Privacy Policy

1. PRIVACY COMMITMENT

Apeiiron Pty Limited places a high priority on the security of information we hold. We have developed this policy to inform you of how we manage your personal information and maintain its integrity and security.

We are subject to and seek to ensure that all Personal Information we collect is handled in compliance with the Privacy Act of 1988. This Policy sets out how we collect, hold, use and disclose information (including Personal Information) that we obtain from you. This Policy also includes our Credit Reporting Policy which sets out how we collect, hold, use and disclose Credit Information to comply with our credit reporting obligations under the Act and the Credit Reporting Code registered under section 26S(1) of the Act (Code).

2. COLLECTION OF PERSONAL INFORMATION

(a) We collect Personal Information as well as non-personally identifiable information that you voluntarily provide.

(b) We will only collect Personal Information about you:

i. from you (including via online enquiry forms you submit, our direct discussions with you, any emails, blogs, letters, faxes or other correspondence you send to us);

ii. from any person authorised by you to provide such Personal Information to us (such as your professional advisors or personal representatives);

iii. if you are part of a Group, from any other member of that Group for so long as you have provided consent to the same and have not revoked that consent by written notice to us;

iv. from third party contractors and suppliers we engage to help us provide services;

v. from external sources where the information is publicly and readily available; and

vi. from third parties (for example, your spouse) where it is otherwise unreasonable or impractical to collect such Personal Information from you directly. In such cases, we will inform you before, or as soon as reasonably practicable after, we collect such Personal Information.

(c) Naturally we collect and hold a broad range of personal information gathered during the course of providing our accounting, audit, taxation and business advisory services. However as stated above, we strive to ensure that we collect and hold only that personal information which is relevant and necessary to your specific matters.

(d) As an example, and without limiting the types of Personal Information we collect, we may collect the following Personal Information (a) name, address, date of birth and contact details such as telephone number and email address, (b) details of your interests in or ownership of entities or control of trusts, and (c) accounting information such as your tax file number, bank account and credit card details, salary and personal income and details of your investments.

(e) We will only collect information relating to your tax file number for purposes authorised by law. You are not obliged to provide your tax file number to us but if you fail to do so, there may be financial consequences.

(f) Through technology we may automatically record details including your internet address, domain name and the date and time of your visit to our Website (including the web pages viewed), your browser and operating system. If you link to our Website from another website, then that information may also be recorded. We do not use cookies, and where applicable, any submitted information by users is only stored on our website temporarily before being deleted.

(g) Where you provide us with Personal Information of third parties (for example, your spouse) you warrant to us that the relevant individuals have consented to you disclosing their Personal Information to us.

3. UNSOLICITED PERSONAL INFORMATION

There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients. In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained it will be destroyed or de-identified. We will try to notify the relevant person, whose information has been mistakenly received, if this situation arises.

4. USE AND DISCLOSURE OF PERSONAL INFORMATION

(a) How we use your Personal Information varies based on the services we are providing. Generally, we may use your Personal Information:

i. as necessary to provide services to you;

ii. to perform due diligence and conflict checks prior to agreeing to provide services to you;

iii. to inform you of developments and other services that we can provide;

iv. for customer relationship management purposes and to respond to your queries;

v. to analyse client needs and improve the services we provide;

vi. for regulatory and compliance purposes;

vii. for industry accreditation purposes;

viii. for accounting and administrative purposes (including to process transactions, provide accounting services, facilitate our internal business operations and comply with our legal or regulatory obligations); and

ix. for other purposes related to our provision of business advisory services to you.

(b) We will not use or disclose your Personal Information for a purpose other than for that which it was collected unless you have provided your consent or you would reasonably expect us to use or disclose the Personal Information for that other purpose. We will also not disclose any of your information overseas. If you are part of a Group and have consented to our use of your Personal Information so we can perform the services in the Engagement Letter in respect of each and any Group member, we may use your Personal Information as part of performing those services for any Group member unless and until you provide us with a written notice revoking such consent.

i. to our contractors, agents and service providers (for example, information technology contractors and debt collection agencies) but only (a) for the purpose of providing services to you, (b) as necessary to facilitate the operation of our business, and/or (c) for the purpose of storing your Personal Information;

ii. to the Australian Taxation Office, the Australian Securities and Investments Commission and other government bodies as required by law or as necessary to provide services to you;

iii. to third parties with whom we are affiliated for the purpose of those third parties providing you with information about their services and promotions;

iv. as required or authorised by law or to meet our professional standards; and

v. to any person with your consent.

(d) If you are part of a Group and have consented to our use of your Personal Information so we can perform the services in the Engagement Letter in respect of each and any Group member, we may disclose your Personal Information to any other Group member as part of performing those services (including disclosure in any document, financial reports or tax returns prepared by us) unless and until you provide us with a written notice revoking such consent.

(e) Information other than Personal Information collected when you visit our Website may be used to monitor usage of and decide how to improve and promote our Website, products and services (including online advertising).

5. COLLECTION, USE AND DISCLOSURE OF SENSITIVE INFORMATION

(a) We will only collect Sensitive Information from you directly as reasonably necessary to provide services to you and with your consent.

(b) As an example, and without limiting the types of Sensitive Information we collect, we may collect the following Sensitive Information (a) tax file number and (b) medical history.

(c) You may revoke your consent at any time if you are no longer our client, in which case, we will only retain your tax file number for any purpose required by law or under any contract with its licensee.

(d) We will only disclose Sensitive Information in accordance with the Act as follows: (a) for the primary purpose for which it was collected, (b) for a secondary purpose that is directly related to the primary purpose, or (c) as required by law.

(e) Information regarding your tax file number will only be disclosed to you personally and according to relevant laws (including, where you are an individual, in compliance with the Privacy (Tax File Number) Rule 2015 made under section 17 of the Act).

6. REQUIREMENT TO PROVIDE INFORMATION

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.

7. COLLECTION OF CREDIT INFORMATION

We may provide credit to you from time to time (for example, by giving you time to pay our account for services) and this may involve the collection of Credit Information. We may collect Credit Information about you (a) directly from you or from persons acting on your behalf (including via application forms submitted by you or on your behalf), and (b) from third parties, including credit reporting bodies and other credit providers, to assist us in determining whether we will provide credit to you.

8. USE AND DISCLOSURE OF CREDIT INFORMATION

(a) With your express consent, as required by law or court order and otherwise in accordance with Part IIIA of the Act and the Code, we may use or disclose the Credit Information we have collected to:

i. credit reporting bodies;

ii. third parties that perform credit assessment and debt collection services on our behalf;

iii. our contractors, agents and service providers; and

iv. current or prospective guarantors in relation to credit we may provide to you.

(b) We may use or disclose Credit Information we have collected about you to:

i. decide whether or not to provide credit to you;

ii. assess your suitability to act as a guarantor for another credit facility;

iii. collect outstanding debts and enforce guarantees; and

iv. comply with our legal or regulatory obligations.

(c) We may also use Credit Information we hold about you for internal management purposes and to respond to queries or complaints about our treatment of your Credit Information. We may disclose your Credit Information to credit reporting bodies if you fail to make payments to us or if you commit a serious credit infringement.

(d) The credit reporting policies for such credit reporting bodies will be available on their websites. You have the right to contact any credit reporting bodies to whom we disclosure your Credit Information and request that they do not (a) use your Credit Information for pre-screening purposes to determine your eligibility to receive direct marketing from credit providers, and (b) use or disclose your credit information if you have been or are likely to be a victim of fraud.

9. HOLDING AND SECURITY OF YOUR PERSONAL INFORMATION AND CREDIT INFORMATION

(a) We may store your Personal Information and Credit Information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.

(b) We take reasonable steps to:

i. ensure that any Personal Information or Credit Information we hold or disclose about you is up to date, complete and correct; and

ii. protect your Personal Information and Credit Information from misuse, interference, loss, and unauthorised access, modification and disclosure using electronic and physical security measures such as:

A. securing our premises;

B. placing passwords and varying access levels on databases to limit access and protect electronic information;

C. the use of firewalls, encryption, passwords and digital certificates; and

D. providing locked cabinets for the storage of physical records.

(c) We will destroy or delete any of your Personal Information or Credit Information which we no longer need to retain noting that we are required by law to retain certain information for a number of years after we have ceased providing the services. If you email us any information (including Personal Information or Credit Information), it is sent at your own risk as it may not necessarily be secure against interception.

10. ACCESSING AND CORRECTING PERSONAL INFORMATION AND CREDIT INFORMATION

(a) Credit Information is still correct when you interact with us in any way, and (b) contacting you if we become aware that your Personal Information or Credit Information is no longer correct.

(b) On your request, except to the extent that we are lawfully able to refuse such a request, we will provide you with access to Personal Information and Credit Information that we hold about you. All requests about the Personal Information or Credit Information that we hold should be made by email or in writing to us (see clause 14 of this Policy for our contact details). We will try to respond to your request within a reasonable period.

(c) If you satisfy us that Personal Information or Credit Information that we hold about you is misleading, inaccurate, out of date or incomplete, except to the extent that we are lawfully able to refuse such a request, we will correct the Personal Information and Credit Information that we hold about you. If it is reasonable and practicable to do so, we will give you access to your Personal Information and Credit Information in the manner that you request. We do not generally charge for providing such access but may do so in certain circumstances.

(d) In the event that we deny access to or refuse to correct your Personal Information or Credit Information that we hold, we will provide you with written reasons and the mechanisms available to complain about such refusal.

11. THIRD PARTY WEBSITES

When you leave our website, you will be going to websites that are beyond our control. Our Policy does not apply to third party websites. Our Policy only governs the handling of your personal information by Apeiiron Pty Limited. We encourage you to read the privacy policies of other third-party websites before disclosing any Personal Information.

12. CHANGES TO POLICY AND COMPLAINTS

This Privacy Policy is not a static document; we may make changes to this Privacy Policy from time to time for any reason. We will publish these changes on our Website. If you believe that we have breached our privacy or credit reporting obligations under the Act, you can make a complaint in writing by emailing us (see clause 14 of this Policy for our contact details). We will attempt to complete our investigation and resolve your complaint within 30 days from the date you lodge your complaint. If we think it will take longer to resolve your complaint, we will inform you. We may decline to investigate a complaint, for example in instances where the complaint relates to privacy issues that are unreasonable, unlawful, frivolous, or interferes with another’s right to privacy. If we do not resolve your complaint to your satisfaction or you are dissatisfied with the action we have taken, you can make a complaint to the Office of the Australian Information Commissioner. For further information about how to do this, please contact the Office of the Australian Information Commissioner on 1300 363 992 or visit www.oaic.gov.au.

13. DEFINITIONS

In this Privacy Policy (Policy):

(a) a reference to us, our or we is Apeiiron Pty Limited.

(b) Act means Privacy Act 1988 (Cth).

(d) Credit Information includes identification information (for example, name, date of birth, driver’s licence number, current and recent addresses and employment details), historical details of credit (including type and amount of credit sought or obtained) and repayment history, information about applications for credit, information about defaults and payment arrangements, details of insolvency proceedings, bankruptcy agreements, judgements and arrangements with creditors, information relating to activities and credit worthiness in Australia and external Territories, information recorded on the National Personal Insolvency Index and opinions of credit providers regarding serious credit infringements;

(e) Engagement Letter means the letter of engagement issued by us outlining the services to be provided by us to members of a Group which is accepted by a member of the Group.

(f) Group means the individuals, entities and/or companies defined as “the Group” in an Engagement Letter.

(g) Personal Information means information (including an opinion) about an individual whose identity is apparent or can reasonably be ascertained from the information whether true or not and whether or not recorded in a material form;

(h) Sensitive Information has the meaning given by the Act and includes Personal Information which relates to an individual’s racial or ethnic origins, religious beliefs or affiliations, trade association, trade union membership, sexual orientation, criminal record and information as to an individual’s health or biometric information.

(i) Website means all of the pages located on the website you are currently viewing, being www.apeiiron.com.au which is operated and maintained by Apeiiron.

14. CONTACT US

If you would like further information regarding this Privacy Policy, if you have concerns about the information that we currently hold about you, or any aspect of this Privacy Policy, please contact us at:

Apeiiron Pty Limited

M: +61 452 487 164

E: info@apeiiron.com.au

DISCLAIMER

In the preparation of this site we have attempted to offer the most current, correct and clearly expressed information possible. However, inadvertent errors can occur and applicable laws, rules and regulations can change.

The information contained in this site is general and not intended to serve as advice. No warranty is given in relation to the accuracy or reliability of any information. Users should not act or fail to act on the basis of information contained herein. Users are encouraged to consult with us for advice concerning specific matters before making any decision.

Apeiiron disclaims all and any liability to any person in respect of anything or in consequence of anything done or omitted to be done by any person or user in reliance, whether whole or partial, upon any information contained herein.

Liability limited by a scheme approved under Professional Standards Legislation.