About this privacy policy
At Lavan we are committed to protecting your privacy and the confidentiality of your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).
This privacy policy explains why and how we collect your personal information, what we collect, how we use and share it, what happens if it is not provided, how we handle information about others, how you can access or correct your information and how to make a complaint.
Why we need to collect your information
We collect your personal information for purposes including verifying your identity, providing legal services, improving our operations and complying with our legal and regulatory obligations including complying with Australia’s Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) laws.
Types of personal information
Lavan may collect and hold information about:
- clients, business associates, beneficial owners, related entities and potential clients and their employees
- suppliers and their employees
- employees, contractors and prospective employees
- other people who come into contact with Lavan.
The types of personal information that Lavan (or Lavan’s third-party service provider) may collect and hold includes (but is not limited to) the following:
- your full name, residential address, email and phone number
- photo ID and unique identifier, such as a passport or driver’s licence number
- occupation and nationality
- date of birth, gender and marital status
- the identity of any person acting on your behalf or on whose behalf you are receiving services
- entity structure, directors, beneficial owners and their locations
- nature and purpose of the business relationship or transaction
- information about your legal issues and personal circumstances
- health information
- politically exposed person and sanctions status
- any other information you provide to us by any means.
How we collect personal information
We may collect personal information from or about you when you (or your representative):
- use our services
- visit us or meet with our representatives
- communicate with us
- sign up to receive information from us
- use our website
- apply for or accept employment with us
- provide or offer to provide services to us.
We collect personal information only by lawful and fair means.
We will generally collect information by way of face-to-face meetings, completed forms, business cards, telephone conversations, video-link meetings, applications, interviews, emails, letters, text messages, social media and invitations.
In some circumstances we may collect personal information about you from a third party. Some examples of third party sources include ASIC, ASX, registers of companies and trusts, financial institutions, professional intermediaries, referees, medical professionals and publicly available records..
If we provide a designated service under AML/CTF laws, your personal information may be shared with and stored by our third‑party provider supporting our customer due diligence obligations.
Cookies are small pieces of information stored on the web browser on your computer. Any web server (including our web server) may from time to time:
- store one or more cookies on your web browser
- request your browser to send data back to our web server
- request your browser to send a cookie which has been stored on your web browser by another web site in the same internet domain.
Our website may store cookies on your web browser to improve your use of our website the next time you visit. Cookies allow a website to track information about use and behavioural patterns on a website. We may use cookies to measure visitor use of our website but we will not collect or store any personal information about you.
Most web browsers allow you to either accept or reject a cookie. You can also review cookies that are stored by your web browser and remove any cookies that you do not want. In some cases, if you reject a cookie, the website may not perform at its optimum capacity or you may not be able to access certain aspects or content on our website.
Who we may share your information with
Purpose
Lavan may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in any other circumstances authorised or required by the Privacy Act or otherwise at law.
In general, we will use and disclose your personal information for the following purposes:
- establish and verify your identity before providing certain services to you
- conduct our business
- provide, develop and market our services
- communicate with you
- purchase from you
- assess and manage money laundering, terrorism financing, proliferation financing risks or related risks associated with the provision of our services
- comply with our legal, professional and regulatory obligations (including under the AML/CTF Act)
- help us manage and enhance our services
- for any purpose for which the information was provided
- any other purpose related to any of the above.
Disclosure of personal information
Lavan may disclose your personal information to:
- other offices of Lavan
- individuals or organisations in connection with providing our services or who perform functions on our behalf (such as barristers, experts, auditors, witnesses)
- credit reporting bodies and financial regulatory agencies
- third parties to comply with our AML/CTF obligations (including AUSTRAC and third party service providers)
- courts, tribunals, land registries, financial institutions and regulatory authorities
- anyone else who you authorise us to disclose information to or we are obliged by law to disclose information to.
- Lavan may also collect personal information from these individuals and organisations and will deal with this information in accordance with this privacy policy.
Transfer of information overseas
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- We may transfer personal information we have collected about you to overseas recipients. These overseas recipients include third party service providers to whom we outsource certain functions. We will only transfer personal information to overseas recipients in accordance with our obligations under the Privacy Act.
- These overseas recipients will treat any personal information collected in Australia in accordance with Australian privacy laws and any applicable local laws relating to privacy. In the event that we do transfer personal information to overseas recipients, those recipients are likely to be located in the United States and the United Kingdom.
Emails you receive from us
We may use your email address to send you Lavan publications, newsletters, seminars or events. We may also contact you by email to seek your opinion or comment on our website and our service offerings. We do not send spam emails. You can unsubscribe from our emails at any time. You can also contact us if you prefer not to receive this information and we will comply with your request.
Information collected through our website
To use our website, we may require you to provide certain information about yourself. We may request your email address and information about you (such as your age) and website user preferences. This information will be used to create a user identification key to enable you to access certain parts of our website and to give you a better quality online experience.
The information you provide to us will be aggregated to establish an average to enable us to understand our audience and how our website is used. The information we collect may also help us to assist in the detection and prevention of fraud and other malicious activities on our website.
From time to time, we may rely on the information we receive from you through our website and report it to third parties. No personal information or confidential information that can identify a user will be disclosed to a third party in these circumstances.
Sensitive information
Some personal information that we collect is ‘sensitive information‘. Sensitive information includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences, criminal records and health information about an individual.
Unless you agree otherwise, sensitive information will only be used and disclosed for the purpose for which it was provided, for a directly related secondary purpose or where certain other limited circumstances apply (eg where required by law).
What happens if we cannot collect your information
If you do not provide us with your personal information, we may not be able to verify your identity, comply with our legal obligations and provide you (or the person on behalf of whom you are acting) with legal services.
Information about other people which you provide to us
If you provide personal information to us about someone else (such as one of your directors or employees) you must ensure that:
- the information is correct and has been collected and disclosed in accordance with the applicable privacy legislation
- you are entitled to disclose that information to us
- without taking any further steps, we may collect, use and disclose that information in accordance with this privacy policy.
You must ensure the individual concerned is aware of the various matters detailed in this privacy policy relating to that individual including, our identity, how to contact us, our purposes of collection, our information disclosure practices (including disclosure to Fist AML, AUSTRAC and overseas recipients), the individual’s right to obtain access to the information, how to make complaints about the handling of the information and the consequences if the information is not provided (such as our inability to provide services).
In addition, Lavan may disclose personal information to you about other individuals in the course of providing services to you. If this occurs, you agree to use, disclose, handle, collect and transfer that information in accordance with the Privacy Act.
Managing your personal information
Security and respect for your privacy
We take your privacy seriously. All personal information is treated as strictly confidential. We may hold personal information in hard copy and electronically. The Privacy Act requires Lavan to take reasonable steps to protect the security of all personal information. Lavan personnel are required to respect the confidentiality of personal information and the privacy of individuals.
Lavan will take reasonable steps to protect personal information we hold from misuse or loss and from unauthorised access, modification, alteration, disclosure or destruction. These measures include the implementation of a range of physical, operational and technological safeguards such as firewalls, encryption, anti-virus software and data backup systems.
Nothing in this Privacy Policy limits our obligations of confidentiality or client legal privilege. However, there may be circumstances where we are compelled to disclose confidential information to AUSTRAC under our AMLCTF obligations.
If we no longer require your personal information for any of the purposes outlined in this privacy policy and we are not required by law or court order to retain it, we will take reasonable steps to destroy or de-identify the information. AML/CTF information and transaction records are kept for 7 years after the business relationship ends or the transaction is completed, as required by AML/CTF laws.
Where a data breach is likely to result in serious harm to an individual whose personal information is involved, we will comply with the Notifiable Data Breaches scheme in the Privacy Act, including notifying the OAIC and affected individuals, as required.
Access to your personal information
In most cases, you can request to see the personal information we hold about you. We will handle requests for access to your personal information in accordance with the Privacy Act and subject to our contractual arrangements where personal information is held by a third party. If you would like a copy of some or all of your personal information, please contact us using the details below. If your request is urgent, please clearly indicate this in your request. We may ask you to verify your identity before giving you access and may also ask that you pay our reasonable costs for complying with your request.
Changing your personal information
We attempt to keep all personal information which we hold about you up-to-date and accurate. You may ask us to correct or remove information which you think is inaccurate, incomplete, out-of-date, irrelevant or misleading. If you would like to amend any of your details or the information which you have provided us, please contact us using the details below. We may ask you to verify your identity before giving you access or making corrections, and we may charge a reasonable fee for providing access (but not for making a correction).
We are not responsible for any problems that may arise if you do not give us accurate, truthful or complete information, or if you fail to update such information.
Making a privacy complaint
If you have any concerns regarding our management of your personal information or would like to make a complaint about a breach or a potential breach by us of our privacy policy, the Australian Privacy Principles or the Privacy Act, please direct your complaint to our People and Culture Manager using the details below. We will contact you within 24 hours to acknowledge receipt of your complaint and will then provide a full response to your complaint within 7 days.
Whilst we aim to resolve your complaint expeditiously and to your satisfaction, if you are not satisfied with our response or we do not resolve your complaint within 30 days, you are entitled to lodge a complaint with the Office of the Australian Information Commissioner.
Changes to our privacy policy
It may be necessary for us to review and amend our privacy policy from time to time. We reserve the right to change our privacy policy at any time. We may notify you about changes to this privacy policy by posting an updated version on our website.
How to Contact us about your privacy
If you have any queries about our privacy policy, would like to access or change your personal information or would like to make a complaint concerning the use or handling of your personal information, please contact our People and Culture Manager on:
Address: Lavan, Level 20, 1 William Street, Perth, WA 6000
Telephone: +61 8 9288 6000
Facsimile: +61 8 9288 6853
Email: privacy.manager@lavan.com.au
Dean Hely
Managing Partner June 2026