Privacy Policy

This document sets out the privacy policy of Claritas ESG ABN 32 671 057 392 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’), the owner and operator of the Oracle ESG service.

The Privacy Act 1988 (Cth) (Privacy Act) requires entities bound by the Australian Privacy Principles to have a privacy policy. We take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.

For the purposes of applicable data protection law, (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and the UK Data Protection Act 2018), your data will be controlled by us.

This privacy policy applies whenever we collect your personal information (including sensitive information) and/or personal data (your personal data), and by providing this information you consent to our storage, maintenance, use and disclosing of this information in accordance with this privacy policy. This includes between you, the visitor to this website (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this website and also where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you.

We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

The personal data we collect may include the following:

• (a) email
• (b) I.P. address and standard web log information

We will collect your personal data in a lawful and fair way. We will only collect your personal data where you have consented to it, or otherwise in accordance with the law.

How we collect information from you

We may collect personal data either directly from you where you:

• (a) contact us through our website;
• (b) receive goods or services from us;
• (c) submit any of our online inquiry forms;
• (d) communicate with us via email, telephone, SMS, social applications (such as LinkedIn or Facebook) or otherwise;
• (e) interact with our website, social applications, services, content and advertising; and
• (f) invest in our business or enquire as to a potential purchase in our business.

We collect and use personal data for the following primary purposes:

• (a) to provide goods, services or information to you;
• (b) for record keeping and administrative purposes;
• (c) to improve and optimise our service offering and customer experience;
• (d) to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
• (e) to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you.

We may also use your personal data for:

• (f) secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
• (g) any other purpose for which we receive consent from you; or
• (h) any other purpose which is permitted or required under applicable privacy laws.

We respect your privacy, and we will take reasonable steps to keep your personal data confidential and protected. We may disclose your personal data to any third parties you have consented personal data to be disclosed to.

We may also disclose personal data to third party contractors as required for us to provide our goods and services to you, such as cloud-service providers and IT professionals.

We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal data for any purpose except for those activities we have asked them to perform on our behalf.

We will not otherwise disclose your personal data unless:

• (a) you have consented to us disclosing your personal data for particular circumstances;
• (b) as needed in an emergency or in investigation suspected criminal activity;
• (c) we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
• (d) we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
• (e) it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
• (f) it is otherwise authorised or required by law.

You have various rights with respect to our use of your personal data:

• Access: You have the right to obtain access to your information (if we’re processing it) and certain other information so that you’re aware and can check that we’re using your information in accordance with data protection law.
• Be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
• Rectification: We encourage you to contact us to let us know if any of your personal data is not accurate or changes, so that we can keep it up-to-date.
• Objecting: You have the right to object to processing of your personal data in certain circumstances, including processing for direct marketing.
• Restricting: You have the right to ‘block’ or suppress further use of your information.
• Erasure: You have the right to ask us to erase your personal data when it’s no longer necessary for the purposes for which it was collected, or if it has been unlawfully processed.
• Portability: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
• Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.
• Withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time.

You may, at any time, exercise any of the above rights by contacting our email address provided below.

All personal data we collect is stored on servers located in Australia and we do not disclose or transfer personal data overseas. However, the cloud service providers we engage to provide us Australian-based servers may operate overseas disaster recovery sites or have personnel overseas who may access the personal data we hold to assist us in managing our servers.

We also may use Google Analytics to track web traffic information which is operated by Google which stores information across multiple countries.

When you communicate with us through a social media service such as Facebook or Twitter, the social media provider and its partners may collect and hold your personal data overseas.

We will only retain your personal data 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. We will securely destroy your personal data in accordance with applicable laws and regulations.

If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.

Collection of sensitive information
We may collect sensitive information about you during the course of providing you our goods and services. We will only collect this sensitive information where you consent to such collection and either directly provide us with this information.

Types of sensitive information we collect
The sensitive information we collect includes any sensitive information provided by you or a third party to us via our website or platforms, or otherwise provided by you or a third party to us.

How we use your sensitive information
Your sensitive information will only be used for the purpose of:

• (a) providing you with our goods and services;
• (b) complying with our legal obligations, resolving disputes or enforcing our agreements with you;
• (c) sending you messages, reminders, notices, updates, security alerts, and other information requested by you;
• (d) any other purpose which is permitted or required under applicable privacy laws.

How we disclose your sensitive information
Your sensitive information will only be disclosed to third parties where it is permitted or required under applicable privacy laws.

How you can withdraw consent
If you wish to withdraw your consent to our collection, use or disclosure of your sensitive information, please contact us using the contact details set out below. We will deal with all such requests within a reasonable timeframe.

We may at times send you marketing communications which will be done in accordance with the Spam Act 2003 (Cth) (Spam Act).

If we do, we may use email, SMS, social media, phone or mail to send you direct marketing communications.

Where consent is needed, we will ask you for your consent before sending you marketing communications, except where you:

• (a) have explicitly opted-in to receiving email marketing from us in the past; or
• (b) were given the option to opt-out of email marketing when you initially signed up for one of our platforms and you did not do so.

You can, at any time, opt out of receiving marketing materials from us by using the opt-out facility provided (e.g., an unsubscribe link on emails) or by contacting us via the details provided at the end of this privacy policy.

The information we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute such information.

We take reasonable steps to ensure your personal data is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems.

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

If you wish to complain about how we handle your personal data held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable timeframe.

For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:

Email: hello@claritasesg.com

Our privacy policy was last updated on 1 February 2025.