Privacy policy

1. Introduction

This Privacy Policy applies to both the public-facing website and any application, portal, or system operated by the Third Way Enterprise PTY. LTD, including membership application platforms and authenticated environments. This Privacy Policy explains how the Third Way Enterprise PTY. LTD and its related entities (collectively, we, us, or our) collect, use, store, disclose, and protect personal information when you access or use our website, platforms, portals, or services (collectively, the Services).

We are committed to handling personal information in a lawful, transparent, and secure manner and to complying with applicable data protection and privacy laws, including (where applicable) the Australian Privacy Act 1988 (Cth), the UK GDPR and Data Protection Act 2018, and the EU General Data Protection Regulation (GDPR).

2. Scope

This Privacy Policy applies to:

  • Visitors to our public website;
  • Users of any application, portal, or digital platform operated by the Third Way Enterprise PTY. LTD;
  • Members, participants, contributors, and counterparties;
  • Applicants for membership or participation;
  • Any individual whose personal information we process in connection with the Services. This Privacy Policy applies to:
  • Visitors to our website;
  • Members, participants, contributors, and counterparties;
  • Applicants for membership or participation;
  • Any individual whose personal information we process in connection with the Services.

3. Personal Information We Collect

We may collect the following categories of personal information:

  • Identity and contact information: name, business name, email address, telephone number, postal address;
  • Professional information: role, organisation, credentials, contribution details;
  • Account and access data: usernames, access credentials, authentication logs;
  • Technical data: IP address, browser type, device identifiers, access times, usage logs;
  • Communications: enquiries, correspondence, submissions, and records of interaction;
  • Compliance information: information required for regulatory, legal, or due‑diligence purposes.

We do not intentionally collect sensitive personal information unless required by law or expressly consented to.

4. How We Collect Information

Personal information may be collected:

  • Directly from you through forms, applications, agreements, or correspondence;
  • Automatically through cookies, log files, and similar technologies;
  • From authorised third parties where lawful and relevant to our activities.

5. Purpose of Collection and Use

We collect and use personal information for the following purposes:

  • To operate, maintain, and improve the Services;
  • To assess eligibility, approve contributions, and administer membership or participation;
  • To communicate with users and respond to enquiries;
  • To manage access, security, and system integrity;
  • To meet legal, regulatory, governance, and compliance obligations;
  • To enforce agreements and protect our legal rights.

Personal information will not be used for purposes unrelated to these activities without consent, unless permitted or required by law.

6. Legal Basis for Processing (EU / UK)

Where the GDPR applies, we process personal information on one or more of the following legal bases:

  • Performance of a contract;
  • Compliance with legal obligations;
  • Legitimate interests pursued by us, balanced against individual rights;
  • Consent, where required.

7. Disclosure of Personal Information

We may disclose personal information to:

  • Internal personnel and authorised representatives;
  • Service providers, contractors, and professional advisers acting on our instructions;
  • Regulatory authorities, courts, or law enforcement agencies where required;
  • Third Way Enterprise PTY. LTD entities or counterparties where necessary to administer approved activities.

We do not sell personal information.

8. Cross-Border Transfers

Personal information may be stored or processed in jurisdictions outside your country of residence. Where cross‑border transfers occur, we take reasonable steps to ensure that appropriate safeguards are in place and that information is protected in accordance with applicable laws.

9. Data Security

We implement reasonable technical and organisational measures to protect personal information against loss, misuse, unauthorised access, disclosure, or alteration. Access is limited to authorised persons on a need‑to‑know basis.

10. Data Retention

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, or as required by law, regulation, or governance obligations.

11. Your Rights

Subject to applicable law, you may have the right to:

  • Request access to personal information held about you;
  • Request correction of inaccurate or incomplete information;
  • Request deletion or restriction of processing;
  • Object to certain processing activities;
  • Withdraw consent where processing is based on consent.

Requests may be made using the contact details below.

12. Cookies, Analytics, and Application Data

Our public website may use cookies or similar technologies to support functionality, security, and analytics. Our applications and portals may additionally collect session data, access logs, and system identifiers strictly for authentication, security, audit, and operational purposes. You can manage cookie preferences in your browser settings, but certain application features may not function correctly without required cookies or session controls. Our website may use cookies or similar technologies to support functionality, security, and analytics. You can manage your cookie preferences in your browser settings.

13. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised effective date.

15. Contact Us

For privacy-related enquiries or requests, please contact:

Privacy Officer
Third Way Enterprise PTY. LTD
admin@3-w-e.com
Commonwealth of Australia

Effective Date: 11-11 2025

The Privacy Policy has now been explicitly aligned for both a public website and an application / portal environment, with clear differentiation between passive website use and authenticated system use. It is suitable for regulator, counterparty, and institutional review in its current form.

Annex A — Regulatory Mapping (ASIC APPs and GDPR Articles 13–14)

This Annex is provided for transparency and compliance demonstration purposes and forms part of this Privacy Policy.

A1. Australian Privacy Principles (APPs)

APP

Requirement

Where Addressed in Policy

APP 1

Open and transparent management of personal information

Sections 1, 2, 14

APP 3

Collection of solicited personal information

Sections 3, 4

APP 5

Notification of collection

Sections 1, 3, 5

APP 6

Use and disclosure

Sections 5, 7

APP 8

Cross-border disclosure

Section 8

APP 10

Quality of personal information

Section 11

APP 11

Security of personal information

Section 9

APP 12

Access to personal information

Section 11

APP 13

Correction of personal information

Section 11

A2. GDPR Articles 13–14

GDPR Article

Information Obligation

Where Addressed in Policy

Art. 13(1)(a)

Identity of controller

Sections 1, 15

Art. 13(1)(b)

Contact details

Section 15

Art. 13(1)(c)

Purposes and legal basis

Sections 5, 6

Art. 13(1)(e)

Recipients of data

Section 7

Art. 13(1)(f)

International transfers

Section 8

Art. 13(2)(a)

Data retention period

Section 10

Art. 13(2)(b–d)

Data subject rights

Section 11

Art. 13(2)(f)

Right to lodge a complaint

Section 11

Art. 14

Indirect collection transparency

Sections 4, 7

This Annex is intended to assist regulators, auditors, and counterparties in assessing compliance alignment and does not create additional rights beyond those set out in the main body of this Privacy Policy.

Effective Date: 11-11-2025