Privacy Policy

Last updated: May 2026  |  Version 2.0

1. Purpose of this policy

Market Line Pty Ltd (ACN 644 883 483) (Market Line, we, us, our) is committed to protecting the privacy of personal information obtained through its operations as a professional valuation and shareholder value advisory firm. Market Line is bound by the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and any relevant privacy code registered under the Privacy Act.

Market Line is Corporate Authorised Representative Number 1284459 of Australian Financial Services Licence Number 3442034. In that capacity, we also comply with the privacy obligations applicable to authorised representatives under the Corporations Act 2001 (Cth).

The purpose of this policy is to inform individuals of:

• how and when we collect personal information;
• how we use and disclose personal information;
• how we keep personal information secure, accurate and up to date;
• how an individual can access and correct their personal information; and
• how we will facilitate or resolve a privacy complaint.

2. Policy statement

The 13 Australian Privacy Principles apply to personal information — that is, information or an opinion (whether true or not) relating to an identified individual or which can be used to reasonably identify that individual. Information about companies is not personal information; however, the principles apply to an individual carrying on a business as a sole trader.

All Market Line offices in Australia are subject to policies and procedures designed to ensure compliance with the Australian Privacy Principles. We review and update this privacy policy from time to time to reflect new laws, regulations and technology. All personal information held, collected and disclosed by Market Line is governed by the current version of this policy.

3. The kinds of personal information we collect and hold

Personal information is defined under the Privacy Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not. Personal information may include sensitive information.

Sensitive information includes information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information, or biometric templates.

Market Line collects personal information for the following purposes: providing valuation services, shareholder value advisory services, expert witness and litigation support, financial reporting valuations, tax valuations, advisory board services, and related professional services; marketing our services and publications (including the Shareholder Value Vantage Point newsletter); and human resources and contractor management.

The specific types of personal information we may collect and hold include:

• name, title, and job title;
• company name and nature of business;
• contact details including address, email address, and telephone number;
• residency and country of residence;
• financial records and information provided in connection with valuation engagements;
• advice received from clients or prospective clients that may contain additional personal information, such as family relationships and other business-related connections;
• qualifications, memberships and other accreditations;
• employee and contractor records, including CVs, resumes and application-related information;
• bank account details for the purpose of processing payments; and
• online interactions with our website, publications, alerts and social media activity.

As set out below, we also collect certain information that is not directly provided by individuals, such as IP addresses, browsing patterns, click stream data, and cookie status.

Market Line does not collect personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which we have been engaged or may be engaged, or our other functions and activities. We provide the option for individuals to remain anonymous or use a pseudonym where practicable; however, in some cases (for example, when entering into an engagement) this may not be feasible.

4. How we collect personal information

Market Line primarily collects personal information that has been directly provided to us by our clients, prospective clients, associates of clients, suppliers, employees, or contractors. Information may also be collected from publicly available sources where it will assist us with the provision of services. Information may be provided verbally, in writing (including by email), or through our website contact form.

We may collect your information when you:

• visit our website or submit information through our website contact form;
• engage us or request a proposal for services;
• meet with us, whether in person, by phone, or online;
• subscribe to our publications or attend our events;
• provide us with your business card; or
• are referred to us by a third party.

We may also collect personal information from alternative sources, including:

• associates of a client or prospective client (for example, a spouse, beneficiary, or business partner) where it is considered unreasonable or impracticable to seek this information directly from the associate;
• referees provided by you in connection with an application;
• publicly available sources including court judgments, directorship and bankruptcy searches, ASIC registers, and professional networking platforms (such as LinkedIn); and
• third parties in connection with engagement due diligence or compliance checks.

If we collect personal information about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply (for example, where the information is collected from a referee you have listed, from publicly available sources, or as otherwise required or authorised by law).

4a. Website contact form

Our website includes a contact form that collects your name, email address, company name, nature of enquiry, and a free-text message. Submissions are received by Market Line’s internal systems and are used solely for the purpose of responding to your enquiry. Contact form submissions are stored securely in accordance with Section 9 of this policy.

4b. Cookies

Our website may use cookies to identify site users and their interests and to track usage of the site. Cookies are small pieces of text stored on a computer that help us to understand how visitors use our site. A user who does not accept cookies may not be able to access certain areas of the site. We also log IP addresses to help diagnose problems with our server and to administer the site. If you prefer not to accept cookies, you can set your web browser to warn you before accepting any cookies or refuse all cookies by turning them off in your web browser.

4c. Unsolicited information

If Market Line receives personal information that we have not requested or solicited (unsolicited information), and we determine that the information is not required, we will destroy it or ensure that it is de-identified. If the unsolicited information relates to potential future employment or engagement with Market Line (such as a CV or resume), we may retain it on our records for that purpose.

5. How we use your personal information

Market Line uses and discloses personal information for the primary purpose for which it was collected — that is, providing valuation and advisory services to our clients, communicating with clients and prospective clients, marketing our services and publications, complying with our legal and regulatory obligations, and dealing with enquiries and complaints. In certain circumstances, the law may permit or require us to use or disclose personal information for other purposes (for example, where a client would reasonably expect us to and the purpose is related to the purpose of collection).

5a. Use of technology and AI tools

Market Line integrates artificial intelligence and technology tools into its analytical workflow to enhance the quality and rigour of its valuation and advisory services. This may include the use of cloud-based AI platforms, data analysis tools, and proprietary analytical systems. Personal information provided in the course of an engagement may be processed through these tools in the course of providing our services.

All personal information processed through AI and technology tools remains subject to the same confidentiality and security obligations as information processed by other means. We take reasonable steps to ensure that any third-party AI or technology service providers comply with obligations that are consistent with the Australian Privacy Principles. We do not use personal information for automated decision-making that produces legal effects or similarly significant effects on individuals without human review.

5b. Sensitive information

Our policy is that we endeavour not to collect sensitive information about our clients or prospective clients; however, that may not always be possible. If any of our clients or prospective clients elects to provide us with sensitive personal information, we will take all reasonable steps to ensure that the sensitive information is securely protected. If we propose to use such personal information other than for the reasons set out in this policy, we will first notify you or seek your consent.

6. Disclosure of personal information

Market Line may disclose your personal information where it is necessary to support the delivery of our services or other related activities, including to:

• third-party service providers utilised in connection with administrative matters;
• IT service providers, cloud platform providers, and consultants who assist Market Line in providing or marketing our services;
• our contractors and agents;
• superannuation fund administrators (in respect of employee or contractor records);
• third parties in connection with any restructuring of Market Line’s business; and
• courts, regulators, or other parties where Market Line is required by law to provide personal information (for example, in compliance with a court order, subpoena, or regulatory request).

We may also use or disclose your personal information without seeking your additional consent where:

• it is disclosed for a purpose related to the primary purpose of collection and you would reasonably expect your personal information to be used or disclosed for such a purpose;
• we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety, or to public health or safety;
• we have reason to suspect that unlawful activity has been, or is being, engaged in; or
• it is required or authorised by law.

If we propose to disclose personal information other than for the reasons set out in this policy, we will first notify you or seek your consent.

If you have received communications from us and no longer wish to receive them, please contact us using the details in Section 11 and we will ensure the relevant communications cease.

6a. Overseas disclosures

The nature of our business activities may on occasion require that personal information be disclosed to overseas recipients in order to provide the services contemplated under our engagement terms. Market Line uses cloud-based technology services and platforms (including Google Workspace, Microsoft 365, and AI platforms) that may store or process data in the United States and other jurisdictions.

Personal information may be disclosed to recipients in the United States, the United Kingdom, and other countries where our cloud service providers maintain infrastructure. By submitting your personal information to Market Line, you expressly agree and consent to the disclosure, transfer, storage or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia may not have the same privacy protection obligations as Australia.

Despite this consent, Market Line takes reasonable steps to ensure that any recipients of your personal information outside of Australia handle that information in a manner consistent with the Australian Privacy Principles. If you do not consent to the disclosure of your personal information outside Australia, please contact us using the details in Section 11 before submitting your personal information.

7. Direct marketing

You give your express and informed consent to us using your personal information to provide you with information about our services, publications, and events, whether by post, email, SMS, messaging applications, or telephone (Direct Marketing Communications). This includes the Shareholder Value Vantage Point newsletter and other Market Line publications.

If you have provided inferred or implied consent (for example, by not opting out where an opt-out opportunity has been provided), or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for that purpose.

If at any time you do not wish to receive Direct Marketing Communications, you may use the “unsubscribe” facility in the communication, or contact us using the details in Section 11.

8. How we store your personal information

Market Line holds personal information securely, either on infrastructure owned or controlled by us or with third-party service providers who comply with the Privacy Act. We take reasonable steps to protect against the loss, misuse and alteration of personal information under our control, including through appropriate physical and electronic security measures.

Only authorised Market Line personnel are provided access to personal information, and these individuals are required to treat this information as confidential.

Market Line uses cloud-based services (including Google Workspace, Microsoft 365, and specialist valuation and analytical platforms) for the storage and processing of electronic records. Where data is stored with an external provider, we are satisfied that the provider’s security protocols meet or exceed the level of security that Market Line could apply if the data were stored in-house. Some of these services store data outside Australia — the jurisdictions to which this applies are set out in Section 6a.

We may need to maintain records for a significant period of time in accordance with professional standards and legal obligations. When we consider information is no longer needed, we will destroy or permanently de-identify these records.

9. Accuracy of personal information

Market Line will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date. As the accuracy of personal information largely depends on the information that you provide to us, we request that you advise us of any errors in or updates required to your personal information. If you believe that the information we hold about you is inaccurate or out of date, please contact us using the details in Section 11.

10. Access to personal information

Under the Australian Privacy Principles, you have the right to request access to any personal information that we may hold about you and to advise us if the information should be corrected. The Australian Privacy Principles set out the circumstances when we can refuse those requests. If we do refuse your request, we will provide you with a written notice setting out the reasons (unless it would be unreasonable to provide them).

Subject to our right to refuse access, Market Line will provide you with a report listing any personal information that we hold about you. We will acknowledge receipt of any request for access or correction within 7 days and provide a written response within 30 days.

If you would prefer to submit a privacy request using a pseudonym or otherwise keep your identity confidential, we will do our best to support that request if it is feasible to do so.

11. Contact us

If you wish to make an enquiry about your personal information, request access to or correction of your personal information, or make a complaint because you believe that we may have breached the Australian Privacy Principles or a privacy code that applies to us, please contact our Privacy Officer:

Privacy Officer
Market Line Pty Ltd
Level 19, 10 Eagle Street
Brisbane QLD 4000
Email: info@mlau.consulting
Phone: 1300 982 534

12. Complaints

We have an effective mechanism and procedure to resolve privacy complaints and enquiries. All complaints and enquiries will be dealt with in a reasonably appropriate timeframe.

In order to resolve a complaint, we will:

• liaise with you to identify and define the nature and cause of the complaint;
• may request that you provide the details of the complaint in writing;
• keep you informed of the likely time within which we will respond to your complaint; and
• inform you of the legislative basis (if any) of our decision in resolving the complaint.

We will respond to each complaint within a reasonable time and maintain a record of the complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

13. Consent, modifications and updates

This policy is a compliance document prescribed by law rather than a contractual agreement. However, certain engagement contracts may incorporate all or part of this policy into their terms.

By using our website, engaging us to provide you with services, or where you have been provided with or had reasonable access to a copy of this policy, you acknowledge and agree that you give the consents described in this policy and have been informed of all of the matters in this policy.

We reserve the right to modify this policy as our business needs require. We will take reasonable steps to notify you of material changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information due to changes in this policy, please cease providing us with your personal information and contact us using the details in Section 11.

14. Notifiable Data Breaches Scheme

The Notifiable Data Breaches Scheme (NDBS) in Part IIIC of the Privacy Act sets out obligations for notifying affected individuals, and the Australian Information Commissioner, about data breaches that are likely to result in serious harm. Market Line acknowledges its obligations under the NDBS and will notify affected individuals and the OAIC in accordance with the scheme where required.

15. Storage and retention of information

Personal information is held for as long as required to accomplish our professional and business purposes and as required by Australian law, professional standards, and the terms of our engagement agreements. You have the option of notifying us if you would prefer us to destroy or de-identify your information, subject to any legal or professional obligations that require its retention.