Privacy Policy


    1. Diogenes Investing Pty Ltd ACN 651 800 814 as trustee for the Gray Holdings Trust ABN 90 095 371 433 (Diogenes Investing, we, our, or us) respect your privacy, and is committed to complying with its obligations under the laws of Australia, where we are based, and the laws of your home country.
    2. This Privacy Policy sets out how Diogenes Investing, and its related corporations and entities, will handle your personal information.
    3. Diogenes Investing is committed to protecting the privacy of all individuals it deals with and will treat your personal information confidentially and according to the laws of the relevant jurisdiction, which set out the ways in which an organisation can collect, use, disclose, store, and provide access to personal information.
    4. Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
    1. Diogenes Investing will collect your personal information in a fair and lawful manner. Where it is practical to do so, we will collect your personal information directly from you, and only to the extent necessary to provide you with our products or services and carry out our operations. However, sometimes we also collect your personal information from the following mediums:
    2. Through our website (which might include the time and date you accessed it); and/or
    3. our business service providers and contractors.
    4. Diogenes Investing may collect personal information from you when:
    5. you submit an enquiry or application form online via our website;
    6. you submit any other information directly via our website;
    7. in performing our assessment of your enquiry, including any subsequent discussions in any form, whether verbally, in writing, electronically or otherwise;
    8. it is administering any of our services;
    9. you contact us by telephone;
    10. you email us; or
    11. you have contact with us in person.
    12. We will collect, use and disclose your personal information only for the particular purpose that you provided it, or for a directly related purpose (see clause 4.3). We may otherwise use your personal information where that other use is:
    13. required or permitted by law; or
    14. with your express or implied consent.
    1. The kinds of personal information that Diogenes Investing will collect about you will depend on the type of interaction that we have with you. For example, we may collect your personal information when you apply to become our client and use our services, which may include your name and contact details and date of birth and any previous services and products you have received from us. More specifically:
    2. Clients, Prospective Clients and the General Public:

We may collect your name, age, gender, telephone number, address, email address, payment details (including credit card and debit card details) as well as any previous services and products that you have received from us. In our day-to-day dealings with you, we may collect information relating to general product enquiries, as well as complaints.

  1. Business Service Providers and Contractors:

In the context of our business relationship, we may collect your name, ABN or ACN if in Australia, or equivalent in your home country, address telephone number and email address.

  1. Job Applicants:

We may collect your name, telephone and email address, as well as information, references and reports arising out of the assessment of your potential suitability as our employee.

  1. We may also collect your name and contact details which you provide to us, in order to respond to your questions and comments about Diogenes Investing and its products and services.
  2. We will only collect your personal information where you have consented, or otherwise in accordance with the law.
  3. When we collect personal information from you, we will take reasonable steps to ensure that you are made aware of the details of the collection (including the purposes for which the information was collected and the organisations to which the information will be disclosed) and the fact that this Privacy Policy contains details on how you may access or correct your information and how to raise any complaints.
  4. Personal information that we collect is held in different formats, including in both hard copy and electronically.
  5. If Diogenes Investing receives personal information about you that it has not requested, and Diogenes Investing would not be able to collect this information under law if it had requested it, then Diogenes Investing will destroy or de-identify the information where lawful and reasonable to do so.
  6. You are not required to disclose your personal information to us, however, if you do not do so, we may not be able to provide you with products or services that you have requested or provide you with an appropriate response to your enquiries.
    1. The way in which Diogenes Investing will use and disclose your personal information depends on the reasons for which it was collected.
    2. We will only use or disclose your personal information for the main reason for which it was collected (such as to provide you with products or services, or to respond to your enquiry), for a directly related purpose, or otherwise where you have consented to such use or disclosure, or the use or disclosure is in accordance with the law.
    3. Some of the specific instances where we will collect, use and disclose your information is to:
    4. assess and review your employment enquiry;
    5. provide you with marketing and promotional material regarding the goods and services we offer;
    6. undertake research (i.e., market research or services and products research, the results of which may be published but without your personal information (except with your prior consent));
    7. provide you with any of our products and services;
    8. manage and administer our products and services;
    9. add you to our mailing list and contact you with newsletters and/or other materials that might be of interest to you; and
    10. investigate your feedback regarding our products and services.
    1. Diogenes Investing may, from time to time, use your personal information to provide you with updates and information about other products and services, details of current promotions and so that it can undertake market research or research into the types of services we offer. This information may be shared with you using a variety of channels, such as direct mail, email and telephone. We may also collect and use your demographic and other data for market research, statistical, advertising and promotional purposes.
    2. We will only provide you with such communications in accordance with the law. If you do not wish to receive these communications from us, please send us an email at
    1. We may engage third party providers and individuals to facilitate our services/ to provide services on our behalf and/or to perform service-related services or to assist in analysing how our service is used.
    2. These third parties have access to your personal information only to perform these tasks on our behalf and are obliged not to disclose or use it for any other purpose.
    1. We may disclose your personal information as follows:
    2. to our data hosting and other service providers worldwide including in Australia.
    3. This does not diminish your rights and we will take all reasonable steps to ensure transferred information is kept secure in accordance with the Act. By submitting your personal information to us you agree that you do not object to any such transfer, processing or storage. If we merge, combine or sell a part of our business, we may also pass on your details to our new colleagues and any entity through which they operate unless prohibited from doing so by law.
    4. We do not share your personal information with other organisations unless you give us your express consent, where sharing is otherwise required or permitted by law, or where this is necessary to enable our contractors to perform specific functions, such as to assess or carry out your request.
    5. Please also note that your information, including personal information may be transferred to — and maintained on — computers located outside of your state, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
    6. If you are located outside Australia and choose to provide information to us, please note that we transfer the information, including personal information, to Australia and process it there.
    7. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
    1. Where lawful and practicable, you have the option of dealing with Diogenes Investing anonymously or by using a pseudonym, including through our website and social media pages. However, we will generally require your contact details if you would like us to transact with you.
    1. Diogenes Investing will take all reasonable steps to ensure that your personal information is protected against misuse, interference and loss, and unauthorised access, modification or disclosure.
    2. When your personal information is no longer needed for the purposes for which Diogenes Investing is authorised to use or disclose it, we will take reasonable steps to destroy the information or ensure it is de-identified unless such information is required to be retained by law.
    1. You have the right to request access to the personal information you provide, and to correct or update your personal information. This right is subject to certain exceptions allowed by law.
    2. To obtain access to your personal information:
    3. you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
    4. you will need to be reasonably specific about the information you require; and
    5. we may charge you a reasonable administration fee, which reflects the cost to us for providing access in accordance with your request.
    6. In certain circumstances, Diogenes Investing may refuse to allow you access to your personal information where this is authorised by the law, such as where giving access would have an unreasonable impact on the privacy of others, or where providing you with access would be unlawful.
    7. Diogenes Investing takes all reasonable steps to ensure that the personal information it collects, uses and discloses is accurate, up-to-date and complete, relevant and not misleading. If you believe that the personal information we hold about you requires correction, you may request that the information be corrected by contacting us using the details in this Privacy Policy. Where we correct your personal information, we will also take reasonable steps to notify third parties that have previously been disclosed your information of the correction.
    8. If we refuse your request for access or correction, we will provide you with written reasons for the refusal, and how you may complain about the decision.
    9. Further, you may instruct us to remove any previous consent you may have provided to receive marketing communications from Diogenes Investing or to remove you from its database.
    1. As set out above, we may collect your personal information through our website, such as your email address and contact details when you submit an online enquiry through one our website pages. Diogenes Investing will handle such information in accordance with this Privacy Policy and the law.
    2. Diogenes Investing may also collect site usage data through its use of internet cookie technology or similar devices. Cookies are small data files which record your visit and may collect statistical information about your visit (such as the pages you visit on our website) in order to customise and improve your website experience. Most internet browsers will accept cookies automatically, but you can delete or disable cookies by changing your browser settings, however some parts of our site may not work properly if you do. This information may be analysed to provide us with insights into users interests and behaviour and may include the use of websites using a range of common technical tools, including cookies, pixels and transparent GIF files.
    3. For completion, a cookie is a small file of letters and numbers that is put on your computer if your browser settings allow this. These cookies allow our service provider to distinguish you from other users of the website which helps them to provide you with a good experience when you browse our websites, and allows us to improve our site.
    4. For completion, we may have third party analytics services applied to our website which also track a user’s online activities across unrelated websites and allows for customised presentation of advertising material to your browser (using adware). We do not receive reports that identify you, however the providers of the analytic services may be able to identify users from your IP address, and may use this personal information about your internet use for their own purposes or those of other clients.
    5. Furthermore, some of our webpages may contain links to other third-party sites. Whilst we take reasonable steps to ensure this is always clear, we do not take responsibility for any collection or use of personal information if you choose to click on these links, and you should refer to the privacy policies of the relevant third party in this regard.
    6. Our websites use industry standard tools to safeguard any personal information when being transmitted over the Internet. There are however inherent risks in transmitting personal information over the Internet, and neither Diogenes Investing nor its service providers can guarantee the security of information you choose to provide through our websites.
    1. Diogenes Investing uses remarketing services to advertise on third party web sites to you after you visited our service. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service. Please note:
    2. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: Google also recommends installing the Google Analytics Opt-out Browser Add-on – – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
    3. Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: Facebook adheres the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada in Canada or the European Interactive Digital Advertising Alliance in Europe, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy:
    1. This Privacy Policy meets Diogenes Investing obligations under the law which requires us to set out our policies on the management of personal information in a clearly expressed document which is available to anyone that asks for it.
    2. Without limiting the generality of the above statement, your access to this communication constitutes an acknowledgement that you have been made aware of our Privacy Policy.
    3. This policy does not create or confer upon any individual any rights or impose upon us any rights or obligations outside of, or in addition to, those imposed by the Act.
    1. Diogenes Investing is committed to working with its clients and members of the public to obtain a fair resolution of any complaint or concern about privacy. To contact us with a query, compliment or complaint, please provide our Privacy Officer with the full details of your complaint and any supporting documentation, using the following contact information:
    2. Email:
    3. Upon receipt of your query, compliment or complaint, our Privacy Officer will endeavour to:
    4. provide an initial response to you within 7 business days
    5. investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
    6. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner or to the equivalent in your home country.
    1. Diogenes Investing reserves the right to change this Privacy Policy at any time, and any amended Privacy Policy is effective upon posting to our website

2. Diogenes Investing make every effort to communicate any significant changes to you via email, however your continued use of our website, and acceptance of our products and services, will be deemed acceptance of any amended Privacy Policy.


This Privacy Policy was last modified: July 2021






Diogenes Investing Pty Ltd ATF Gray Holdings Trust;  ABN 90 095 371 433;  Level 19/10 Eagle Street Brisbane QLD 4000