Effective Date: 29th May 2026

This Privacy Policy applies to Lighthouse Service Partners Holdco Pty Ltd (ABN 66 685 112 216), Lighthouse Service Partners Midco Pty Ltd (ABN 39 685 112 985) and Lighthouse Service Partners Bidco Pty Ltd (ABN 91 685 113 197) (“we”, “us”, or “our”). It describes how we collect, use, disclose, store and handle “personal information” in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (the “Privacy Act”).

Part A – Suppliers, job applicants, contractors and other members of the public

1. Personal Information We Collect

“Personal information” refers to information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Additionally, we may collect “sensitive information” in some circumstances. “Sensitive information” is a category of personal information that is given additional protection under the Privacy Act and includes information about racial or ethnic origin, political opinions, religious beliefs or affiliations, philosophical beliefs, trade union membership or association, sexual orientation or practices, criminal record, health information, and genetic or biometric information. We will only collect sensitive information with your consent or as permitted or required by law.

The kinds of personal information we collect will depend on how and why you engage with us. The following table sets out some of the common kinds of information we may collect.

Our website may use cookies and analytics tools to collect data about how visitors to our website use our website such as browser type, operating system and pages viewed. Generally, the data collected by these cookies or analytics tools does not identify you. However, we may be able to identify you in some circumstances, such as if you submit an online enquiry. 

2. How We Collect Personal Information 

Where reasonable and practicable in the circumstances, we will collect personal information directly from you. We may collect this information when you contact us by telephone, SMS, email, through our websites or in any other way, or when you visit our websites. 

In some circumstances, we collect personal information about you from our subsidiaries (such as if you are a customer, supplier or employee of one of our subsidiaries), and we may also collect personal information about you from publicly available sources (such as, if you are a job applicant or prospective employee or contractor, from LinkedIn) and third parties (such as if you are a job applicant or prospective employee or contractor, from relevant recruitment agencies, referees, former employers or academic institutions). 

3. Purpose of Collection, Use and Disclosure 

We collect personal information only where reasonably necessary for our functions or activities. We generally use and disclose your personal information for the primary purpose for which we collect it. The following table sets out purposes for which we generally collect, use and disclose your personal information: 

In the ordinary course of our business, we may also use and disclose your personal information for the following additional purposes, depending on the circumstances: 

• for general business purposes, including record keeping, reporting, administration, accounting, insurance, audit, training, quality assurance, identifying and implementing business efficiencies and improvements to products and services; 

• analysing aggregated personal information to better understand the people we deal with; 

• complying with our legal and regulatory obligations; 

• protecting our lawful interests; 

• managing health and safety; 

• responding to and investigating incidents and complaints; 

• as we and our subsidiaries grow and change, to facilitate corporate transactions; and 

• otherwise, where permitted or required by law. 

4. Disclosure of Personal Information 

In the ordinary course of our business, we may disclose your personal information to the following third parties: 

• our related entities or affiliates, if any; 

• employees, contractors and service providers assisting in our business operations (such as IT, cloud hosting, payment processing and/or marketing service providers (see Section 5)); 

• our professional advisors, such as our accountants, lawyers and auditors; 

• as we and our subsidiaries grow and change, to third parties involved in corporate transactions with us; 

• legal or regulatory authorities, where authorised or required by law; and 

• any other party where you have provided consent. 

5. Direct Marketing 

We may use your personal information to send marketing communications to you where you have consented or would reasonably expect to receive such marketing communications. 

You may opt out at any time if you no longer wish to receive marketing communications by contacting us using the details at the end of this Policy or using the unsubscribe function in the communication. 

6. Cross-Border Disclosure 

We do not ordinarily disclose personal information overseas. 

However, some of our IT and other service providers may access, process or hold personal information in locations or on servers located outside Australia, such as in the United States of America. 

7. Security 

We hold personal information in digital and hard copy forms. 

We implement reasonable technical and organisational security measures to protect and safeguard your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure — including access controls, encryption where appropriate, secure cloud-based systems, restricting physical access to our offices and hard copy records, and staff training. 

8. Access, Correction and Quality 

We take reasonable steps to ensure information is accurate, complete and up to date. 

You may request access to, or correction of, the personal information we hold about you by contacting us using the details at the end of this Policy. 

We will respond to your request within a reasonable time. If we refuse your request, we will provide written reasons. 

We will not charge you for making a request to access your personal information. However, if we incur any costs in retrieving or providing access to your personal information, we may charge a reasonable fee. 

Part B – Employees 

9. Employee Information We Collect 

In addition to the personal information we collect about job applicants (see Section 1 in Part A of this Policy), if you are an employee of ours, we may also collect the following kinds of personal information about you: 

• any diversity and inclusion information you choose to provide to us, such as racial and ethnic origin, and sexual orientation; 

• financial and related information such as your bank details, tax file number and superannuation information; 

• information about you and your role set out in your employment contract, including your remuneration; 

• information about your attendance at work, including leave; 

• performance-related information, such as information about you gathered through performance reviews, performance management and disciplinary matters; 

• training and development information; 

• health and safety information related to fitness for work, your health and safety at work and workers compensation claim information; 

• information about your work-related expenses; 

• information about your use of company equipment; and 

• information related to the end of your employment. 

We will only collect sensitive employee personal information where it is reasonably necessary for our functions or activities, including our employment relationship with you. Collection will generally be with your consent unless otherwise permitted or required by law. All sensitive information is used and disclosed only in accordance with this Policy and the law. 

Our handling of your employee personal information after we have collected it in relation to your employment with us will generally be exempt from the requirements of the Privacy Act. 

10. Use and Disclosure of Employee Personal Information 

We use your employee personal information for purposes including: 

• managing our employment relationship with you (e.g. payroll, appraisals, disciplinary action); 

• administering leave and superannuation; 

• ensuring workplace health and safety; 

• monitoring performance and compliance with our policies; 

• complying with our legal and regulatory obligations (including liaising with the ATO, Fair Work Ombudsman and WorkCover); 

• preventing fraud; and 

• defending investigations or legal proceedings. 

We may also use your name, image and work contact details for legitimate business and marketing purposes with appropriate regard to your role and position. 

We may disclose your employee personal information to third parties in connection with our business and your employment with us, including: 

• our related entities or affiliates, if any; 

• service providers assisting in our business operations (such as IT, cloud hosting and payroll); 

• external consultants and advisors (legal, HR, accounting, insurance); and 

• government agencies, where required. 

Part C – General Provisions 

11. Updates 

This Policy may be updated from time to time. The current version will be published on our website and is available free of charge on request. 

12. Complaints and Contact 

For queries, complaints, access requests, or corrections, contact us: 

Lighthouse Service Partners Holdco Pty Ltd 

Email: efischer@lighthousesp.com.au

Website: lighthousesp.com.au

Once we have received your complaint, we will investigate and endeavour to respond to you within a reasonable time, usually within 30 days. 

If you are unsatisfied with our response or the outcome of your complaint, you may refer it to the OAIC: 

Office of the Australian Information Commissioner 

Website: www.oaic.gov.au | Phone: 1300 363 992 | Post: GPO Box 5288, Sydney NSW 2001