PRIVACY POLICY

This Privacy Policy details how we protect your privacy and how we comply with the requirements of the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles set out in the Privacy Act. This Privacy Policy sets out our approach to gathering personal information, and our approach to the use and dissemination of such information.

This Privacy Policy may be supplemented or amended from time to time, and may be subject to privacy statements that are specific to certain areas of our website. The date of this Privacy Policy will inform you as to whether there have been updates since your last visit.

If you have any questions or concerns regarding this Privacy Policy, please contact the Privacy Officer using the contact details below.

• Collection of information

• Use and disclosure of information

• Access and correction

• Information security

• Visitors’ questions and complaints

• Additional Information

Collection of information

What personal information do we collect?

‘Personal information’ means information or an opinion about an individual whose identity is apparent or can reasonably be ascertained. Generally, we will only collect personal information about you if you voluntarily submit it to us by:

• providing your information by form, telephone or facsimile;

• sending us an email;

• sending us information via the ‘Contact Us’ page on our website; and/or

• sending us personal information when using any part of our website.

There may be occasions when we collect your personal information from other sources such as

• your employer where they are our client;

• your family members;

• your representatives, agents or referral partners;

• a related body corporate or business partner or associate of TAXSpot; and/or

• a publicly available record.

The types of personal information we may collect include:

• your name and birth date;

• your contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;

• where relevant to the services we are providing you, your financial information about your assets, occupation and income, bank account balances, account activities, payment history;

• government identifiers (such as TFN);

• shareholdings and details of investments;

• details of superannuation and insurance arrangements;

• educational qualifications, employment history and salary;

• visa or work permit status; and/or

• personal information about your spouse and dependants.

We may also store and maintain any content that you provide in connection with our website, including but not limited to postings on any blogs, forums, wikis and other social media applications and services that we may provide.

It may be necessary in some circumstances for us to collect sensitive information about you in order to provide specific services or for recruiting purposes. Examples of the types of sensitive information that may be collected in such circumstances include professional memberships, ethnic origin, criminal record and health information.

We will generally hold your personal information as either physical record, records on our servers, and on third party servers.

We may collect and hold information about you that is not personal information, including:

• data relating to your activity on our website via tracking technologies such as cookies;

• the identity of your Internet browser, the type of operating system you use, your IP address and the domain name of your Internet service provider; and

• details of any survey responses you provide.

We may use this information for internal purposes, including administering our services, diagnosing problems, generating statistics and trends, and improving the quality of our products and services. When reasonable and practicable to do so, we will collect personal information directly from you or someone authorised by you and not from third parties.

Use and disclosure of information

When will we use and disclose your information?

In general, we will collect, hold, use or disclose personal information for a number of purposes including (but not limited to):

• to provide professional services, including audit and assurance, business advisory, corporate advisory, family office, finance and lending, financial, forensic accounting, management consulting, superannuation and taxation consulting services;

• to respond to requests or queries;

• to maintain contact with our clients;

• to keep our clients and other contacts informed of our services and industry developments;

• to notify our clients of seminars and other events;

• for administrative purposes;

• for recruitment purposes;

• for purposes relating to the employment of our staff;

• when engaging service providers, contractors or suppliers relating to the operation of our business;

• to manage any conflict of interest or independence (including auditor independence) obligations or situations;

• to conduct surveys;

• for seeking your feedback;

• to meet any regulatory obligations;

• as part of a corporate transaction such as a sale, divestiture, merger or acquisition; and/or

• for any other business related purposes. By providing us with your personal information, you also consent to us using and disclosing your personal information for:

• providing you with news and information about our goods and services;

• purposes necessary or incidental to the provision of our goods and services;

• providing you with the functionality on our website, and customising and improving your online experience with us;

• personalising your experience with our products and services, for example, via connectivity with social media services;

• sending you marketing and promotional material that we believe you may be interested in, either from any of our related entities or a third party business which we consider may be of interest to you; and

• seeking your feedback on our services, or for market research purposes. You may at any time request that we discontinue sending you emails or other communications.

Your personal information may also be used and disclosed to protect our rights or property and that of our users and, where appropriate, to comply with legal processes, which may include disclosures to law enforcement, regulatory or government agencies.

Disclosure of information to third parties

Generally, we will only disclose your personal information for a purpose set out above. This may include disclosing your personal information to:

• third parties engaged to perform administrative or other business management functions;

• our business partners and associates;

• people or entities considering acquiring an interest in TAXspot’ enterprise or assets; TAXspot’ professional advisors, contractors, consultants and related bodies corporate. TAXspot’ disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with law. We may also disclose your personal information with your consent or if disclosure is required or authorised by law.

Access and correction

Accessing and checking the personal information we hold about you

We will take reasonable steps to ensure that your personal information is accurate, complete, up to date, and relevant whenever it is used, collected or disclosed. You may request access to your personal information by contacting the Privacy Officer. Subject to any legal restrictions we would be happy to advise you what personal information we hold about you if you request this. We will respond to all requests within a reasonable period.

There may be some cost to you to cover the cost of retrieving and processing the information if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form. We will let you know in advance if any charges will apply.

We rely on the accuracy of the information you provide to us. If you think that we may hold information about you that is incorrect in any way, please contact us and we will correct any errors or inaccuracies where required.

If we are unable to provide you with access to your information, or make any amendments which you have requested, we will advise you of our reasons.

If at any time you wish to know what information we are holding about you, you are welcome to request your details by contacting the Privacy Officer.

4. Information security

We have in place reasonable commercial standards of technology and operational security to protect all personal information provided to us from misuse, interference, loss, unauthorised access, modification or disclosure.

5. Visitors’ questions and complaints

If you have any questions or concerns regarding your privacy, or if you would like to make a complaint about a possible breach of this Privacy Policy or the Australian Privacy Principles, you may direct your correspondence to our Privacy Officer at [email protected]

We take all complaints seriously, and will respond to your complaint within a reasonable period.

If you believe that we have not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner.

Additional information

For further information about privacy and the protection of privacy, visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.www.oaic.gov.au

FEES

Unless otherwise agreed with you or required by law, our fees will be charged at hourly rates according to the time spent by our employees and consultants working on the matter.

How we calculate our fees may be subject to change.

Unless stated otherwise, our fees, expenses and charges exclude GST.

CLIENT RESPONSIBILITIES

You agree that you will provide us with complete, clear, accurate, meaningful and timely instructions, and all information and documents requested by us, or necessary for us to undertake and complete the work you have engaged us to perform.

You also agree that you will arrange for reasonable access to relevant individuals and documents. You acknowledge and agree that you will be responsible for the completeness, accuracy and clarity of the information supplied to us.

CONFIDENTIALITY & DATA PROTECTION

Personal information collected by us in the course of our dealings with you will be handled in accordance with our privacy policy.

The purpose of collecting your personal information is to carry out the Services and for related purposes such as staff training and education, updating and enhancing our client records, analysis for management purposes and statutory returns, legal and regulatory compliance and crime prevention.

We will use and disclose personal information as set out in our Privacy Policy.

Information you provide to us will be kept strictly confidential. Access to the information by our employees and contractors will be limited to the level of access required for them to complete the Services.

Our files may be subject to review as part of the quality control review program of Chartered Accountants Australia and New Zealand which monitors its members’ compliance with professional standards. By accepting our engagement you acknowledge that, if requested, our files relating to this engagement will be made available under this program. Should this occur, we will advise you. Very occasionally, we may also be required to disclose confidential information by law, regulatory bodies, insurers or otherwise in accordance with APES 110 Code of Ethics for Professional Accountants.

Where you share personal information regarding a third party (including your directors and employees) with us, you confirm that you have complied your obligations under the Privacy Act 1998(Cth) (including, if you are not bound by that Act, as if you were so bound), including that the personal information was lawfully collected, that you are entitled to disclose the personal information to us, and that we may use and disclose the personal information in the manner detailed above.

THIRD PARTIES

We utilise the following external services:

Microsoft Office 365 Outllook to manage our email communications

Microsoft Office 365 Sharepoint to store workpapers and client information

Xero Practice Manager to prepare and lodge information to the ATO.

Xero Pracice Manger for client billings and information storage

Quickbooks for client bookkeeping and information storage

Xero for client bookkeeping and information storage

MYOB for client bookkeeping and information storage

BGL for company secretarial matters and information storage

Gettimely is our online booking system which stores client contact details

BurstSMS is used to manage bulk client contact and stores client contact details

JUMBA Website Server

To perform Services, we provide the above listed with access to your data to the extent that this is required to perform this Services. This requires information being sent overseas in accordance with the Privacy Policy.

LIMITATION OF LIABILITY

We will provide our Services with reasonable care and skill. Our liability to you is limited to losses, damages, costs and expenses directly caused by our negligence or wilful default.

Our liability may also be limited by a scheme approved under Professional Standards Legislation. Further information on schemes is available from the Professional Standards Councils’ website: http://www.psc.gov.au.

OWNERSHIP OF DOCUMENTS

All original documents that we obtain from you to perform the Services under this engagement remain your property. However, you agree that we may make a reasonable number of copies of the original documents for our records and to provide the Services to you.

We retain all copyright in any document prepared by us during the course of carrying out the engagement for you, except where the law specifically states otherwise.

To the extent permitted by law or professional standards, we reserve the right to exercise a lien over all documents and records in our possession relating to all engagements for you until all outstanding fees and disbursements are paid to us in full.

COMPLAINTS & DISPUTES

We have a complaints process in place and will use our best endeavours to resolve a complaint or dispute to the mutual satisfaction of the parties involved. We may ask that you provide your complaint in writing to allow us to fully investigate the issues your raise.

Either party to a dispute can request the complaint or dispute is managed through external dispute resolution or mediation service. We and you agree that external dispute resolution will be undertaken before any legal claim is formally commenced. This does not override the rights of either party to seek legal action to enforce contractual rights under this engagement agreement.

REFERRAL RELATIONSHIPS

Our business has a referral relationship with the following businesses:

Duo Tax Quantity Surveyors

WealthSpot Financial Advisors

Sydney Tax Practice

Aus Home Loan Group

Outsource Financial

As part of our referral relationships referral fees may be paid or received.

To perform Services, we provide the above listed with access to your data to the extent that this is required to perform this Services.