Privacy Policy

Last updated: 29 Jun 2026. This Privacy Policy explains how Harrington O’Sullivan collects, uses, discloses, and protects personal information. We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and we have elected to apply these standards as a matter of policy.

This policy applies to ESG Group Pty Ltd (ABN 67 652 212 498) trading as Harrington O’Sullivan and to the website harringtonosullivan.com.

We may collect identity and contact details you provide via our contact or enquiry forms, by email, or by phone, such as your name, company, role, email address, and telephone number. We may also collect the content of your enquiry or correspondence, and technical and usage data automatically collected when you visit the Website, such as IP address, device and browser information, and pages visited.

We collect personal information directly from you when you submit a Website form, email or call us, or engage with our content. We also collect information indirectly via our website analytics and customer-relationship tools. We collect only what is reasonably necessary for the purposes outlined below.

We use personal information to respond to enquiries, provide information about our services, manage and develop our client and referral relationships, maintain our customer-relationship records, comply with legal obligations, and where permitted, send you marketing communications.

Where we send marketing communications by email, we do so in accordance with the Spam Act 2003 (Cth). We send commercial electronic messages only with your consent (express or inferred), identify ourselves as the sender, and include a functional unsubscribe facility. You can opt out at any time by using the unsubscribe link or contacting us. We will action opt-out requests promptly.

We disclose personal information to third parties who help us operate, including website hosting, customer-relationship management (HubSpot), and email-marketing (Mailchimp) providers. We require these providers to handle personal information consistently with this policy and applicable law. We do not sell personal information.

Some of our service providers (including HubSpot and Mailchimp) store or process data on servers located outside Australia, including in the United States. By providing personal information, you acknowledge it may be disclosed to and stored by recipients overseas. We take reasonable steps to ensure overseas recipients handle your information consistently with the APPs. Where we engage on international projects (including in Sub-Saharan Africa), personal information of project contacts may be disclosed to relevant parties in those jurisdictions for the purposes of the engagement.

Some of our service providers (including HubSpot and Mailchimp) store or process data on servers located outside Australia, including in the United States. By providing personal information, you acknowledge it may be disclosed to and stored by recipients overseas. We take reasonable steps to ensure overseas recipients handle your information consistently with the APPs. Where we engage on international projects (including in Sub-Saharan Africa), personal information of project contacts may be disclosed to relevant parties in those jurisdictions for the purposes of the engagement.

The Website may use cookies and similar technologies, including third-party analytics, to understand site usage and improve performance. You can manage cookies through your browser settings. Disabling cookies may affect Website functionality.

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. No internet transmission is completely secure, and we cannot guarantee absolute security.

You may request access to the personal information we hold about you and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading. Contact us using the details below. We will respond within a reasonable period and may need to verify your identity.

We retain personal information only for as long as necessary for the purposes for which it was collected or as required by law, after which we take reasonable steps to destroy or de-identify it.

If you have a privacy complaint, contact our Privacy Officer using the details below. We will investigate and respond within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

We may update this Privacy Policy from time to time. The current version is always available on the Website, with the “Last updated” date amended accordingly.

Privacy Officer, ESG Group Pty Ltd t/a Harrington O’Sullivan, 1/1 Tully Road, East Perth, WA 6004. Email: george@harringtonosullivan.com.au.