Privacy Policy

About Us

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website.

In this Privacy Policy, "we", "us" or "our" means The Trustee for Fraser Social Purpose Investments Trust ABN 23 772 236 044

We are committed to complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and where applicable, the Tax Agent Services Act 2009 (Cth) in our handling of personal information.

What is Personal Information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information includes information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

In the context of accounting and business advisory services, sensitive information may also include financial information such as income, assets, liabilities, tax records, and business performance data, which we treat with the highest level of care and confidentiality.

What Personal Information Do We Collect?

The types of personal information we may collect about you include:

Your name and the names of related individuals such as directors, trustees, and beneficiaries

Your contact details, including email address, mailing address, street address and telephone number

Your date of birth and identification information required for regulatory compliance purposes

Your Tax File Number (TFN) and Australian Business Number (ABN), collected and handled in accordance with the Tax File Number Guidelines and applicable tax legislation

Financial information including income, expenses, assets, liabilities, bank account details, investment portfolios, superannuation balances, and tax records

Business information including financial statements, profit and loss records, business structures, company and trust documentation, shareholder agreements, and ASIC registration details

Superannuation and SMSF information where you engage us for self managed super fund services

Employment and payroll information where we provide payroll or bookkeeping services

Your preferences, goals, and information you provide to us through our advisory and planning processes

Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and browsing behaviour

Information about your access and use of our website

Any other personal information requested by us or provided by you or a third party in connection with the services we provide

How Do We Collect and Store Personal Information?

How We Collect

We collect personal information in a variety of ways, including:

When you provide it directly to us, such as when you contact us, make an enquiry, engage our services, or complete onboarding documentation

When you provide us with financial records, tax documents, business records, or other materials as part of our service delivery

Through our secure client portal and cloud-based accounting platforms such as Xero

From third parties such as the Australian Taxation Office (ATO), ASIC, your bank or financial institution, or other professional advisors acting on your behalf

From publicly available sources such as ASIC registers or government databases

Through our use of cookies and other tracking technologies on our website

Where reasonable and practical, we will collect your personal information directly from you.

Where We Store

We store personal information in secure physical and electronic formats. This may include:

Secure servers and databases located in Australia

Cloud-based accounting and practice management platforms, including Xero and other third party software providers

Physical records stored securely at our premises

Some of our service providers may store data outside of Australia. Where this occurs, we take reasonable steps to ensure your information is protected in accordance with the Australian Privacy Principles.

Why Do We Collect, Hold, Use and Disclose Personal Information?

We may collect, hold, use and disclose personal information for the following purposes:

To provide accounting, tax, bookkeeping, business advisory, and related professional services to you

To prepare and lodge tax returns, business activity statements, and other documents with the ATO and relevant regulatory bodies on your behalf

To provide business advisory, strategic planning, budgeting, forecasting, and financial analysis services

To assist with business structure advice, including company, trust, and SMSF establishment and administration

To comply with our obligations as registered tax agents under the Tax Agent Services Act 2009 (Cth) and our obligations under applicable taxation and corporate legislation

To contact and communicate with you about our services and your ongoing advisory relationship with us

For internal record keeping, administrative, invoicing and billing purposes

For analytics, market research and business development, including to operate and improve our website

For advertising and marketing, including to send you relevant information about our services

To comply with our legal obligations and resolve any disputes that we may have

To consider your employment application where applicable

Any other purpose for which the information was collected

Do We Disclose Personal Information to Third Parties?

We may disclose personal information to:

The Australian Taxation Office (ATO), ASIC, and other government and regulatory bodies as required in the course of providing our services or as required by law

Third party service providers including cloud accounting platforms, practice management software providers, IT service providers, data storage providers, web hosting providers, and professional advisors

Our employees, contractors, and related entities involved in delivering services to you

Financial institutions, banks, and lenders where required in connection with funding or advisory services

Legal professionals, including lawyers and conveyancers, where required in connection with business structuring or other advisory matters

Our existing or potential agents or business partners

Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred

Courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights

Third parties to collect and process data, which may include parties that store data outside of Australia

We do not sell your personal information to third parties.

Disclosure to Overseas Recipients

Some of the recipients to whom we disclose your personal information may be based overseas, including cloud software providers whose servers may be located outside Australia. It is not practicable to list every country in which such recipients are located.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a manner consistent with the APPs.

Tax File Number Information

We are required to collect your Tax File Number (TFN) in order to provide certain tax and accounting services. We handle TFN information strictly in accordance with the Tax File Number Guidelines issued under the Privacy Act 1988 (Cth). Your TFN will only be used for lawful purposes directly related to the provision of our services and will not be disclosed to third parties except as required by law or with your consent.

How Do We Treat Sensitive Information?

We will only collect sensitive information about you with your consent, unless we are required or authorised by law to collect such information.

Sensitive information, including detailed financial and business information, will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you otherwise agree, or an exemption under the Privacy Act applies.

Your Rights and Controlling Your Personal Information

Your Choice and Consent:

By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide accounting, tax, or advisory services to you.

Information from Third Parties:

If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy.

Marketing Communications:

We may use your personal information to send you relevant updates, newsletters, and information about our services. You can opt out at any time by contacting us using the details below or by using the unsubscribe facilities provided in the communications.

Access to Your Personal Information:

You may request access to the personal information that we hold about you. We will respond to your request within a reasonable period and may charge a reasonable administrative fee for doing so.

Correction of Your Personal Information:

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below and we will take reasonable steps to correct it.

Complaints:

If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below. We will promptly investigate your complaint and respond to you in writing. You also have the right to contact the Office of the Australian Information Commissioner (OAIC) if you wish to make a complaint.

Unsubscribe:

To unsubscribe from our email database or opt out of communications, please contact us using the details below or use the opt-out facilities provided in the communication.

How Do We Store and Protect Your Personal Information?

We are committed to ensuring that the personal information we collect is secure. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

How Long We Keep Your Information:

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law. For tax and accounting records this is typically a minimum of five years in accordance with ATO requirements, though longer retention periods may apply in certain circumstances. We will take all reasonable steps to destroy or permanently de-identify personal information when it is no longer required.

Security of Information:

While we take all reasonable steps to protect your personal information, we cannot guarantee the security of any information you transmit to us over the internet. The transmission and exchange of information is carried out at your own risk.

Cookies and Web Beacons

We may use cookies on our website from time to time. Cookies are text files placed in your browser to store your preferences and may allow third parties such as Google to serve relevant advertisements as part of retargeting campaigns. You can control and manage cookies through your browser settings, however disabling cookies may affect the functionality of our website.

We may also use web beacons to monitor visitor behaviour and collect data about the viewing of web pages on our site.

Links to Other Websites

Our website may contain links to other websites. We are not responsible for the privacy practices of those websites and recommend you review their privacy policies independently.

Updates to This Privacy Policy

We may vary this Privacy Policy at any time by publishing the amended version on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy. Your continued use of our website and services following any changes will be taken to indicate your acceptance of those changes.

Contact Us

For any questions, concerns, or notices regarding this Privacy Policy, or to make a request to access or correct your personal information, or to make a complaint, please contact our Privacy Officer at:

Segue Advisory Group
Email: helen@baylandfinance.com.au

Phone: 0406 608 916

Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au

Phone: 1300 363 992