D&K PRIVACY POLICY
V1, 12 April 2026
1. INTRODUCTION AND SCOPE
1.1 Introduction
Dixon & King Pty Ltd ACN 652 615 499 (we, us, our) is committed to protecting the privacy of individuals and ensuring compliance with the Privacy Act 1988 (Cth) and the APPs. This policy outlines how we collect, use, disclose, and manage Personal Information.
1.2 Scope
This policy applies to all Personal Information collected by us in the course of delivering legal services to our clients and carrying on our related business activities, including Personal Information that we may collect from time to time in relation to:
(a) clients, prospective clients and their Associates;
(b) other representatives, agents or professional service providers of clients, prospective clients and their Associates;
(c) representatives, agents or professional service providers of our clients’ counterparties (and their Associates);
(d) suppliers, consultants, and contractors;
(e) regulatory and government stakeholders;
(f) the employees of any of the persons mentioned in Items 1.2(a) to (e) above;
(g) job applicants and recruitment candidates;
(h) event attendees and subscribers; and
(i) website visitors and digital platform users,
(you, your).
1.3 Definitions
In this policy:
APPs means the Australian Privacy Principles set out in Schedule 1 of the Privacy Act.
Associate means, in relation to a person, any one or more of the following:
(a) any Associated Entity (as defined in the Corporations Act 2001 (Cth);
(b) any Child, Parent, Relative or Spouse (as defined in section 995-1 of the Income Tax Assessment Act 1997 (Cth);
(c) any employer of the person;
(d) any entity in respect of which the person holds office as a director or secretary;
(e) any other person who is a director, secretary or shareholder of an entity listed in paragraph (d) of this definition.
Personal Information has the meaning as defined in the Privacy Act, and includes information or an opinion about an identified individual, or an individual who is reasonably identifiable.
Privacy Act means the Privacy Act 1988 (Cth).
Sensitive Information has the meaning as defined in the Privacy Act, and includes Personal Information which includes health information, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, criminal record, and membership of professional or trade associations.
1.4 Obtaining a copy of this policy
This policy is available free of charge on our website: www.dixonking.com. Where we receive a request to provide a copy of this policy in a different format, we will take reasonable steps to comply with such a request.
2. TYPES OF PERSONAL INFORMATION
2.1 Personal Information
Without limitation, the types of Personal Information we may collect about you, include:
(a) name, contact details, date of birth and job title;
(b) identification documents (e.g., passport, driver’s licence);
(c) financial and billing information;
(d) employment history and qualifications;
(e) details regarding the real and personal property you may own or hold a beneficial interest in;
(f) details of any directorships or other offices you may hold;
(g) IP address, browser type, device identifiers;
(h) website usage data and analytics;
(i) cookies and cookie preferences.
2.2 Sensitive Information
We will only collect your Sensitive Information with your consent and where:
(a) required by law (e.g., verification of identity obligations, including obligations under conveyancing legislation, and anti-money laundering and counter terrorism financing (AMLCTF) laws); or
(b) necessary in connection with legal advice or legal proceedings.
2.3 Methods of collection
(a) We may collect your Personal Information by:
(i) providing legal services to you or your Associates;
(ii) providing legal services to your counterparties or their Associates;
(iii) procuring services which are utilised by our business from you, your employer or your employer’s Associates;
(iv) carrying out recruitment processes;
(v) organising and/or attending events or webinars;
(vi) receiving third-party referrals; or
(vii) browsing our website.
(b) We may collect such Personal Information by:
(i) interacting directly with:
(A) you or with your other representatives, agents or professional service providers;
(B) your Associates or with their other representatives, agents or professional service providers;
(C) your counterparties and their representatives, agents or other service providers;
(D) your counterparties’ Associates and their representatives, agents or other service providers,
including through meetings, emails, video meetings, phone calls and text messages;
(ii) carrying out searches of public records (including without limitation titles offices, the Australian Securities and Investments Commission, local government entities and court registries);
(iii) carrying out searches in order to complete AMLCTF screening activities (including by requesting third party service providers to carry out such screening activities on our behalf);
(iv) engaging third parties to carry out verification of identity checks in relation to you (including third parties such as Australia Post, Infotrack and other identity agents who we may engage from time to time); or
(v) you browsing or otherwise interacting with our website.
2.4 Unsolicited Personal Information
(a) From time to time, we may receive unsolicited Personal Information. When we receive such information, we will determine as soon as reasonably practicable whether we could have collected that Personal Information in a manner which complies with Items 2.1 to 2.3 above if we had solicited the information.
(b) If we determine that we could not have collected the Personal Information in a manner which complies with Items 2.1 to 2.3 above if we had solicited the information, or if we do not have any lawful purpose to retain such Personal Information that is aligned with our above functions and activities, we will, as soon as practicable (and provided it is lawful and reasonable to do so), destroy the information or ensure the information is deidentified.
3. PURPOSES FOR COLLECTION AND USE
(a) We collect and use Personal Information for the purpose of:
(i) delivering legal services to our clients;
(ii) managing client relationships and engagements;
(iii) fulfilling legal and regulatory obligations, including verification of identity and AMLCTF screening obligations;
(iv) marketing communications and event invitations;
(v) recruitment and employment processes;
(vi) internal training, quality assurance, and service improvement;
(vii) other purposes incidental or related to the above.
(b) Our website may use cookies and analytics tools to:
(i) enhance user experience; and
(ii) monitor traffic and usage patterns.
(c) We do not use cookies and website analytics tools for marketing purposes.
(d) You can manage cookie preferences via our website.
4. DISCLOSURE OF PESONAL INFORMATION
4.1 Disclosure in ordinary course of business
(a) We may disclose your Personal Information in the course of providing legal services to our clients and procuring services used by our business, including to:
(i) barristers, counsel, and expert witnesses;
(ii) contractors, service providers and financiers of our clients;
(iii) regulators, courts, and government agencies (including titles offices, the Australian Securities and Investments Commission and the Foreign Investment Review Board);
(iv) titles offices and electronic conveyancing platforms, such as PEXA (Property Exchange Australia);
(v) counterparties in transactions or disputes and their representatives, agents or professional service providers;
(vi) third parties who we engage from time to time to carry out AMLCTF screening on our behalf;
(vii) successors in business transfers or restructures;
(viii) our IT and cloud service providers; and
(ix) our accountants, banks and financiers.
(b) We do not ever sell Personal Information.
(c) We will not disclose your Sensitive Information without your written consent.
4.2 Other disclosure
We may also disclose your Personal Information:
(a) if required or compelled to do so under applicable law;
(b) if a permitted general situation (as defined in the Privacy Act) exists, including without limitation:
(i) as we believe may be necessary to reduce or avoid a threat to an individual’s life or health and safety or a serious threat to public health and safety and it is unreasonable or impracticable to obtain your consent;
(ii) as we consider to be appropriate, if we have reason to suspect that unlawful activity or misconduct of a serious nature relating to our functions or activities has been engaged in;
(iii) as we believe is reasonably necessary to assist with the location of a person who has been reported missing; or
(iv) as we believe is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim or for the purpose of an alternative dispute resolution process.
4.3 Automated decision making
(a) We may use computer‑assisted tools to support internal decision‑making processes, including conflict checks, matter‑opening risk assessments, and client due‑diligence screening, including for AMLCTF compliance.
(b) In doing so, we may use Personal Information such as your name, address, contact details and date of birth.
(c) These tools do not make final decisions about you or our clients (on an automated basis or otherwise). All decisions that may affect your rights or interests are reviewed and confirmed by a qualified member of our staff.
4.4 Professional duties and legal professional privilege
(a) Nothing in this policy requires us to disclose Personal Information (or any other information) in a manner that is inconsistent with legal professional privilege, our duties of confidentiality as legal practitioners, or the other legal obligations we owe to our clients.
(b) Where an APP obligation conflicts with legal professional privilege, our duties of confidentiality or our other professional duties, we will act in accordance with those duties or obligations.
5. OVERSEAS DISCLOSURES
(a) As we are an Australian-based company, Personal Information we hold will primarily be collected, stored and used in Australia and disclosed to recipients located in Australia. Our cloud back up service provides host all of our information on servers located in Australia.
(b) From time to time, in the course of providing legal services, we may also send Personal Information overseas (for example if our clients are located overseas, or if our clients’ counterparties or stakeholders are located overseas).
(c) We will only disclose Personal Information to a third party located overseas (including a data back-up, storage and processing service provider hosted outside of Australia) if:
(i) you have consented or otherwise instructed us to do so; or
(ii) we are reasonably satisfied that the recipient of the information is subject to a law that is substantially similar to the Privacy Act and you have mechanisms available to you to enforce your rights under that law; or
(iii) we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs (other than APP1) in relation to Personal Information, including by entering into an enforceable contract with such recipient requiring them to comply with such APPs; or
(iv) if a relevant permitted general situation exists of the kind mentioned in Item 4.2 above.
6. DATA SECURITY
(a) We take reasonable steps to ensure that Personal Information is protected by all reasonable safeguards against loss, unauthorised access, unauthorised use, modification, disclosure or any other misuse.
(b) We also maintain a Privacy Management Plan to document the types of Personal Information held by us and to create appropriate systems and organisational measures to ensure we manage the Personal Information we hold in accordance with this policy, the Privacy Act and the APPs.
7. DATA RETENTION AND DESTRUCTION
We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected, or as required by law or professional conduct rules which apply to us. When no longer needed, information is securely destroyed or de-identified.
8. MARKETING COMMUNICATIONS
We may send newsletters, legal updates, and event invitations to our clients and other individuals in our database. You can opt out at any time via unsubscribe links or where no such links are provided, by contacting us directly.
9. ACCESS, CORRECTIONS AND COMPLAINTS
9.1 Your rights
(a) Under the APPs, you have the right to:
(i) access your Personal Information;
(ii) request correction of inaccurate or outdated Personal Information.
(b) A request to amend Personal Information may be refused by us if it is not reasonable in the circumstances to make those corrections, having regard to the purpose for holding the information. For example, requests to correct details on academic qualifications sourced and verified by issuing authorities will typically be refused.
9.2 How to make a request
Requests for access or correction should be directed to our Privacy Officer using the contact details below. We will respond within a reasonable time and may require verification of identity.
9.3 Complaints
If you believe we have breached the APPs, you may lodge a complaint with our Privacy Officer. If unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
10. INTERNAL GOVERNANCE AND ACCOUNTABILITY
We maintain internal policies and procedures to ensure compliance with privacy obligations, including:
(a) staff training and awareness;
(b) privacy impact assessments for new systems;
(c) breach response protocols; and
(d) regular reviews of data handling practices.
11. POLICY UPDATES
This policy was last updated on 12 April 2026. We may update this Privacy Policy from time to time. Changes will be published on our website with a revised “last updated” date. We encourage you to review the policy periodically.
Contact Details
Attn: Privacy Officer
Email: privacy@dixonking.com
Address: GPO Box 1070, ADELAIDE SA 5001