Privacy policy

This policy explains how TOMBO Consulting (ACN 696 428 627, ABN 20 696 428 627) and its related company TOMBO Health, registered in Zambia (Reg. No 120251035138) — together “TOMBO”, “we” and “us” — handle personal information collected through this website.

We handle personal information in line with the Australian Privacy Principles in the Privacy Act 1988 (Cth) and, where TOMBO Health is involved, the Data Protection Act, 2021 of Zambia.

This policy covers the website only. Information collected while delivering a service — during a TOMBO Health or TOMBO Migration Services engagement, for example — is handled under the terms of that engagement and the law that applies to it.

We collect only what you choose to send us through the enquiry form:

• your name, and optionally your organisation and phone number;
• your email address;
• the service you’re asking about, and your message; and
• a record that you agreed to this policy when you sent it.

Please don’t include health information or other sensitive information in an enquiry. If an engagement needs it, we’ll ask for it at that point.

Like any website, the servers that host this one keep standard technical logs — such as IP address, browser type and the pages requested — to operate and secure the site.

You don’t have to identify yourself to ask a general question by phone, but we need a name and an email address to reply to a written enquiry.

We use your information to:

• reply to your enquiry and work out whether TOMBO is the right fit;
• scope and deliver any services you then ask us to provide;
• keep a record of our dealings with you; and
• meet our legal obligations.

We don’t sell personal information, and we won’t add you to a mailing list or send you marketing without your consent.

Before an enquiry is sent, the form asks you to agree to your details being used as this policy describes. An enquiry isn’t sent unless you agree, and a note of your agreement is kept with it.

You can withdraw your consent at any time by contacting us. We’ll then stop using your information, except where we need to keep it to meet a legal obligation.

We share personal information only where we need to:

• Email delivery. Enquiries reach our inbox through Resend, an email delivery service based in the United States.
• Website hosting. Our hosting provider processes the technical logs described above and, if an enquiry can’t be delivered, may briefly hold a copy of it so it isn’t lost.
• TOMBO Health. If your enquiry concerns health services in Africa, we may pass it to TOMBO Health in Zambia so it can respond.
• Where the law requires it, for example to comply with a court order or a regulator’s request.

These recipients may store or process information outside Australia, including in the United States and Zambia. We take reasonable steps to ensure anyone we share personal information with protects it to a standard consistent with the Australian Privacy Principles.

This website doesn’t use cookies. It doesn’t use analytics, advertising or social-media trackers either, and it doesn’t load scripts, fonts or other content from third-party services — everything is served from our own domain.

That’s why there’s no cookie banner: there is nothing to consent to. If we ever add analytics or another tool that sets a non-essential cookie, we’ll update this policy first and ask for your consent before it runs.

The website is served over an encrypted (HTTPS) connection, and we take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

We keep personal information only for as long as we need it for the purposes in this policy or as the law requires, and then securely delete or de-identify it.

You can ask for a copy of the personal information we hold about you, or ask us to correct it, using the contact details below. There is no charge for making a request, and we’ll respond within a reasonable time — usually within 30 days.

If we refuse a request, we’ll tell you why and how to complain.

If you think we’ve mishandled your personal information, please tell us first using the contact details below. We’ll acknowledge your complaint and aim to resolve it within 30 days.

If you’re not satisfied with our response, you can complain to the Office of the Australian Information Commissioner at oaic.gov.au. Where your information was handled by TOMBO Health, you can also contact the Office of the Data Protection Commissioner in Zambia.

We’ll update this policy when the way we handle personal information changes. The current version is always on this page, with the date it was last updated at the top.

For privacy questions, requests and complaints:

• Email: tommy@tombo.com.au
• Phone: +61 438 888 697 or +61 432 320 230
• Post: TOMBO Consulting, 58A Winthrop Drive, Winthrop WA 6150, Australia