Privacy Policy


Adherium Limited ACN 605 352 510 (ADR, we, us, our) respects your privacy and understands that your privacy is important to you. This privacy policy summarises how we collect, store, use and disclose your personal information. If you have any questions regarding this privacy policy, you should contact ADR in any of the ways specified under “Contact us”, below.


Collecting your personal information

“Personal information” is information or an opinion, whether true or not and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable, and includes sensitive information.

We will only collect personal information about you if you provide it to us knowingly or otherwise in accordance with this policy. We collect your personal information to allow us to conduct our business functions and to market and sell our products and services, as well as the specific purposes for which we collect your personal information set out in the section entitled “Using your personal information” below. If you do not provide certain personal information, we may not be able to provide certain services to you.

We may collect information on you from a third party including but not limited to, our related entities and regulatory or government authorities. Should a third party provide ADR with your personal information, we assume that you have provided your consent to that third party. If you have any problems or queries with ADR obtaining information on you from a third party, you should approach the relevant third party.

When you acquire services, visit our website (see below), request information about us or our products, or otherwise contact us (via our website or otherwise), we may collect personal information about you including (but not limited to) your full name, email address, telephone number, residential address, date of birth, tax file number or other similar information. We are authorised to collect tax file numbers by the Income Tax Assessment Act 1936 (Cth). It is not compulsory for you to provide your tax file number for our products and services, but if you do not, taxation law may require additional deductions to be made from amounts payable to you.

We may keep a record of visits to our website, using “cookies” and “log files” to store your preferences, record session information and collect information on how you visit and access our web pages. This information is collected automatically whenever you use the website. A cookie is a small amount of data (which may include information about a user’s identity, browser type or website visiting patterns) that is sent to your Internet web browser from our web server and stored on your computer. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. If you disable the use of cookies on your web browser or remove or reject specific cookies from our website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

We may also log IP addresses (i.e. the electronic addresses of computers connected to the Internet) to analyse trends, administer the website, track users’ movements on the website, and gather broad demographic information for aggregate use and for advertisers and business partners.

If you provide us with personal information that we have not requested (unsolicited personal information) we will, unless required or permitted by law, delete or destroy it as soon as possible after receiving it.


Collecting sensitive information

We do not generally collect sensitive information about you unless required by law. Sensitive information includes information relating to:

  • - race;
  • - political or religious beliefs;
  • - sexual preferences;
  • - membership of professional or trade associations or unions; and
  • - health information.


Links to third party websites

Our website may contain links to other sites. We are not responsible for the privacy policies of such sites. We recommend that you examine the privacy policy for all third party websites you visit to understand their procedures for collecting, using and disclosing personal information.


Using your personal information

We collect, hold and use your personal information to:

  • - communicate with you and assist us in the provision of products and services to you;
  • - assist you by providing you with information and support, and managing and administering any account you may hold with us;
  • - administer our website and make enhancements to our website in order to improve the users experience;
  • - keep you up to date with events, products and services that may be of interest to you;
  • - help us research the needs of our shareholders;
  • - comply with legal and regulatory obligations; and
  • - allow us to provide advertising material to you regarding us, our related entities and our business partners.

We may also collect personal information about individuals who are not our shareholders themselves but are individual employees or associates of a shareholder with whom we deal.

You consent to us using your personal information in the above ways. We may collect and use your personal information for other purposes not listed above. If we do so, we will make it known to you at the time we collect such information.

We will not use personal information provided by you to us in a manner inconsistent with the Privacy Act 1988 (Cth), the Australian Privacy Principles or any other relevant laws or guidelines.


Disclosing your personal information

We may provide your personal information on a confidential basis to third parties to achieve the purposes specified in “Using your personal information”, above. These parties may include our related entities, third parties that provide products and services to us or through us, or other third parties such as regulatory or government authorities and any authorised representatives on your account. We may also disclose your personal information to our website host or IT service providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner.

Generally, we’ll only disclose your personal information:

  • - for the purposes set out in this privacy policy or any agreement you enter into with us (please refer to “Using your personal information”);
  • - in circumstances permitted by the Australian Privacy Principles;
  • - if we are otherwise required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth); or
  • - if the disclosure is made with your consent.

We will not sell, rent or lease your personal information to any other party.


Overseas disclosures

Some of your personal information may be disclosed, processed or stored overseas by us, our related entities or by our third party service providers. In particular, as at the date this privacy policy was most recently updated, your personal information will be disclosed to recipients in New Zealand, and other countries from time to time. This may happen if our related entities are overseas, or if transactions, information, services or products have an overseas connection. Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

You agree to the disclosure and use of such personal information in accordance with this privacy policy, and consent to its disclosure overseas and its use by third parties, including our related entity in New Zealand and such other countries in which those parties or their computer systems may be located from time to time, where it may be used solely for the purposes described in this privacy policy, without us being responsible for such use (or for any breach).



You consent to us using your personal information from time to time to send you information about us or our products and services, as well as the products and services of our related entities and our business partners. You also consent to us sending you such information by means of direct mail, telemarketing, email, SMS or MMS messages. We will only do this if we believe this will be of interest to you. If you do not want us to send you any of this material or if you want to stop receiving direct marketing, you can let us know by using the “contact us” information specified below.


Safeguarding your personal information

We will take reasonable steps to preserve the security of your personal information and other information or data collected by us. We protect your information by using technical and physical security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls, virus scanning tools, data encryption and secure work environments.

Unfortunately, no data transmission over the Internet can be guaranteed as perfectly secure. As a result, although we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us over the Internet. You transmit such information at your own risk.


Accessing and updating your personal information

You are entitled to access personal information that we hold about you. If you request access to your personal information, in ordinary circumstances we will give you full access. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your personal information, we will provide you with reasons for the refusal unless it is unreasonable to do so.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request amendment of it. If we are required to correct any of your personal information, we will take reasonable steps to correct the personal information within 30 days from the day on which the request is made or such longer period as you have agreed in writing. If we do not agree that there are grounds for amendment, we will provide you with our reasons why. If you are not satisfied with the outcome of your request, you can refer your request to the Australian Information Commissioner.


Contact us

If you would like to access the personal information that we hold about you, have a complaint or would like further information about our privacy policy, you can contact us by:


Calling ADR on +64 9 307 2771
We will investigate your queries and complaints within a reasonable period of time and will notify you of the outcome of our investigation.


Amendments to this Privacy Policy

We reserve the right to change this privacy policy at any time by posting an updated version of the policy on our website at You should visit this page periodically to review the privacy policy for changes.


Last updated: 23 Dec 2015