Privacy Policy

1. About this policy

ICM Consulting Pty. Ltd. (ABN 64 143 127 404), trading as Argenti Cloud and using the Argenti brand (Argenti, we, us or our), respects privacy and is committed to handling personal information responsibly and in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

This Privacy Policy explains the kinds of personal information we collect and hold, how we collect and use it, when we may disclose it, how we protect it, and how individuals may request access or correction or make a privacy complaint.

2. Who we are and how to contact us

Legal entity: ICM Consulting Pty. Ltd.

ABN: 64 143 127 404

Registered business name: Argenti Cloud

Brand: Argenti

Office: Level 3, 82 Elizabeth Street, Sydney NSW 2000

General and privacy enquiries: hello@argenti.com.au

Telephone: +61 2 9140 9400

3. Scope

This policy applies to personal information handled by Argenti in connection with our website, enquiries, marketing, events, recruitment, client and prospective-client relationships, suppliers, partners, professional services and other business activities.

It does not replace privacy terms contained in a specific client contract, employment arrangement or other agreement.

4. Personal information we collect and hold

The personal information we collect depends on how an individual interacts with us and may include:

• Identity and contact details: name, email address, telephone number, postal address and preferred contact method.

• Professional information: job title, employer, business contact details, industry, role and professional interests.

• Enquiry and relationship information: messages, meeting notes, service interests, proposals, correspondence, feedback and records of our relationship.

• Client, supplier and partner information: authorised contacts, project information, contract administration details, billing contacts and records required to provide or receive services.

• Event and marketing information: event registrations, attendance, content preferences, communication subscriptions, consent and unsubscribe records.

• Recruitment information: resumes, qualifications, employment history, references, work rights and information supplied during recruitment.

• Website and technical information: IP address, browser and device information, referring pages, pages viewed, dates and times of visits, session information, interaction data and online identifiers.

• Security information: fraud, bot-detection, form-validation and security signals used to protect our systems and website.

• Other information: information an individual chooses to provide, or that we are authorised or required by law to collect.

We do not routinely seek sensitive information through our public website. If sensitive information is required for a particular purpose, we will collect it only where permitted by law and, where required, with consent.

Individuals should not include sensitive, security-classified or regulated information in a general website enquiry unless we have provided an approved secure method.

5. How we collect personal information

We may collect personal information:

• directly from an individual through website forms, email, telephone, meetings, events, workshops, surveys and business interactions;

• when an individual subscribes to communications, downloads a resource or registers for an event;

• from an employer, colleague, client, recruitment referrer, supplier, partner or other authorised third party;

• from publicly available professional and business sources, including company websites, tenders and professional networking platforms;

• automatically through website logs, cookies, similar technologies, analytics tools and security services; and

• as otherwise authorised or required by law.

6. Why we collect, hold, use and disclose personal information

We may handle personal information to:

• respond to enquiries, requests and complaints;

• assess needs, prepare proposals and manage prospective-client relationships;

• deliver, manage, secure and improve our services and client engagements;

• manage events, meetings, resources, subscriptions and communications;

• administer contracts, suppliers, partners, invoicing and business operations;

• recruit and manage personnel and contractors;

• operate, secure, monitor, troubleshoot and improve our website and systems;

• understand website use and evaluate the effectiveness of content, services and campaigns;

• meet legal, regulatory, insurance, audit, governance and record-keeping obligations;

• prevent fraud, misuse, security incidents and unlawful activity; and

• exercise or defend legal rights.

7. Disclosure of personal information

We may disclose personal information where reasonably necessary for the purposes described in this policy, including to:

• our employees, officers and contractors who need the information to perform their roles;

• website hosting, customer relationship management, communications, collaboration, security, analytics, event, recruitment, cloud and information-technology service providers;

• professional advisers, auditors, insurers and legal representatives;

• clients, partners and suppliers where an individual has authorised the disclosure or it is reasonably expected in the circumstances;

• government agencies, regulators, law-enforcement bodies or courts where required or authorised by law; and

• a purchaser, adviser or participant in a proposed or completed corporate transaction, subject to appropriate confidentiality arrangements.

We do not sell personal information.

8. Direct marketing

Where permitted by law, we may use contact details to send professional insights, event invitations, service updates and other business communications that may be relevant. We obtain consent where required and provide a clear way to unsubscribe from commercial electronic messages.

An individual may opt out at any time by using the unsubscribe facility in a message or contacting us. We retain the minimum information needed to record and respect an unsubscribe request, even if other information is deleted.

9. Website technologies, cookies and analytics

Our website uses cookies and similar technologies to operate and secure forms, remember consent choices, understand website use, improve the website experience, measure campaigns and connect website activity with enquiries.

These technologies may collect technical and interaction information such as IP address, device and browser characteristics, URLs, referrers, timestamps, pages viewed and session activity.

Our website technology providers include Webflow, HubSpot, Google Tag Manager, Google Analytics 4, Microsoft Clarity, LinkedIn Insight Tag and Cloudflare Turnstile.

Non-essential cookies and browser storage are managed through the website’s consent controls. Further information is provided in our Cookie Policy.

10. Overseas handling and disclosure

Some of our technology and service providers operate globally and may store, process or access personal information outside Australia. Overseas recipients are likely to be located in the United States and may be located in other countries in which our providers or their approved subprocessors operate.

Where the Australian Privacy Principles require it, we take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with those principles, unless an exception applies.

11. Security

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.

Measures may include access controls, authentication, encryption, monitoring, security testing, staff obligations, vendor management, backups and incident-response processes.

No internet transmission or storage system can be guaranteed to be completely secure. Individuals should avoid sending sensitive or confidential information through an unsecured channel unless agreed with us.

12. Retention and deletion

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, to maintain business and legal records, resolve disputes, enforce agreements or meet legal, tax, insurance, audit and regulatory requirements.

As a general guide:

• enquiry and inactive prospective-client records may be retained for up to 24 months after the last meaningful contact, unless the relationship continues or a longer period is reasonably required;

• contract, transaction and financial records may be retained for 7 years or another period required by law;

• unsuccessful recruitment records may be retained for up to 12 months, unless the applicant consents to a longer period or a longer period is required;

• marketing records are retained while a person remains subscribed, and a minimum suppression record may be retained after opt-out so the preference can be honoured; and

• website analytics and security information is retained in accordance with provider settings, operational requirements and applicable law.

When personal information is no longer required, we take reasonable steps to destroy it or de-identify it, subject to backup, legal-hold and technical constraints.

13. Access and correction

An individual may request access to personal information we hold about them and may ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. We may need to verify identity before acting on a request.

In some circumstances, the law permits or requires us to refuse access or correction. If so, we will generally provide written reasons and information about available complaint options.

14. Privacy questions and complaints

A privacy question, access or correction request, or complaint may be sent to the Privacy Officer using the contact details below. Please provide enough information for us to understand and investigate the matter.

We aim to acknowledge a privacy request or complaint within 5 business days and provide a substantive response within 30 calendar days. A more complex matter may take longer, in which case we will keep the individual informed.

If an individual is not satisfied with our response, they may be able to complain to the Office of the Australian Information Commissioner at www.oaic.gov.au.

15. Data breaches

We maintain processes for assessing and responding to suspected privacy and security incidents.

Where the Notifiable Data Breaches scheme or another law applies, we will assess the incident and notify affected individuals and the relevant regulator when required.

16. Children

Our website and services are directed primarily to businesses and professionals and are not intended for children.

If we become aware that we have collected personal information from a child without appropriate authority, we will take reasonable steps to address the situation.

17. Changes to this policy

We may update this policy to reflect changes to our practices, technology or legal obligations. The current version will be published on our website with its effective date.

Material changes may also be communicated through an appropriate additional notice.

18. Contact

Argenti

hello@argenti.com.au

Level 3, 82 Elizabeth Street, Sydney NSW 2000

+61 2 9140 9400