This Privacy Policy (Privacy Policy) outlines the way in which ProAcc Australia Pty Ltd ACN 163 624 351 (ProAcc Australia, we, us, our) collects, holds, uses and discloses personal information. By using our websites, applications and services, or otherwise providing us with your information, you consent to us collecting, holding, using and disclosing your personal information as described in this Policy. If we are not able to collect, handle, use and disclose personal information about you as set out in this Policy, we may not be able to provide you with our services or with access to our websites or applications. ProAcc Australia is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cwlth) (Privacy Act). This Privacy Policy sets out how ProAcc Australia handles personal information. This Privacy Policy does not apply to personal information collected by ProAcc Australia that is exempted under the Privacy Act, for example employee records. ProAcc Australia may modify this Privacy Policy from time to time to reflect its current privacy practices.

PERSONAL INFORMATION WE COLLECT

The types of personal information we collect depends on the nature of our engagement with you. Examples of personal information we may collect include:

• name;
• company name;
• residency;
• date of birth;
• country of residence;
• job title and employer;
• tax file number;
• employee record information;
• contact details such as address, email address;
• business/mailing address;
• title;
• nature of business;
• bank account and credit or debit card details;
• advice received from the client or prospective client that may contain additional personal information, such as family relationships and other business-related connections;
• qualifications, memberships and other accreditations;
• financial records;
• racial or ethnic background, political or religious beliefs; and/or
• online interactions with our website, publications, alerts and social media activity.

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. It is generally not practical to remain anonymous or to use a pseudonym when dealing with us as usually we need to use your personal information to provide specific services to you, or which relate to or involve you. We do not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which we have been engaged or may be engaged, or its other functions and activities.

HOW WE COLLECT PERSONAL INFORMATION

Generally we collect your personal information from you directly, for example, when we deal with you in person or over the phone, when you send us correspondence, including via email, when you complete a questionnaire, form or survey, when you subscribe to our publications or when you use our website or our social media. Sometimes it may be necessary for us to collect your personal information from a third party. We may collect your personal information from your employer where they are our client, from your personal representative, another member firm or a publicly available record. We may also collect personal information about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites. As much as possible, we only collect personal information that has been directly provided to us by our clients or prospective clients, associates of clients, our suppliers or potential suppliers, our employees or potential employees, or is otherwise available in the public domain where this information will assist us with the provision of services to our current and prospective clients. Information may have been provided verbally or in writing (including by email or through web forms). We may from time to time collect personal information from alternative sources. Some examples of these alternative collection events are:

• concerning an associate of a client or a prospective client (e.g. a spouse or a child) where it is considered unreasonable or impracticable to seek this same information directly from the associate;
• when we collect personal information about you from third parties;
• personal information collected from your business card;
• when we collected personal information about you from a referee provided by you on an application made with us;
• when we collect information from you in order to provide you with services, a quote for services or our invoices in relation to services rendered;
• when we collect personal information about you when you register to attend or attend an event; or
• when we collect personal information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc.).

Also, our website uses cookies to identify site users and their interests and to track usage of the site. Cookies are small pieces of text stored on a computer that help us to know which browser the operator is using, where they have been on the site and any websites to which they may link in order to use some of our features. By acceptance of our cookie, the user will be permitted access to certain pages of the site without having to log in each time they visit. A user who does not accept the cookie from the site may not be able to access certain areas of the site. We also log IP addresses, or the location of computers on the internet to help diagnose problems with our server and to administer the site. If the user prefers not to accept a cookie, they can set their web browser to warn them before accepting any cookies. Alternatively, they can refuse all cookies by turning them off in their web browser. If we collect details about you from someone else, we will whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause below. In general, we will not tell you when we collect personal information about you in the following circumstances:

• where information is collected from our share registry provider;
• where information is collected from any personal referee you have listed on any application form (including any employment application);
• where information is collected for publicly available sources including but not limited to, Freedom of Information Act 1982 (Cwlth), searches, court judgements, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc.); or
• as otherwise required or authorised by law.

WHERE YOU PROVIDE US WITH PERSONAL INFORMATION ABOUT SOMEONE ELSE

If you provide us with someone else’s personal information, you should only do so if you have their authority or consent to provide us with that information. You should also take reasonable steps to inform them of the matters set out in this Privacy Policy or any Privacy Collection Statement we give you.

HOLDING PERSONAL INFORMATION

We hold personal information in hard copy and electronic formats. We take security measures to protect the personal information we hold including physical (for example, security passes to enter our offices and storage of files in lockable cabinets) and technological (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates). We also have policies and processes which govern document retention and data breach incidents. In some cases, we engage third parties to host electronic data (including data in relation to the services we provide) on our behalf.

PURPOSE FOR COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION

We collect, holds and uses personal information for a number of purposes including:

• to provide and enhance our services and those of other member firms
• to respond to requests or queries
• to maintain contact with our clients and other contacts (including alumni), and keep them informed of our services, industry developments, seminars and other events
• to verify your identity
• for administrative purposes, including processing payment transactions
• for recruitment purposes
• for purposes relating to the employment of our personnel, providing internal services or benefits to our partners and staff and for matters relating to the partnership
• when engaging service providers, other member firms, 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 an actual (or proposed) acquisition, disposition, merger or de-merger of a business or entering into an alliance, joint venture or referral arrangement or
• to develop our expertise and know how, for benchmarking purposes, analytics, quality assurance and thought leadership, and other purposes related to our business.

As part of an engagement, if you are a customer, an employee, a contractor or supplier of services to one of our clients, then we may disclose your personal information as part of providing services to that client. The types of third parties to whom we may disclose your personal information include:

• experts or other third parties contracted as part of an engagement
• our agents, third party contractors and suppliers
• our professional advisers
• other member firms (which includes entities they wholly or dominantly own and control)
• third parties as part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business or to enter into an alliance, joint venture or referral arrangement or
• government or regulatory bodies or agencies, as part of an engagement or otherwise, (for example, the Australian Taxation Office).

We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. However, we may share non-personal, de-identified or aggregated information with select third parties for research or promotional purposes other than direct marketing.

ACCURACY OF PERSONAL INFORMATION

We will take all reasonable steps to make sure that any personal information collected, used or disclosed is accurate, complete and up to date. As the accuracy of personal information largely depends on the information that you provide to us, we request that you advise us of any errors in or updates require to your personal information. If you believe that the information we hold about you is inaccurate or out of date, they may contact our Privacy Officer (refer Section 10) and we will update the relevant information accordingly.

HOW DO WE USE AND DISCLOSE PERSONAL INFORMATION?

FOR CLIENTS The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services. FOR CUSTOMERS AND PARTICIPANTS If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur. DISCLOSURE TO CONTRACTORS AND OTHER SERVICE PROVIDERS We may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research. Personal information may also be shared between related and affiliated companies of us, located in Australia and overseas. Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies. USE AND DISCLOSURE FOR ADMINISTRATION AND MANAGEMENT We will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

• administering billing and payments and debt recovery;
• planning, managing, monitoring and evaluating our services;
• quality improvement activities;
• statistical analysis and reporting;
• training staff, contractors and other workers;
• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
• responding to enquiries and complaints regarding our services;
• obtaining advice from consultants and other professional advisers; and
• responding to subpoenas and other legal orders and obligations.

OTHER USES AND DISCLOSURES We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

DIRECT MARKETING

Proacc Australia may use your personal information for the purpose of marketing its services to you. If you do not want to receive marketing material from us, you can contact us as detailed below:

• for electronic communications, you can click on the unsubscribe function in communications; or
• for hard copy communications, you can email info@proaccaustralia.com.au; or
• through our contact details in ‘Contact Us’.

AUTOMATIC COLLECTION OF PERSONAL INFORMATION

Cookies, web beacons and other technologies are used by Proacc Australia and its service providers on some Proacc Australia websites and through email to automatically collect certain types of information. The collection of this information allows us to customise your online experience (including tailored Proacc Australia marketing), to improve the performance, usability and effectiveness of Proacc Australia’s online presence and to measure the effectiveness of our marketing activities. If you register or log into a Proacc Australia web site and provide information about your preferences, we will use your information to personalise your user experience. If you register or log into a Proacc Australia web site using a third party account (such as LinkedIn, Google or Twitter), we may collect any information you have permitted the third party service to share, including your name and email address, depending on the privacy settings you have set with the third party service and their privacy policy.

IP ADDRESS

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. Public IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis, and to enhance user experiences.

COOKIES

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites’ features. Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including public IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and is not used to identify individual visitors.

ANALYTICS TOOLS

Proacc Australia uses analytics tools, such as Google Analytics and Adobe Analytics. To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. More information about how Google Analytics is used by PROACC AUSTRALIA can be found here: https://www.google.com/analytics/terms/us.html Adobe also provides a range of opt-out options for Adobe Analytics.

WEB BEACONS

A web beacon is a small image file on a web page that can be used to collect certain information from your computer such as an IP address, the time that content was viewed, a browser type, and the existence of cookies previously set by the same server. Proacc Australia or its service providers may use web beacons to track the effectiveness of third party websites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies. You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded. In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

LOCATION BASED TOOLS

Proacc Australia may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

SOCIAL MEDIA WIDGETS AND APPLICATIONS

Some Proacc Australia websites and services may include functionality to enable information sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of Proacc Australia websites. Any personal information that you provide via such social media applications may be collected and used by members of that social media application separate to Proacc Australia. Such interactions that are monitored by social media applications are governed by the privacy policies of the relevant companies that provide the applications. We do not have control over, or responsibility for, those companies or their use of your information. In addition, Proacc Australia websites or affiliate websites may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Proacc Australia social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

LINKS TO THIRD PARTY WEBSITES

Proacc Australia websites may contain links to third parties’ websites, including sites maintained by other Proacc Australia member firms. Those other websites are not subject to our privacy policy and procedures. You will need to review those websites to view a copy of the relevant privacy policy. Unless expressly advised, Proacc Australia does not endorse, approve or recommend the services or products provided on third party websites.

YOUR CHOICES

You have several choices regarding your use of Proacc Australia websites. In general, you are not required to provide personal information when you visit our websites. However, if you make an enquiry or subscribe to receive information about our services, events and industry updates or wish to apply for a job, provision of certain personal information will generally be required to facilitate such requests.

CHILDREN

We understand the importance of protecting the privacy of children, especially in an online environment. In particular, our websites are not intentionally designed for, or directed at, children under the age of 13. It is our policy to never knowingly collect or maintain information about any person under the age of 13, except as part of a specific engagement to provide services which necessitates such personal information be collected, for the purposes of ensuring compliance with our auditor independence policies, or as otherwise required by law.

HOW DO WE INTERACT WITH YOU VIA THE INTERNET?

You may visit our website without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy. Our website use cookies. A “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information. You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website. Our website may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked to our website.

CAN YOU DEAL WITH US ANONYMOUSLY?

We will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for us to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

HOW DO WE HOLD INFORMATION?

We store information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. We maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems. Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet. We take steps to destroy or de-identify information that we no longer require.

DO WE USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

We may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below. If you opt-out of receiving marketing material from us, we may still contact you in relation to its ongoing relationship with you.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by us on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below. You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change. However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information. We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

GAINING ACCESS TO PERSONAL INFORMATION WE HOLD

You can request access to your personal information, subject to some limited exceptions as permitted or required by law. Such request must be made in writing to Proacc Australia’s Privacy Liaison. Please see ‘Contact Us’ for details. Proacc Australia may charge reasonable costs for providing you access to your personal information.

KEEPING PERSONAL INFORMATION CURRENT

If you believe that any personal information Proacc Australia has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact Proacc Australia’s Privacy Liaison and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act. Please see ‘Contact Us’ for details.

COMPLAINTS

If you wish to make a complaint to us about our handling of your personal information, you can contact our Privacy Liaison as set out in ‘Contact Us’. Following your initial contact, you will be asked to set out the details of your complaint in writing in a form provided. We will endeavour to reply to you within 30 days of receipt of the completed complaint form and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, we may decline to investigate the complaint (for example if the complaint relates to an act or practice that is not an interference with the privacy of the person making the complaint). If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner: A: GPO Box 5218, Sydney NSW 2001 E: enquiries@oaic.gov.au T: 1300 363 992 W: https://www.oaic.gov.au

HOW TO CONTACT US

If you have a query in relation to this Privacy Policy, or would like to notify Proacc Australia that you: no longer wish to receive marketing material from us, wish to want to access or correct your personal information or wish to make a complaint about Proacc Australia’s handling of your personal information; please contact Proacc Australia as follows: Privacy Liaison Proacc Australia PO Box 21, Five Dock NSW 2046 T 61 8957 8811 E info@proaccaustralia.com.au

UPDATES TO THIS POLICY

We may amend this Privacy Policy from time to time, with or without notice to you to take account of new laws and technology, changes to our operations and practices and the changing business environment. We recommend that you visit our website regularly to keep up to date with any changes. This Privacy Policy was last updated on 6 September 2020. By engaging us to provide you with services, where you have been provided with a copy of our Privacy Policy or had a copy of our policy reasonably available to you, you acknowledge and agree that, amongst other things, you consent for us to collect, hold, use and disclose such personal information in accordance with our Privacy Policy (as amended from time to time) and in accordance with your acknowledgments, consents and other matters raised therein.