1. We respect your privacy

1. SPIRE LAW PTY LTD (“Spire Law”) respects your right to privacy and is committed to safeguarding the privacy of our customers and Website visitors. This policy sets out how we collect and treat your personal information.
2. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and to the extent applicable, the Personal Information General Data Protection Regulation (GDPR).
3. “Personal information” is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly (‘Personal Information‘).
4. This Website including any supply for products and services is not intended for individuals under the age of 13 years old. We do not knowingly collect or store Personal Information provided by anyone under 13 years of age.
5. You may contact us in writing at Level 5, 8 Maroochydore Road, Maroochydore QLD 4558 Australia for further information about this Privacy Policy.

2. What Personal Information is collected

1. Spire Law will, from time to time, receive and store Personal Information that you submit to our Website, that you provide to us directly or where you give it to us in other forms.
2. You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.
3. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
4. Additionally, we may also collect any other information you provide while interacting with us.
5. We will only use your Personal Information for the purpose which it was collected.

3. How we collect your Personal Information

1. Spire Law collects Personal Information from you in a variety of ways, including when you interact with us electronically or in person, when you access our Website and when we engage in business activities with you. We may also receive Personal Information from third parties.
   If we do, we will protect it as set out in this Privacy Policy.
2. By providing us with Personal Information, you agree that we may collect, use, authorise, transmit and manage that Personal Information in accordance with this Privacy Policy.

4. How we use your Personal Information

1. Spire Law may use Personal Information that we collect from you to provide you with information about our products or services. We may also use it to inform you of new products, services or opportunities that we make available to you.
2. Spire Law will use Personal Information only for the purposes that you consent to. This includes to:
   1. provide you with products or services during the usual course of our business activities;
   2. administer our business activities;
   3. manage, research and develop our products and services;
   4. provide you with information about our products and services;
   5. communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail; and
   6. investigate any complaints.
3. If you withhold your Personal Information, it may not be possible for us to provide you with our products and services or for you to fully access our Website.
4. We may disclose your Personal Information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
5. We may also use your Personal Information to protect the copyright, trademarks, legal rights, property or safety of Spire Law, https://www.spirelaw.com.au, its customers or third parties.
6. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any Personal Information and non-Personal Information contained in those databases.

5. Disclosure of your Personal Information

1. Spire Law may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.
2. If we do disclose your Personal Information to a third party, we will protect it in accordance with this Privacy Policy.

6. General Data Protection Regulation (GDPR) for the European Union (Personal Information)

1. Spire Law will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
2. We process your Personal Information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
3. We must establish a lawful basis for processing your Personal Information. The legal basis for which we collect your Personal Information depends on the Personal Information that we collect and how we use it.
4. We will only collect your Personal Information with your express consent for a specific purpose and any Personal Information collected will be to the extent necessary and not excessive for its purpose. We will keep your Personal Information safe and secure.
5. We will also process your Personal Information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
6. We process your Personal Information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
7. We do not collect or process any Personal Information from you that is considered “Sensitive Personal Information” under the GDPR, such as Personal Information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
8. You must not provide us with your Personal Information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the Personal Information of children.

7. Use of your Personal Information and legal basis for collection under the GDPR

1. “Personal Information” refers to any information relating to an identifiable natural person who can be identified directly or indirectly (‘Data Subject’) (Article 4).
2. If you are an individual residing in the European Union (Personal Information), we collect and process Personal Information about you in accordance with the GDPR.
3. When we collect or process your Personal Information, we do so as either a ‘processor’ or a ‘controller’ as defined in the GDPR. In some instances, Spire Law may be a controller and a processor.
4. The legal basis for which we collect Personal Information from you depends on the products or services you use and how you use them.
   Spire Law will only collect and use your Personal Information on the following legal bases: under the terms and conditions of our contract to provide you with our products or services, when you give us your express consent to use and process Personal Information for a specific purpose, for the satisfaction of a legitimate interest or to comply with a legal obligation.
5. When we collect your Personal Information, we only collect what is necessary to the purpose for which the Personal Information is being collected.
6. We will only share your Personal Information to third-party service providers where you have given us your express consent, and only for the purposes described in this Privacy Policy.
7. Where we employ data processors to process Personal Information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect Personal Information against unauthorised use, loss and theft.
8. We only store your Personal Information while it remains necessary, or if the purpose of the processing could not reasonably be fulfilled by other means.
9. We do not knowingly collect or process Personal Information of persons 13 years or younger. If you are under the age of 16, we request that you obtain and provide parental consent as required by the GDPR.

8. Your Legal Rights under the GDPR

1. If you are an individual residing in the European Union, you have certain rights as to how your Personal Information is obtained and used. Spire Law complies with your rights under the GDPR as to how your Personal Information is used and controlled if you are an individual residing in the Personal Information.
2. These rights include the right to request access, correction, deletion, restriction, transfer, to object to processing, to portability of data and where the lawful ground of processing is consent to withdraw your consent.
3. We comply with your rights under the GDPR (subject to the grounds set out in the GDPR) that permit you:
   1. to be informed as to how your Personal Information is being used;
   2. to access your Personal Information and to know specifically what information is held about you and how it is processed, where and for what purpose (we will provide you a copy of your Personal Information in electronic format free of charge if requested);
   3. to rectify your Personal Information if it is inaccurate or incomplete;
   4. to erase your Personal Information (also known as ‘the right to be forgotten’) if you wish to delete or remove your Personal Information;
   5. to restrict processing of your Personal Information;
   6. to retain and reuse your Personal Information for your own purposes (Personal Information portability);
   7. to object to your Personal Information being used; and
   8. to object against automated decision making and profiling.
4. You can contact us any time to exercise your rights under the GDPR including as to:
   1. request access to Personal Information that we hold about you;
   2. to correct any Personal Information that we hold about you;
   3. delete Personal Information that we hold about you; or
   4. opt out of emails, marketing, and any other push notifications that you receive from us.
5. Please contact us at any time to exercise your rights under the GDPR through the contact details in this Privacy Policy.
6. We may ask you to verify your identity before acting on any of your requests.

9. Data Retention under the GDRP

1. We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

10. Hosting and International Personal Information Transfers

1. Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia.
2. We may transfer your Personal Information to countries that the European Commission have approved as providing an adequate level of protection for Personal Information or if we use US-based providers that are part of the Personal Information-US Privacy Shield as they have equivalent safeguards in place.
3. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

11. Security of your Personal Information

1. Spire Law is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
2. Where we employ data processors to process Personal Information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect Personal Information against unauthorised use, loss and theft.
3. The transmission and exchange of information is carried out at your own risk. No method over the transmission or storage system is 100% private and secure. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that Personal Information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

12. Access to your Personal Information

1. You may request details of Personal Information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at amy@spirelaw.com.au.
2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.

13. Complaints about privacy

1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to amy@spirelaw.com.au.
   We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

14. Changes to Privacy Policy

1. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our Website or notice board. Please check back from time to time to review our Privacy Policy.

15. Website

1. When you visit our Website When you come to our Website (https://www.spirelaw.com.au), we may collect certain information such as browser type, operating system, Website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
2. Cookies
   We may from time to time use cookies on our Website. Cookies are very small files which a Website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings.
   However, this may prevent you from taking full advantage of our Website. Our Website may from time to time use cookies to analyses Website traffic and help us provide a better Website visitor experience. In addition, cookies may be used to serve relevant ads to Website visitors through third party services such as Google AdWords.
   These ads may appear on this Website or other Websites you visit.
   Please refer to our Cookie Policy for further details.
3. Third party sites
   Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only.
   Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Spire Law is not responsible for the privacy practices of other websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

16. How can we help? Getting in touch – Questions, concerns or complaints

• If you have any questions, concerns or complaints about Spire Law’s data practices or concerning its use of this Privacy Policy, we encourage you to get in touch with our appointed Data Protection Officer (“DPO”).
• If you believe you have suffered harm due to a breach of your rights by Spire Law under this Privacy Policy, and Spire Law has not handled your complaint in a reasonably sufficient manner, please contact us at the details below.
• The contact information for Spire Law’s Data Protection Officer is:

Amy Lowry, Level 2, 61 The Esplanade, Maroochydore QLD 4558 Australia
Email: amy@spirelaw.com.au