This website is managed by Pendleton & Co Pty Ltd (Pendleton & Co) on behalf of the company and its subsidiaries.

For the purposes of this Privacy Statement, subsidiaries, correspondent firms and associated firms of Pendleton & Co Pty Ltd are together described as Participant Firms.

Pendleton & Co provides information and documentation on World Wide Web sites, such site(s) being known as the Pendleton & Co Internet (the “site”). This page contains the information gathering and use policies adopted by Pendleton & Co in connection with the site. These policies are subject to periodic review and any changes will be included within this section of the site.

Pendleton & Co is not responsible for the privacy policies of third party sites to which links are provided (including sites of Participant Firms of Pendleton & Co). The privacy policies on these sites should be checked before providing any personal information to these sites.

Pendleton & Co is committed to the protection of personal information supplied by clients and prospective clients and other users of this website.

Collection of information

Pendleton & Co will only collect and use personal data voluntarily and openly provided to this site. Authorised users are able to browse the Site without disclosing any personal information. An authorised user of this site may choose to provide Pendleton & Co with limited personal data as required in order to register for certain services; once registered the information will only be used for the specified purpose(s).

At the present time IP addresses of authorised users are not logged for either administrative or other purposes. The IP address indicates the location of the authorised users’ computer on the Internet. If it is decided to log IP addresses in the future, the information so obtained may be aggregated to provide statistical information about the users of the site. However no individual user will be identifiable from such information and IP addresses will not be used to track the access to the Site. Pendleton & Co does not require registration for access to the site.

It will normally be clear when personal information is being collected. The information required is the minimum necessary to enable Pendleton & Co to deal with the services requested, but additional information may be requested for Pendleton & Co to provide the most appropriate response. If such additional information is requested it is highlighted and its provision is voluntary.

Sensitive personal data includes gender, race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records. We do not solicit sensitive personal data through the site except where legally required to do so, eg for the purposes of recruitment, and for the purposes of retaining information for inclusion in the Pendleton & Co directories of Participating Firms, their principals and their professional expertise. We would suggest information of this nature is not provided except where legally provided to do so, eg for the purposes of recruitment, and where such data is for inclusion in Pendleton & Co directories of Participating Firms, their principals and their professional expertise.


At the present time the standard technology known as “cookies” is used on the site. Cookies are small text files placed on the authorised user’s hard drive that allow the site to store tokens of information in connection with use of the site by allocation of an identifier to an authorised user while the site is in use. Use of cookies enables Pendleton & Co to analyse the operation of the site, thus permitting continuous improvement of the service that it provides, but cannot retrieve any other data from the hard drive of the authorised user’s computer or capture the authorised user’s e-mail address. In any event it is not intended to link personal data to information that may be contained in a cookie to determine or track the identity of any user of the site.

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

Google Analytics

We use Google Analytics to analyse our website usage and create reports for internal use at Pendleton & Co only.

Google Analytics Cookies

Like many services, Google Analytics uses first-party cookies to track visitor interactions. These cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Browsers do not share first-party cookies across domains. To find out more about how Google treats personal information, please see; The Google Privacy Policy.

Use of information

Information is used only for the specific purpose for which it was provided except where there has been an explicit selection to receive other information from Pendleton & Co. Personal data provided through the Site will be made available to the provider of the information on request as any individual whose personal data is held on the Site is entitled under the Privacy Act 1988 (as amended) and the Australian Privacy Principles (APPs) to the information constituting his or her personal data. Personal information may be deleted from the site at any time. Requests for copies or deletion of information may be made by e-mailing Pendleton & Co at any time.
Provision of Information to Third Parties

Pendleton & Co will provide personal information to third parties in the following circumstances:

  • Where the transfer is necessary to fulfil the requirements of the operations for which the information was provided, and the third party is a Participant firm;
  • in order to fulfil a request which involves other Participant Firms;
  • so as to assist Pendleton & Co ‘s professional advisors regarding matters referred to them concerning the operation of the site:
  • where requested explicitly by an authorised user of the Site; or
  • as required by a court order or any other legal or regulatory requirement.

Pendleton & Co does not collect or compile personal data or information obtained by the site for dissemination or sale to outside parties not Participant Firms for the purposes of marketing or mailing by or on behalf of third parties. Pendleton & Co does not undertake marketing activities for third parties.

Accuracy of information

Pendleton & Co assumes responsibility for keeping an accurate record of personal data once it has been submitted, but not for confirming the ongoing accuracy of the personal information. If Pendleton & Co is advised that the personal data is no longer accurate, it will be amended (where practical).

Retention of information

Information collected from authorised users of the site will only be kept in order to provide the required services. Once the service has been completed all information will be destroyed in accordance with Pendleton & Co ‘s data retention policies. Where the information has been collected in connection with an expression of interest in working for Pendleton & Co or a Participant Firm it is agreed that Pendleton & Co may use, hold and destroy personal data supplied in connection with the initial expression of interest in accordance with Pendleton & Co ‘s standard recruitment procedures:

  • details may be retained for up to the next twelve months for the purpose of notification of suitable vacancies that might arise;
  • details may be used for the purpose of research and analysis designed to improve recruitment and human resources policies and practices.

Where the authorised user of the site has provided additional information, personal details will be retained for a period of time reasonable in the context of the nature of the request.

If these conditions are not acceptable the site should not be further used.

Security of information

Pendleton & Co has implemented accepted standards of technical measures and security policies that are aimed at protecting the personal data it has under its control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification;
    unlawful destruction or accidental loss.

All Pendleton & Co personnel are required to keep personal information confidential and only authorised persons have access to such information.

Credit Reporting

If you apply for an account with Pendleton & Co and require credit terms, we may request credit reports from credit reporting bodies. These credit reports contain information which assists us to assess your application, including information about your credit history with other credit providers. Credit reporting bodies can provide credit providers with credit reports in certain circumstances, including when an individual makes an application for credit, or when a credit provider is seeking to help an individual avoid defaulting on their credit. Credit reports are designed to assist credit providers to accurately assess an individual’s ability to repay credit.

To request a report, Pendleton & Co will provide information that identifies you and information about your application – including the type and amount of credit you are applying for.

Pendleton & Co may request such reports for consumer credit or commercial credit applications.

Pendleton & Co also discloses information about you to credit reporting bodies that can then be included in reports provided to other credit providers.


Pendleton & Co understands the importance of protecting children’s privacy especially in an online environment. The site covered by this privacy statement is not intentionally designed or directed at children 13 years of age or younger and it is Pendleton & Co policy never to knowingly collect or maintain information about anyone under the age of 13 years.

Other matters

Please note that the site contains links to other sites (including sites maintained by Participant Firms) which are not governed by this privacy statement.

If you have any questions about this privacy statement please contact Pendleton & Co (see below).

Pendleton & Co Pty Ltd

Legal Department; Legal Counsel
1/85 Manning Road

Bentley WA 6152