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Privacy Policy

Discover how we manage your personal information at TMX Transform with our transparent Privacy Policy.

TM Insight Holdings Pty Ltd ACN 538 123 449 (trading as TMX Transform) and its related entities (collectively referred to as “TMX Transform”, “we”, “us” or “our”) recognise the importance of your privacy and are committed to the protection of your Personal Information and personal data in accordance with applicable privacy laws.

For the purposes of data protection law, the “data controller” (which means the entity which determines the purposes and means of any processing of your personal data) may be any member of the TMX Transform group depending on your interactions.

1. Application of our Privacy Policy

This Privacy Policy describes the way in which TMX Transform collects, holds, uses and discloses your Personal Information. This Privacy Policy also covers how TMX Transform makes the Personal Information it holds available for access and correction by you and how you can make a complaint.

This Privacy Policy must be read together with any other privacy statement that TMX Transform may provide to you when it collects your Personal Information or provides its services (“Privacy Statement”). If there are any inconsistencies between this Privacy Policy and a Privacy Statement, the terms of the Privacy Statement will prevail.

By using or accessing our website tmxtransform.com (“Website”) and any services operated or made available to you by TMX Transform (“TMX Transform Systems”), whether using your mobile phone, personal computer, or any other means, or by otherwise providing Personal Information to us, you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy and any Privacy Statement we may give to you. This Privacy Policy is in addition to any other applicable terms and conditions that may apply wo your relationship and/or engagement with us.

To avoid doubt, this Privacy Policy does not apply to information about or relating to a company or other entity that is not an individual.

2. What is Personal Information?

Personal information is any information that can be used to personally identify you such as your name, address, telephone number, email address and profession or occupation.

If information personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information, whether the information is true or not, and whether recorded in a material form or not.

Sensitive information is a subset of personal information, that is given a higher level of protection by privacy laws. It includes information about an individual’s health and includes genetic and biometric information. It also includes information about race or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious beliefs, sexual orientation or practices and criminal record. In this Policy when we talk about personal information, we include sensitive/health information.

3. What kinds of Personal Information do we collect?

The Personal Information we collect will vary depending on the types of services that you request, or your dealings with us.

The categories of Personal Information which TMX Transform may collect and hold includes the following types of Personal Information:

  • contact information (for example, full name, email address, mailing address and telephone/mobile phone number, emergency contacts);
  • information provided in connection with the use or purchase of any services supplied by TMX Transform or your relationship with us (for example, as a supplier or contractor; and
  • information provided by you through the Website, TMX Transform Systems or TMX Transform related communication channels such as social media sites used, managed or owned by TMX Transform, telephone and/or email support, customer service or customer surveys.

4. When and how do we collect information?

We collect Personal Information in a number of ways, including:

  • directly from you, including when you:
  • buy or use our services;
  • when you provide information online, by phone, in application forms or in agreements;
  • request information about us or our services;
  • provide feedback to us;
  • contract with us; and
  • contact us by our Website, telephone, facsimile, email, post or in person;
  • from an associated entity of TMX Transform; and
  • from social media sites managed, used or owned by TMX Transform.

When you use our Website, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory.

5. Cookies

Cookies are pieces of information that may be transferred to your computer’s memory when you visit a website. Most web browsers are configured to accept cookies, however you may configure your browser to reject cookies or notify you when a cookie is sent. If you reject all cookies, you may not be able to access our Website. The use of cookies on its own does not identify an individual but it does provide us with statistics on how people use our Website and helps us to know what they find interesting and useful on our Website. We do not link this information back to your identity or other information that you have provided to us. We do not store any information in cookies that identifies you.

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

TMX Transform tracks visitor and prospect activities on our Website and landing pages by setting cookies on their browsers. Cookies are set to remember preferences (like form field values) when a visitor returns to our site. Other TMX Transform third party cookies don’t store personally identifying information, only a unique identifier.

When you request anonymity, we will explain to you any impact this choice has on our ability to engage with you.

6. Use of Personal Information

We must tell you why we process your personal data and what lawful ground we rely on. There are several grounds but, in most cases, we rely on one or more of the following.

  • Contract – this is where we process your data to fulfil our agreement with you or because you have asked us to carry out a service before entering into an agreement.
  • Consent – this is where you have provided permission to us to use your data for a particular purpose. You can withdraw your consent at any time.
  • Legitimate interests – this is where we rely on our interests or the interests of third parties. These interests can include our commercial interests.
  • Legal requirement – this is where we must process your data to comply with a legal requirement.

TMX Transform uses the Personal Information it collects about you to provide services and for our business functions and activities, which may include the following:

  • to provide you with information or services you have requested;
  • to communicate with you or verify your identity;
  • to operate, protect, administer, maintain and manage the TMX Transform Systems;
  • to personalize and customize your experiences on our Website or any TMX Transform System.
  • to screen for potential risk or fraud;
  • to help TMX Transform research the needs of its customers;
  • to conduct research for the purposes of improving existing services or creating new products or services;
  • to provide you with information, marketing or promotional messages or advertising which we believe may be of interest to you, including information on our services or activities and information on third parties (who may or may not have a relationship with us);
  • to comply with regulatory or other legal requirements;
  • for purposes related to the employment of our personnel and providing internal services to our staff; and
  • for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.

TMX Transform may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes listed in the previous paragraph, and you would reasonably expect us to use it for that secondary purpose, if we have your consent or if otherwise provided for under applicable privacy laws.

TMX Transform may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. Subject to and in accordance with applicable law, TMX Transform may provide you with these materials by telephone, electronic messages (e.g. email), through social media sites managed, used or owned by TMX Transform and other means. TMX Transform will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing communications may include promotional material about TMX Transform or may relate to the services TMX Transform (and our related entities) provide and other products and services which may be of interest to you.

You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “Contact us” section below.

We may de-identify data (including Personal Information) you provide to us, combine data, aggregate data, and generate data and insights for research and service offering purposes. We will not sell your Personal Information to third parties for marketing purposes.

Generally, we will only collect and use your Personal Information in accordance with this Privacy Policy. In the event that we collect or use Personal Information in ways other than as stated in this Privacy Policy, we will ensure that we do so in accordance with applicable privacy laws.

7. Disclosure of Personal Information

Who we may disclose Personal Information to:

Depending on the nature of your engagement with TMX Transform, we may disclose your Personal Information to our shareholders, officers, employees, contractors, consultants, advisers, agents and related bodies corporate of TMX Transform, third parties that provide products and services to or through TMX Transform or our Website or TMX Transform Systems, directly to you (at your request), suppliers and other third parties, or otherwise as required by law. We do not knowingly collect or share the personal information or sensitive personal information of any individual who is 13 years or younger.

TMX Transform may also disclose your Personal Information to our Website host or software application 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.

We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.

Unless otherwise specified in this Privacy Policy, TMX Transform or our Website host will not disclose any of your Personal Information to any other organization unless the disclosure is required by law or is otherwise permitted by the Privacy Principles.

Cross-border disclosure

Our main operations are based in Australia and your personal data or information is generally processed, stored and used within Australia. Depending upon our arrangements with a client, personal data or information may also be stored within the UK or the United States. We also operate globally, in particular, in the UK, Europe, the United States, and Singapore to support our global clients. A current list of countries within which we operate can be found on our Website. Accordingly, we may also share data with our related bodies corporate or team members that are located globally. However, please note that all data is encrypted in transit.

We will only consciously transfer your Personal Information overseas if:

  • we reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles substantially similar to the privacy principles set out in the Privacy Act 1988 (Cth);
  • you have consented to the transfer;
  • the transfer is necessary for the performance of a contract;
  • the transfer is necessary for the establishment, exercise or defence of legal claims; or
  • we are otherwise required or authorized by law.

By consenting to provide us with Personal Information (whether by using the TMX Transform Systems, through a Privacy Statement or otherwise), you consent to the disclosure of your Personal Information to third parties who reside outside Australia and, if you are a European Union (EU) citizen, to third parties that reside outside the EU. Where the disclosure of your Personal Information is solely subject to Australian privacy laws (and not subject to the European Union’s General Data Protection Regulation), you acknowledge that we are not required to ensure that those third parties who reside outside Australia comply with Australian privacy laws.

8. Employee records

In Australia, employee records are not generally subject to the Privacy Act 1988 (Cth). As such this policy may not apply to the handling of officer, employee, contractor or consultant information. Please contact us directly for information about these information handling practices.

9. Access to Personal Information

How you can access your Personal Information

You have a right to access your Personal Information. If you would like to do so, please direct your request to TMX Transform by email or post using the contact details set out in the “Contact us” section below.

Sometimes, we may not be able to provide you with access to all of your Personal Information. This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals. If we refuse you access, we will tell you why.

We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself). We may need to verify your identity as part of this process.

10. Accuracy of Personal Information

We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request that your Personal Information be corrected. If you think that Personal Information we hold about you is not accurate, complete and up-to-date, please contact us using the contact details set out in the “Contact us” section below and we will take all reasonable steps to correct the information.

11. Security of Personal Information

Precautions taken

We understand the importance of protecting your Personal Information. We take all reasonable precautions to protect the Personal Information we hold about you from misuse, interference and loss, and from unauthorized access, modification or disclosure.

Some of the controls we have in place are:

Personal Information that is held by us in hard copy is stored securely on our premises.

  • We limit physical access to our buildings and user access to our systems to only those that we believe are entitled to be there;
  • We use technology controls for our information systems, such as firewalls, user verification, strong data encryption, and separation of roles, systems & data;
  • We utilise industry "good practice" standards to support the maintenance of a robust information security management system; and
  • We apply a "need to know" approach in relation to access to any data or systems.

Links

The TMX Transform Systems may link to other websites which are outside our control, and other websites outside our control may link to TMX Transform Systems. We are not responsible for the protection and privacy of any Personal Information which you provide while you are visiting or using those other sites, online products or services. Those websites are not governed by this Privacy Policy. You should exercise caution and review the privacy policies applicable to those other sites.

12. How long we keep your Personal Information for

TMX Transform will keep your Personal Information only for as long as required for the purposes described in this Privacy Policy and otherwise as required by law.

Where we no longer need to keep your Personal Information in accordance with this Privacy Policy, we will take reasonable steps to destroy or de-identify your Personal Information.

If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).

13. Your data rights at a glance

You have the right to:

  • ask for a copy of personal data that we hold about you;
  • request that we delete personal data held on you (where we no longer have a valid reason to retain it);
  • ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
  • opt out of any marketing communications that we may send you and to object to us using/holding your personal data for direct marketing purposes or otherwise if we have no legitimate reasons to do so;
  • ask us to ‘restrict processing of data’ which means that we would need to secure and retain the data for your benefit but not otherwise use it; and
  • ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation.

If you are seeking to exercise any of these rights, please contact us using the details in the "Contact Us" section below. Please note that we will need to verify your identity before we can fulfil any of your rights under data protection law. This helps us to protect the personal information belonging to our customers against fraudulent requests.

14. Data breaches or complaints

If you wish to report a data breach or make a complaint about the way we have collected, used, held or disclosed your Personal Information, please contact us using the contact details listed in the “Contact us” section below.

To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.

We will use the information you provide to investigate and respond to your data breach report or privacy complaint. We aim to resolve all complaints as quickly as possible. Some complaints are resolved within weeks, but more complex complaints may take longer. You may withdraw your complaint at any time.

If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the relevant data protection regulator for further investigation.

You always have the right to complain to the relevant data protection regulator.

For Australian residents this is the Office of the Australian Information Commissioner (https://www.oaic.gov.au).

For UK residents this is the Information Commissioner’s Office (https://ico.org.uk).

Although you can complain to the relevant data protection regulator without speaking to us first, they expect you to raise the issue with us first so if you haven’t already, please contact us using the contact details listed in the “Contact us” section below and we will try and help.

15. Contact us

If you have any questions or would like further information about our privacy policies or practices, please contact us by emailing enquiries@tmxtransform.com.

16. Changes to our Privacy Policy

We reserve the right to change our Privacy Policy at any time. We will notify you about changes to this Privacy Policy by posting an updated version on our Website.

Last updated on 18 August 2026.