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Privacy Policy

Privacy. We take yours seriously.

Carbon Link Operations Pty Ltd (ABN 46 609 904 010) and its related and associated bodies corporate (us, we, our, CarbonLink) maintain a policy of strict confidence concerning your (you, your) personal information (Privacy Policy). This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (Privacy Act). The Privacy Policy applies to the collection, storage, use and disclosure by us of your personal information.

By engaging with us, including by accessing our site at https://carbonlink.com.au/ or such other sites as we may own or operate (Site), through the use of our Site or online presence or other applications or web-based services, engagement of our services, or by any other means, you accept the terms of this Privacy Policy.

This Privacy Policy applies to information provided to us and demonstrates how we will comply with the Australian Privacy Principles (APPs) under the Privacy Act.

The APPs set out standards, rights and obligations in relation to handling, holding, accessing and correcting personal information.

The APPs are structured to reflect the personal information lifecycle and are grouped into five parts:

  • Part 1 — Consideration of personal information privacy (APPs 1 and 2). This Policy has been prepared to meet this requirement.
  • Part 2 — Collection of personal information (APPs 3, 4 and 5)
  • Part 3 — Dealing with personal information (APPs 6, 7, 8 and 9)
  • Part 4 — Integrity of personal information (APPs 10 and 11)
  • Part 5 — Access to, and correction of, personal information (APPs 12 and 13)

It is the aim of this Policy to set out how we protect the privacy of CarbonLink customers, staff and other persons with whom we have dealings.

Although we will comply with this Privacy Policy in respect of information provided to us by persons under the age of 18 years, those persons must obtain the consent of a parent or guardian prior to engaging with us, and the parent or guardian will be responsible for appropriately supervising the person’s engagement.

This Policy will be made available at https://carbonlink.com.au/, and you can also request a copy by post or email. If you have any further questions or if you wish to receive more information on our information practices and Privacy Policy, please contact us at 7A, 60 Edward Street, Brisbane City 4000 or by sending us an email at info@carbonlink.com.au.

1. Collecting personal information

Personal information has the meaning given to it under the Privacy Act.

In general terms, personal information is information or an opinion, whether true or not, about a person whose identity is apparent from the information or opinion. Personal information includes any information we collect from you directly or from another party to establish or provide our products and services or to provide employment to you.

Personal information also includes ‘sensitive information’.

If we are unable to collect personal information we reasonably require, we may not be able to do business with you or the organisation with which you are connected. Many of our products or services require us by law to collect your personal information.

Where it is possible, for example when providing general information, CarbonLink will allow persons to remain anonymous or use a pseudonym.

1.1 When and how we collect information

If it is reasonable and practical to do so, we will collect personal information directly from you. This may take place in a number of ways, including:

  • when you provide us with personal information about yourself through the Site;
  • when you complete a form;
  • or when you interact directly with us, including over the phone or via text, social media messaging, or email; and/or
  • when you enter into an Agreement with us for the provision of our services.

This collection could also include:

  • publicly available sources of information; and/or
  • any third party that you consent to us collecting information from.

Relevant to the services engaged, and the stage of delivery of those services, third parties that we collect your personal information from could include:

  • any relevant police department, or other government agency, or department as required to facilitate your Agreement or application with the Agencies;
  • your previous employers; and/or
  • your representatives.

If we collect personal information about you from somebody else, we will take reasonable steps to make sure you and the other party are aware of this Policy in relation to the information we collect.

If someone other than you provide us with personal information about you that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you, as soon as practicable. This notice will be given unless to do so would be in breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

You must not provide us with personal information about another person unless you are lawfully authorised to do so by that person.

1.2 What types of information we collect

The types of personal information we collect include those which we are authorised by law to collect, as well as other information as is reasonably necessary for us to carry out our functions or activities.

This could include:

  • Site information including any information you may provide us through our Site which identifies or could identify you;
  • Browsing and advertising data including any information provided to us by any third party regarding your usage of our Site, as well as your preferences and responses to marketing in relation to us;
  • Contact details including phone number, email, residential address and billing addresses;
  • Identity data including your name, previous names, pronouns, job title, date of birth, gender, and images of you; and
  • Publicly available and third-party information including any information about you we may access or be provided by third party, such as ASIC.

When progressing a soil carbon project with the Clean Energy Regulator, a range of detailed information is required. Similar information is also required for authorised contacts, sole traders, organisations, and trusts.

Therefore, we may require information such as:

  • Land and project data including data which identifies or could identify you and which relates to land owned, leased and/or used by you, or by an entity you control at least in part;
  • Financial Data including your bank account details where you have provided these to us for invoicing or reconciliation purposes, or to allow us to make a payment to you. CarbonLink does not collect or store payment card details and does not operate a merchant facility;
  • Transaction data including details of payments from us to you, and other details of services you have purchased from us;
  • Government related identifiers including your passport and driver’s licence numbers;
  • Insolvency and bankruptcy information including details of your bankruptcy or involvement with companies that have gone into administration or been liquidated;
  • Citizenship data including, where you are an Australian visa holder, details of your visa;
  • Compliance information including details of any breach by you of any laws, regulations, industry codes, enforceable undertakings, contracts, or related obligations;
  • Litigation data including details of whether any court proceedings against you are pending or have concluded, and their outcome;
  • Officeholder and employment information including:
    • details of your position as a registered officeholder under the Corporations Act 2001 (Cth) or any other relevant legislation;
    • your professional history, including details of your employment with a company incorporated in Australia or elsewhere and any disciplinary findings made against you; and
  •  
  • Submission data including all data created or collected by us which identifies or could identify you, including when preparing and submitting an application for a scheme as part of our services.

Sensitive information refers to a subset of personal information defined under the Privacy Act, which is afforded a higher level of protection. Sensitive information includes information or an opinion about an individual’s criminal record, political opinions or associations, membership of a professional or trade association, membership of a trade union, philosophical or religious beliefs, racial or ethnic origin, or sexual orientation or practices.

We will only collect sensitive information about you:

  • where you have given express consent to us to do so and the information is reasonably necessary for us to carry out our functions or activities;
  • the use of this information is required or authorised under Australian law or a court or tribunal order; or
  • when the information is necessary for the establishment, exercise or defence of a legal claim.

The types of sensitive information we may collect include your criminal record.

2. Cookies, pixels & tags

When you visit the Site, the server may place a tracker—such as a cookie, pixel, or tag—on your device. These trackers help us understand how the Site is used and which pages are most relevant to visitors. This information may be used to show content or ads we think may interest users of your device.

Behavioural data is also used on our Site to remember your preferences, improve functionality and enhance your browsing experience.

We will obtain your valid consent before using cookies or similar technologies to collect, share, or use personal data for personalisation.

3. Use and disclosure of personal information

We use and disclose personal information about you for the primary purpose of providing you with our services, and for purposes which you would reasonably expect or have consented to including:

  • fulfilling our contractual obligations to you;
  • sales, business development, market analysis, and marketing;
  • compliance with our legal obligations, including complying with our obligations as an authorised representative of a holder of an Australian Financial Services License;
  • employment-related purposes, such as background checks and recruitment; and
  • hosting, storing, and organising data and your personal information using service providers (e.g., cloud hosting, CRM, analytics). This may require the disclosing or storing of your personal information to or with third parties, including business operations subprocesses with either Australian or overseas data hosting, as provided for below in section 3.

In addition to what is set out above, we may also disclose your personal information to:

  • provide our services to you, including to prepare and submit applications on your behalf for schemes administered by the Clean Energy Regulator. This will involve sharing some of your personal information, including sensitive information, with third parties, which may include the Australian government, state agencies or regulatory bodies;
  • our related bodies corporate, including to True Oak Investments Pty Ltd (ABN 81 002 558 956) under whose Australian Financial Services License we operate;
  • our employees, contractors and subcontractors, including third parties to collect and process data;
  • professional advisors, insurers, insurance brokers, banker and auditors;
  • payments systems operators or processors;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any legal proceedings, or in order to establish or protect our legal rights; and
  • your professional advisers and representatives, as requested by you.

We will only disclose sensitive information with your consent or where permitted by law.

We will only collect, store, use and disclose personal information as set out in this Privacy Policy, any agreement that you have with us or as otherwise permitted by law.

3.1 Use and disclosure of personal information overseas

We store your personal information in Australia. However, some of our providers operate globally and may store, transfer or access your personal information in multiple overseas regions. Overseas providers may not be subject to Australian Privacy laws.

We may disclose your personal information to service providers located outside Australia to perform essential business functions and to perform our services. In this regard we:

  • use the access, advertising, analytics, personalisation and collaboration services of Google LLC, located in the United States, European Union and other countries where Google operates data centres;
  • use the advertising, analytics, and personalisation using the services of Meta Platforms, Inc and LinkedIn Corporation, both located in the United States;
  • use work and task management services, including customer reporting, such as Asana, Inc. and Smartsheet Inc., located in the United States;
  • use software testing and fault logging services such as Sentry.io and Gitlab, located in the United States and Germany; and
  • use Identity verification through e-signature providers, such as DocuSign, PandaDocs and Adobe, located in the United States.

We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

3.2 Third parties

While we are committed to keeping your personal information secure, the transmission of information online via the internet is not completely secure. We, together with our service providers will do our best to protect your personal information but information provided is at your sole risk.

We will not sell or lease your personal information to third parties.

We may disclose your personal information to your financial advisor or to your third-party authority or attorney only after you have provided us with your explicit authorisation. Such authorisation is required in writing, and you will be required to provide proof of identity before the authorisation is accepted.

We may be required to collect and use certain government related identifiers to provide certain services to you.

Our website may link to third-party sites. We are not responsible for their privacy practices and recommend reviewing their policies.

4. Marketing Communications

If you do not want us to use your personal information for marketing, event and research purposes you can opt out at any time by contacting us.

You agree and acknowledge that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide. Once you opt out of receiving marketing material from us, you agree and acknowledge that this removal from our distribution lists may take several business days after the date of you request to be removed.

5. Storage and security

We will use all reasonable endeavours to keep your personal information in a secure environment; however, this security cannot be guaranteed. These security measures are designed to ensure your personal information is not subject to unauthorised access, loss or misuse. If you reasonably believe that there has been unauthorised use or disclosure of your personal information, please contact us (see below).

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with applicable laws.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident, we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

In the event of a security incident involving unauthorised access, use or disclosure of personal information where a third party with whom we share personal information is involved, we will seek to work cooperatively with them to protect the personal information we have shared with them.

6. Accuracy of your personal information

We take all reasonable steps to ensure that your personal information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your personal information is not accurate, up-to-date, complete, relevant and not misleading, please contact us (see below) and we will take all reasonable steps to correct it within a reasonable time.

7. Access to personal information we hold about you

If you request access to the personal information we hold about you, or have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request, or notify you of the outcome of this investigation (as applicable) and any subsequent internal investigation. This will be subject to any exemptions allowed under the Privacy Act. You may request this information by writing to:

Carbon Link Operations Pty Ltd (ABN 46 609 904 010)
15 Morgan Street, Gladstone, QLD 4680

or sending an email to us at info@carbonlink.com.au

There may be some situations where we will not be able to provide you with access to your personal information we hold. The situations may include where the access would have an unreasonable impact on the privacy of others, the information relates to existing or anticipated legal proceedings, giving access would be unlawful, or, we have reason to suspect that unlawful activity or misconduct of a serious nature is being or may be engaged in.

If you remain dissatisfied with the way in which we have handled a privacy issue, you may approach an independent adviser or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action that may be available.

When contacting us you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you in that way. We are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

8. Termination of agreement

On termination or expiry of formal agreements, access to data, including personal information, will be governed by the terms set out in the relevant agreement, alongside this Policy.

9. Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so that you are aware of any variations made to this Privacy Policy. You will be deemed to have consented to such variations by your continued use of the Site or our services following such changes being made.