Privacy Policy

Groom Kennedy Privacy Policy

Our commitment to privacy

Groom Kennedy Pty Ltd (ACN 151426 498) is committed to protecting the privacy and security of personal information.

From 1 July 2026, we are required to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) in relation to personal information we handle, including due to our obligations under the Anti‑Money Laundering and Counter‑Terrorism Financing Act 2006 (Cth) (AML/CTF Act).

This Privacy Policy explains how we collect, use, disclose, store and protect personal information, including information collected to meet our AML/CTF obligations.

What personal information we collect

We may collect personal information including (but not limited to):

• identification details (such as name, date of birth and contact details)
• identity verification information for AML/CTF purposes
• information about beneficial ownership or control of entities
• client instructions and matter‑related information
• information required to assess, manage and monitor AML/CTF risk
• other personal information necessary to provide legal services or comply with legal obligations

We only collect personal information that is reasonably necessary for our functions and activities, including to comply with the AML/CTF Act and related Rules.

How we collect personal information

We collect personal information directly from individuals where possible, including through:

• client onboarding processes
• correspondence
• instructions received in connection with legal services
• identity verification and due diligence procedures

In some cases, we may collect personal information from third parties or electronic verification providers where permitted or required by law for AML/CTF or other compliance purposes,including (but not limited to) InfoTrack.

Information collected via our website

When you visit or interact withour website, we may collect certain information automatically or through your use of the site.

This may include:

• technical data such as your IP address, browser type and device information
• location data and standard web log information
• information about how you use and navigate our website
• any information you submit through online forms or enquiries

We may use cookies and similar technologies to:

• enable the proper functioning of our website
• remember user preferences
• analyse website usage and performance
• improve our services and user experience

You can control or disable cookies through your browser settings. However, doing so may affect the functionality of the website.

Our website may contain links tothird-party websites. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies.

Why we collect and use personal information

We use personal information to:

• provide legal and related professional services
• conduct client due diligence and ongoing monitoring under the AML/CTF Act
• comply with reporting, record‑keeping and risk management obligations
• communicate with clients, courts, regulators, counterparties and other third parties
• manage our business operations, professional obligations and risk

Where you interact with our website, we may also use information to:

• respond to enquiries submitted via the website
• monitor and improve the performance, security and usability of the website

We do not use personal information for direct marketing where prohibited by law.

Disclosure of personal information

We may disclose personal information:

• to regulators such as AUSTRAC or other government bodies where required or authorised by law
• to service providers who assist us with identity verification, compliance, technology, administration or professional     services
• to courts, counterparties or other third parties in connection with legal matters, where authorised by law or the client
• as otherwise required or authorised by law

We do not disclose personal information in a manner that would breach our obligations under the AML/CTF Act.

Storage, retention and security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

Consistent with privacy and AML/CTF requirements:

• we do not retain copies of full identity documents unless required by law
• we retain personal information only for as long as it is required to meet legal, regulatory and professional obligations
• we securely destroy or de‑identify personal information when it is no longer required

If we experience a data breach involving personal information, we will assess and respond in accordance with our legal obligations, including notification requirements under applicable privacy laws.

Access and correction

Individuals may request access to, or correction of, personal information we hold about them.

Requests will be handled in accordance with the Privacy Act, subject to legal limitations, including where providing access or correction would prejudice AML/CTF compliance, investigations or other lawful activities.

Anonymity and pseudonymity

Where lawful and practicable, individuals may interact with us anonymously or using a pseudonym.

This may not be possible in circumstances where identification is required by law, including under AML/CTF obligations or to provide legal services.

Overseas disclosure

We may use technology or service providers that store or process data outside Australia.

Where this occurs, we take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with the Australian Privacy Principles, unless an exception under law applies.

Complaints

If you have a concern about how we handle personal information, please contact us in the first instance using the details below. We will acknowledge and investigate complaints and respond within a reasonable period.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Contact details

Groom Kennedy Pty Ltd

Email: sarah.clifford@groomkennedy.com.au

Address: 1/47 Sandy Bay Road, Hobart TAS 7000

Phone: (03) 6221 4800

Updates to this policy

This Privacy Policy may be updated from time to time to reflect changes in law or our practices.

The version published on our website is the current version.

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Current Version Effective: 1 July 2026