Privacy Policy

Updated 14 September 2026

1. General

1.1 This Privacy Policy is for customers of TBA (NSW) Pty Ltd trading as Theodore Bruce ACN 145 506 716 and its Related Bodies Corporate (as defined in section 50 of the Corporations Act 2001 (Cth)), collectively the “Company”.

1.2 The Company is committed to protecting your privacy when you deal with it and when you use the Company’s website (“Website”). The purpose of this Privacy Policy is to explain:

a. the application of this Privacy Policy;
b. the kind of information the Company may collect about you, how we collect it, and how we use it;
c. how we may disclose that information;
d. how you can access the information we hold about you;
e. when we may use your information to contact you;
f. the protection of your personal information; and
g. how you can make a complaint.

2. Application of this Privacy Policy

2.1 This Privacy Policy applies to personal information collected by the Company, whether we have asked for the information or not. The Company is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

2.2 The Company will review this policy regularly, and may update it from time to time. If we make changes, we will post those changes on the Website.

3. Collection and use of personal information

3.1 Why we collect personal information

The Company collects personal information about you:

a. because we need it to provide a product or service that you have requested, for example, if you have requested information from this Website; or
b. because you work for us, or apply to us for a job or work experience; or
c. because we are legally required to.

3.2 How we collect information

Broadly, there are two types of information or data we collect:

a. Information that you specifically give us, for example:

i. Forms: Sometimes you may provide information about yourself when you are filling in a form. This type of information may include your home address, business address, telephone number, business telephone number, email address and date of birth.

ii. Permissions. Sometimes you will be asked to confirm that you agree to a particular activity. For example, you may need to expressly agree that you would like to receive a newsletter or to confirm that you agree to the terms and conditions of a competition.

You may be able to make changes to the information you provided us (for example, if you change your email address) or withdraw the permission you gave us for a particular service. We will make it clear how you do that.

b. Data we collect that tracks your activity

i. Data regarding your use of this and associated websites may be linked to personal information you have chosen to share with us when you register. Most Internet browsers automatically accept cookies. However, you can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit.

ii. A cookie is a small information file sent to your computer, mobile or other device when you visit a website. It recognises your device on future visits. These types of files help us remember your visits to this website, assisting us in improving your site experience as well as ensuring that you see relevant online adverts or offers. Apart from the cookies that help us remember your browsing preferences, language, or search parameters, another type of performance cookies collects anonymous information on how people use the site. We use third party services such as Google AdWords and Analytics to merge this data with other users to enable us to improve how this site operates. This stored data does not save any personal details that might identify you. This process helps us provide you with an online browsing experience that is more suited to your selections in order to make each visit more tailored. We use these cookies to collect information about your browsing habits in order to make advertising relevant to you and your interests.

iii. This Website does not collect personally identifiable information about individuals except when such individuals specifically provide such information on a voluntary basis.

4. Disclosure of personal information

4.1 Disclosure of personal information to Related Bodies Corporate

The Company may exchange your personal information with Related Bodies Corporate of the Company so that the Company may provide an integrated service to its customers. Recipients may use this information for any of the purposes mentioned in section 3.

4.2 Disclosure of personal information to third parties

a. The Company may disclose your personal information to third parties, including Commonwealth and State government departments, verification service providers and other organisations, for the following purposes:

i. to provide the service you wish to use;
ii. to customise and promote Company services which may be of interest to you;
iii. to provide technical support to you to use Company services;
iv. to conduct customer due diligence, such as verifying your identity as required by law;
v. if permitted or required by law; or
vi. otherwise with your consent.

b. The Company may also disclose your email address and home address to third parties for the purposes of direct marketing the Company’s services including brochures, videos, information about promotions, news and other information about our website, products, services or special promotions.

c. You will be able to opt-out of direct marketing at any time if you so choose.

d. Under no circumstances will the Company sell or receive payment for licensing or disclosing your personal information.

5. Accessing your personal information

5.1 You have the right to request access to personal information that is held by the Company about you.

5.2 You also have the right to request the correction of any of your personal information that the Company holds. The Company will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date. To seek access to, or correction of, your personal information please contact the Company by email on privacy@theodorebruce.com

6. Use of your personal information to contact you

6.1 We will never knowingly send you unsolicited commercial electronic messages. More information on the Spam Act 2003 (Cth) is available from the regulator’s website: www.acma.gov.au/spam

6.2 We may use information that we know about your likes and interests to tell you about other Company products and services. We may know about your likes and interests because you have provided that information.

7. Protection of your personal information

7.1 The Company has implemented appropriate physical, electronic and managerial security procedures in order to protect personal information from loss, misuse, alteration or destruction. The Company regularly reviews security and encryption technologies and will strive to protect information to the fullest extent possible.

7.2 We encourage you to be vigilant about the protection of your own personal information when using third party digital services.

8. Credit card information

8.1 Your credit card details are only stored and transmitted in encrypted form. Unencrypted credit card information is NOT stored on our internet servers. Online credit card payments are currently processed using a third party payment gateway service.

8.2 If you use your credit card and the transaction is manual rather than electronic, the imprinted record will be stored by the Company for the period that financial records are required to be retained.

9. Making a Complaint

9.1 If you have a complaint about the way we handle your personal information, you may contact the Office of the Australian Information Commissioner by calling them at 1300 363 992, making a complaint online at www.oaic.gov.au or writing to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.

10. Privacy and Change of Control

10.1 In the event that the Company goes through a business transition, such as a merger, being acquired by another company or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred.

11. Linked sites

11.1 This Website may contain links to other sites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy statements of any linked sites as their privacy policy may differ from ours.