Kubed Legal Privacy Policy

Kubed Legal Pty Ltd ACN 138 124 660 (Kubed Legal, we, us, our) respects and upholds the Australian Privacy Principles established by the Privacy Act 1988 (Cth) (Privacy Act). This Privacy Policy sets out how Kubed Legal collects, uses, holds, discloses and manages personal information, including the personal information we collect to meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules 2025 (Cth) (AML/CTF Rules). In this Privacy Policy you can also find out how to change inaccurate personal information and the process to opt out of receiving future communications from us.

This Privacy Policy is dated 24 June 2026. We may update this policy from time to time and we encourage you to review it regularly to ensure you are aware of any changes. The current version is available on our website.

Our AML/CTF obligations and your information

From 1 July 2026, when we provide certain legal services (designated services under the AML/CTF Act, such as acting on the purchase, sale or transfer of real estate or of a business or entity, handling money or property in a transaction, or creating or restructuring a company or trust), we are required by law to collect and verify information about our clients and other relevant persons. This is known as customer due diligence. Because of these obligations we are required to:

    • verify your identity before we provide a designated service;
    • identify and verify the beneficial owners of a company, trust or other entity (broadly, the individuals who ultimately own or control it);
    • determine whether you are a politically exposed person (a PEP), being a person who holds, or whose family member or close associate holds, a prominent public position;
    • assess and manage money laundering, terrorism financing and related risks; and
    • make reports required by law and keep records for at least 7 years.

How does Kubed Legal collect and hold your personal information?

Typically, we collect your personal information when you provide it directly to us. For example, when you request or receive services from us, when you complete and submit the enquiry form on our website, or when you apply for a job with us. There may also be occasions when we collect your personal information from other sources, such as a publicly maintained record (for example ASIC, land registries, and court and regulatory filings), an identity verification agent or electronic verification service provider, a financial institution, or another party involved in your matter. Kubed Legal will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect it from you.

When you visit our website, we collect non-personal information such as the type of web browser and operating system you are using and the address of any referring website or search engine. This information is provided by your web browser and is stored for statistical purposes. We use it for website traffic analysis and system administration purposes only, and no attempt is made to identify users or their browsing activities.

What type of personal information will Kubed Legal collect and hold?

The type of information we collect from individuals includes personal information relating to clients (and potential clients) who contact us, as well as consultants, employees and applicants for employment. The personal information we may collect could include: first and last names; contact details (including phone numbers, addresses and email addresses); date of birth; professional information such as business addresses, email addresses, phone and fax numbers and job title; further information relating to facts or opinions that are part of an enquiry on behalf of a client (or potential client); information specific to the legal advice sought by a client or arising in the course of giving legal advice; and information about people’s dealings with us or our clients, including visits made to our office or to events with which we are involved. In some circumstances, Kubed Legal may also hold other personal information provided by you.

To meet our AML/CTF obligations we may also collect: photo identification and identifier numbers (such as a passport or driver licence number); information about your source of funds or source of wealth; and information about the beneficial ownership and control of an entity.

Information we collect could also contain sensitive information. Sensitive information is defined as a subset of personal information which, under the Australian Privacy Principles, is provided a higher level of protection. The kind of sensitive information we may collect could include: information or opinions relating to ethnic origin, racial origin, political opinions, membership of a political association, membership of a trade association or trade union, religious beliefs or affiliations, sexual orientation and practice, and criminal records; and health information and biometric information. For AML/CTF purposes, sensitive information may include biometric information (such as facial features used for automated identity verification) and information collected to determine whether you are a PEP. We collect sensitive information only where permitted by law and, where required, with your consent.

Any information, whether personal information or sensitive information, that is collected will be referred to as “information” or “personal information” for the purposes of this Privacy Policy. Information received from third parties will be protected as set out in this Privacy Policy, and all reasonable steps will be taken to make you aware that we hold information about you and how we collected it. If you have provided us with a third party’s information, we will assume that you have the consent of the third party to do so.

What does Kubed Legal do with your personal information?

We use your personal information to provide the services or information you have requested; for accounting, billing and other internal administrative purposes; for developing and facilitating a business relationship with you or an entity with which you are connected; and to meet our legal and professional obligations, including any prescribed by the AML/CTF Act, the AML/CTF Rules, the Legal Profession Uniform Law Application Act 2014 (Vic) and the Legal Profession Uniform General Rules 2015 (Vic). For enquiries submitted through our website, your information will be used to respond to your enquiry. For online job applications submitted through our website, your information will be used to assess and process your application. We may also use your information to provide you with legal updates and news relevant to you and your business. You may opt out of receiving these communications at any time by contacting the Privacy Officer whose details are provided below.

Where personal information is used or disclosed, Kubed Legal takes reasonable steps in the circumstances to ensure it is relevant to the purpose for which it is used or disclosed. You are under no obligation to provide your personal information to Kubed Legal; however, without certain information Kubed Legal may not be able to provide its services to you. It is also an offence under the AML/CTF Act to use a false name or to fail to tell us any other name you are commonly known by.

Who will Kubed Legal disclose your personal information to?

Personal information is only shared with Kubed Legal employees, contractors or third parties who are directly engaged in the provision of legal services or administrative services, such as invoicing, advising or providing information to you. Depending on your matter, this may include other parties involved in completing or processing it, such as the other side, your lender, broker or agent, a land registry, the relevant State Revenue Office, and an electronic lodgement network operator such as PEXA or Sympli, as well as identity and information service providers such as InfoTrack. Personal information will also be disclosed to an appropriate third party if it is required by law.

To meet our AML/CTF obligations we may also disclose your personal information to the Australian Transaction Reports and Analysis Centre (AUSTRAC), the Australian Sanctions Office, and (if applicable) other entities in our AML/CTF reporting group. Where the law prohibits us from doing so, we will not disclose to a customer the fact that a report has been, or may be, made to AUSTRAC.

Overseas disclosure

Some of our service providers store or process information outside Australia, which means your personal information may be disclosed to, or accessible from, overseas. We take reasonable steps in the circumstances to ensure that overseas recipients comply with the Australian Privacy Principles or are bound by a substantially similar privacy scheme, unless you consent to the overseas disclosure or it is otherwise required or permitted by law. The countries in which your information may be stored or accessed include New Zealand, the United Kingdom, the United States and (where international intellectual property filings are involved) Switzerland, and may include other countries where our service providers operate.

Openness, access and correction

You have a right to access and amend the personal information we hold about you by contacting the Privacy Officer at the address provided below. Where Kubed Legal holds information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how access is provided (for example by emailing or mailing it to you). If you believe the personal information we hold about you is incorrect, incomplete or inaccurate, you may request amendment of it. In certain circumstances, we are permitted to deny a request for access, or to limit the access we provide. We reserve the right to charge a small administrative cost for retrieving your information.

Marketing

From time to time we may send out information relating to legal services that Kubed Legal offers, where we have obtained your consent or where, in the circumstances, it would be reasonably expected that we would use your information for this purpose. For those who do not wish to receive such information, we have an opt-out procedure which can be activated by contacting the Privacy Officer whose details are provided below. Your consent to receiving this information will remain current until you advise otherwise.

Retention and destruction of personal information

Once your personal information is no longer required by Kubed Legal, we will take all reasonable steps and use appropriate technology to destroy or de-identify it. In some circumstances, Kubed Legal may be required by law to retain your personal information after the purpose for which it was collected, or the relationship, has ended. This includes the requirement under the AML/CTF Act to keep certain records for at least 7 years. If your personal information is retained, the protections described in this Privacy Policy will continue to apply.

Security of information

Kubed Legal will take reasonable steps in the circumstances to ensure that personal information it holds is protected from loss, misuse, and unauthorised access, alteration, disclosure or destruction. It should be noted that any transmission of information is never completely free from threat or error. Kubed Legal specifically recognises that emails sent to our inbox may not be completely secure, and you should therefore take particular care with the content of such emails before sending information by this means.

Questions and complaints

If you have any questions about this Privacy Policy, or if you believe we have failed to keep one of our commitments to you in relation to the handling of your personal information, please contact our Privacy Officer:

Privacy Officer: Georgie Jensz, Principal

Kubed Legal Pty Ltd, Level 2, 439 High Street, Prahran VIC 3181

Email: georgie.jensz@kubedlegal.com.au    Phone: (03) 9529 4714

We will respond and advise whether we agree or disagree with the complaint, and offer an explanation and any potential action that may be taken in response. If you are not satisfied with our response (having provided us with a reasonable time to respond), we urge you to contact the Office of the Australian Information Commissioner (OAIC) by:

  • Phone: 1300 363 992 (local call cost; calls from mobiles and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749
  • TTY: 1800 620 241 (dedicated to the hearing impaired only; no voice calls)
  • TIS (Translating and Interpreting Service): 131 450
  • Email: enquiries@oaic.gov.au
  • Post: GPO Box 5288, Sydney NSW 2001

Kubed Legal website

Upon visiting Kubed Legal’s website, its server will automatically make a record of the visit and may log the following information for statistical, analytical and administrative purposes:

  • the server address of the user – used to consider which users attend the site regularly and to tailor the site to their interests and requirements;
  • the date and time of any visit to the site – used to identify the website’s peak traffic and to avoid inconveniencing visitors by scheduling maintenance outside those hours;
  • navigation of the site by users and documents downloaded from the site – used to determine which pages, documents or sections are most accessed, and to help make important information more easily accessible;
  • the duration of a user’s visit – used to indicate how engaging the content is; and
  • IP address, computer operating system, browser type and screen resolution – used to better understand the website’s usage and for browser-specific coding.

Kubed Legal may use cookies while users are browsing its website. A cookie is sent by an internet website, contains a piece of information, and is stored in your browser when you access certain information from that site. There are two types of cookies with two different functions: a session cookie is stored in memory, while a persistent cookie is placed on your hard disk. Kubed Legal does not use persistent cookies, and when your browser is closed the session cookie set by Kubed Legal’s website is destroyed; no personal information which might identify you is maintained after you leave our website.