevent us from telling you if we have made a report about your matter. If you do not provide the information we are required to collect, we may be unable to act for you. We collect, use and disclose this information only as permitted or required by the AML/CTF laws and the Privacy Act.

Data Breaches

If a data breach occurs that is likely to result in serious harm to any individual whose personal information is involved, we will respond in accordance with the Notifiable Data Breaches scheme under the Act. This includes containing the breach, assessing it, and, where required, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

Linked Sites

Progue’s website may contain links to websites which are owned or operated by other parties. You should make enquiries as to the privacy policies of these parties. We are not responsible for information, or the privacy practices of such websites.

How Can You Access Your Personal Information?

You may in writing request access to personal information that we hold about you. We will provide you with access to personal information in accordance with the Act and APPs and we may not grant you access to the personal information that we hold where the APPs allow us to do so. If you are refused access to information, we will provide you with reasons for the refusal in writing.

Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us using the details below. We will acknowledge your complaint and aim to respond within a reasonable time. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

How To Contact Us

If you have any questions in relation to privacy, or wish to make a complaint or a request to access or correct your personal information, please contact us on vision@progue.com.au or 02 8850 6711. For more information about privacy law please visit http://www.oaic.gov.au/privacy/australian-privacy-principles.