SAMPLE AUDIT REQUEST

Privacy Policy

Sample Audit Request
1300 780 436

Digital Engineering Corporation (Australia) Pty Ltd Pty Ltd

Privacy Policy

Effective Date: 20 March 2026

Version: 1.0  |  Jurisdiction: Australia

ABN: 31 165 578 576

IMPORTANT NOTICE TO INDIVIDUALS: This business collects and processes publicly available professional information about named individuals for the purpose of providing B2B commercial intelligence services to enterprise clients. If you wish to request removal of your information from our database, please contact us using the details in Section 10 of this Policy.

1.  About This Policy and Our Business

Digital Engineering Corporation (Australia) Pty Ltd Pty Ltd (ABN: 31 165 578 576) (‘we’, ‘us’, ‘our’) also operates a B2B commercial intelligence service. Our service identifies and analyses publicly available signals — including professional hiring activity, infrastructure planning permit data, grant announcements, and related organisational indicators — and provides structured intelligence reports to enterprise clients operating in the Fintech, Cybersecurity, and MedTech sectors.

This Privacy Policy explains how we collect, hold, use, and disclose personal information in the course of operating our business. It applies to all personal information we handle, whether collected from public sources, our clients, or directly from individuals.

This Policy is issued in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We are committed to handling personal information responsibly and transparently.

2.  What Personal Information We Collect

2.1  Information About Business Professionals

In providing our intelligence services, we collect the following categories of personal information about named individuals in their professional capacity:

  • Full name and professional title or designation
  • Current employer organisation and business unit
  • Professional contact information including business email address and LinkedIn profile URL
  • Employment history as publicly disclosed on professional networking platforms
  • Professional activity signals including conference attendance, published commentary, and public statements in professional contexts
  • Organisational role inferred from public job posting data and professional profile information

We do not intentionally collect sensitive information as defined under the Privacy Act, including health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, or criminal record information.

2.2  Information About Client Organisations

We also collect organisational-level information that is not personal information, including:

  • Company name, registered address, and ABN or ACN
  • Infrastructure planning permit filings sourced from public government portals
  • Grant award announcements from public government databases
  • Job posting data sourced from public employment platforms
  • Financial and regulatory filing information from public databases

2.3  Information About Our Clients

We collect personal information about the individuals who represent our enterprise clients, including names, business contact details, and account information necessary to manage our commercial relationships. This information is used solely for service delivery and account management.

3.  How We Collect Personal Information

3.1  Collection From Public Sources

The majority of personal information we process is sourced from publicly available platforms and databases. These include:

  • Professional networking platforms including LinkedIn
  • Public employment advertising platforms including Seek, Indeed, and company career pages
  • State and territory government planning permit portals
  • Commonwealth and state government grant announcement databases
  • Publicly accessible corporate websites and press releases
  • Industry conference and event programmes where attendance is publicly listed
  • Third-party data enrichment providers who aggregate publicly available professional data

Where we use third-party data enrichment providers, we take reasonable steps to confirm that those providers have collected information lawfully and in accordance with applicable privacy obligations.

3.2  Direct Collection

We collect personal information directly from individuals when they contact us to enquire about our services, when they enter into a commercial agreement with us as a client, or when they exercise their privacy rights under this Policy.

4.  Why We Collect and Use Personal Information

4.1  Primary Purpose

We collect and use professional personal information about named individuals for the primary purpose of providing B2B commercial intelligence services to our enterprise clients. Specifically, this involves:

  • Identifying named professionals whose organisational role and professional activity suggest that their employer organisation may be in the market for specific enterprise services
  • Compiling structured intelligence profiles that combine professional identity information with organisational trigger signals to support targeted commercial outreach by our clients
  • Delivering intelligence reports to enterprise clients containing the above information for the purpose of enabling their sales and business development activity

4.2  Secondary Purposes

We may also use personal information for the following secondary purposes:

  • Improving the accuracy, relevance, and quality of our intelligence products
  • Managing our commercial relationships with clients and prospective clients
  • Complying with our legal obligations
  • Responding to privacy enquiries and managing opt-out requests

4.3  Legitimate Interests Basis

Where we rely on legitimate interests as the basis for processing professional personal information, we have assessed that our commercial interest in providing B2B intelligence services is not overridden by the privacy interests of the individuals whose professional information we process, having regard to the following considerations:

  • The information we process relates exclusively to individuals in their professional capacity, not their personal lives
  • Senior professionals operating in enterprise roles have a reduced expectation of privacy with respect to their professional activities and organisational affiliations
  • The information we process is limited to what is reasonably necessary to identify commercially relevant contacts
  • We provide a clear and accessible mechanism for individuals to opt out of our database at any time

A full Legitimate Interests Assessment is maintained as an internal governance document and is available to the Office of the Australian Information Commissioner upon request.

5.  How We Disclose Personal Information

5.1  Disclosure to Enterprise Clients

We disclose personal information about named professionals to our enterprise clients as part of delivering our intelligence service. Our enterprise clients are businesses operating in the Fintech, Cybersecurity, and MedTech sectors who use our intelligence to support their sales and business development activities.

Before disclosing personal information to a client, we require that client to agree to our Client Data Use Terms, which restrict the use of disclosed information to legitimate commercial outreach purposes and prohibit resale, redistribution, or use for purposes unrelated to the client’s business development activities.

5.2  Disclosure to Service Providers

We may disclose personal information to third-party service providers who assist us in operating our business, including cloud infrastructure providers, data enrichment providers, and workflow automation platforms. These providers are engaged under contractual terms that require them to handle personal information only as directed by us and in accordance with applicable privacy obligations.

5.3  Disclosure Required by Law

We may disclose personal information where required or authorised by law, including in response to a valid court order, regulatory requirement, or law enforcement request.

5.4  Overseas Disclosure

Some of our service providers are located outside Australia, including cloud infrastructure and workflow automation providers operating in the United States. Where personal information is disclosed to overseas recipients, we take reasonable steps to ensure that the overseas recipient handles the information in a manner consistent with the Australian Privacy Principles. By using our services or remaining in our database, you acknowledge that your information may be transferred to and stored on infrastructure located outside Australia.

6.  Data Quality and Retention

We take reasonable steps to ensure that the personal information we hold is accurate, up-to-date, and relevant to the purposes for which it is held. Our automated workflows include data validation steps to reduce the incidence of outdated or inaccurate information.

We retain personal information about named professionals for the following periods:

  • Active intelligence profiles: retained while the individual remains in a role relevant to our intelligence product and has not requested removal
  • Profiles delivered to clients: retained in our systems for a maximum of 24 months from the date of delivery, after which they are deleted or de-identified
  • Opt-out records: retained indefinitely to prevent re-inclusion of individuals who have requested removal
  • Client account information: retained for the duration of the commercial relationship and for 7 years thereafter in accordance with our legal and taxation obligations

7.  How We Protect Personal Information

We implement reasonable technical and organisational measures to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include:

  • Access controls limiting access to personal information to personnel who require it for their role
  • Encryption of personal information in transit and at rest where technically practicable
  • Use of reputable cloud infrastructure providers with established security certifications
  • Regular review of data access permissions and security configurations

In the event of a data breach that is likely to result in serious harm to affected individuals, we will comply with our mandatory data breach notification obligations under the Privacy Act, including notifying the Office of the Australian Information Commissioner and affected individuals as required.

8.  Your Privacy Rights

8.1  Right to Access

You have the right to request access to personal information we hold about you. We will respond to access requests within 30 days. In some circumstances we may be unable to provide access, for example where doing so would reveal confidential commercial information about our clients. Where we decline an access request, we will explain our reasons.

8.2  Right to Correction

If you believe that personal information we hold about you is inaccurate, out-of-date, incomplete, or misleading, you may request that we correct it. We will take reasonable steps to correct the information within 30 days of receiving your request.

8.3  Right to Opt Out (Removal from Database)

You have the right to request that we remove your personal information from our active intelligence database at any time. Upon receiving a valid opt-out request, we will:

  • Remove your profile from our active intelligence database within 10 business days
  • Add your identifying information to our suppression list to prevent re-inclusion
  • Notify clients to whom your profile was previously delivered that you have opted out

Please note that we are unable to require clients who have already received your information to delete it from their own systems, but we will inform them of your opt-out request.

8.4  Right to Make a Complaint

If you believe we have handled your personal information in a manner inconsistent with the Australian Privacy Principles, you have the right to make a complaint. We ask that you contact us directly in the first instance so that we can attempt to resolve your concern. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

9.  Website and Cookies

Our website may use cookies and similar tracking technologies to improve user experience and analyse site traffic. We do not use website cookies to collect personal information that is incorporated into our intelligence products. You may configure your browser to decline cookies, however this may affect your ability to use certain features of our website.

10.  How to Contact Us

For all privacy enquiries, access requests, correction requests, or opt-out requests, please contact:

Digital Engineering Corporation (Australia) Pty Ltd Pty Ltd

Privacy Officer

Email: contact@dec-aus.com

Postal Address:

Response time: Within 10 business days for opt-out requests, within 30 days for all other requests.

11.  Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business operations, applicable law, or regulatory guidance. The current version of this Policy will always be available on our website. Where we make material changes, we will notify our clients directly.

This Policy was last reviewed and updated on 26 March 2026.