PRIVACY POLICY
1. We respect your privacy
1.1 Count on Grace Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth). This policy sets out how we collect and treat your personal information.
1.2 "Personal information" is information we hold which is identifiable as being about you.
2. Kinds of Information collected
2.1. Count on Grace Pty Ltd will, from time to time, receive and store both personal information and sensitive information from you when you enter onto our website, provided to us directly or given to us in other forms.
2.2. Personal information is any information about you that identifies you or by which your identity may be reasonably determined. The kinds of personal information that may be collected from you includes, but is not limited to, your full name, address, phone number, email address and payment details. By collecting this personal information, we are able to contact you when necessary, identify and protect your information from unauthorised use and provide the best possible service.
2.3. Sensitive information includes information or an opinion about an individual’s race, religion, political or trade association, among others. The kinds of sensitive information we may collect from you can include, but is not limited to your tax file number, medical history or affiliations. We will only collect sensitive information in circumstances where you have consented to the collection and if the information is reasonably necessary for us to provide our services.
3. Collection of Personal Information
3.1. Count on Grace Pty Ltd will collect your personal information directly from you, online and from third parties.
3.2. We may collect your information to provide selected services to you at your request and to ensure that you receive the best possible service.
3.3. We will only collect personal information about you:
from you (including via online enquiry forms you submit, our direct discussions with you, any emails, blogs, letters or other correspondence you send to us and when you subscribe to our online publications);
if you have created an online account including an account to facilitate file transfers or payment information with us, from your use of that online account;
from any person authorised by you to provide such personal information to us (such as your professional advisors or personal representatives);
from third party contractors and suppliers we engage to help us provide services;
from external sources where the information is publicly and readily available; and
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.
3.4. As an example, and without limiting the types of personal information we collect, we may collect the following personal information (a) name, address, 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 details, credit card details and details of your investments.
3.5. 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, we may be unable to provide you with the best possible service.
3.6. Through use of our Website, 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 may also use cookies that are small pieces of information that allow an organisation to track websites browsed by you. If you do not want to allow cookies to be used to collect information, you may disable cookies on your computer by changing the security and privacy settings in your browser. However, if you do disable cookies, you may not be able to interact with our website or take advantage of the improved functionality that cookies enable.
3.7. 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.
3.8. We will not collect personal information by unlawful means or means that are unfair or intrude to an unreasonable extent upon your personal affairs.
4. Use of Personal Information
4.1. How we use your personal information varies based on the services we are providing. We will only use your personal information for the purpose it was obtained unless you consent to its use for another purpose or where an exception applies under the Acts.
4.2. Generally, we may use your personal information:
as necessary to provide services to you;
in administering our Website;
in order to enable your access to our Website services;
to perform due diligence and conflict checks prior to agreeing to provide services to you;
to send you marketing communications;
for customer relationship management purposes and to supply to you the services which you have requested;
to send you statements and invoices and collect payments from you;
for recruitment purposes;
to analyse client needs and improve the services we provide;
for audit, regulatory and compliance purposes;
for industry accreditation purposes;
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
for other purposes related to our provision of business advisory services to you.
4.3. We may use personally identifiable information in a summative form to improve our services and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.
4.4. 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).
4.5. We may also use the information collected to provide to you information (via email or post) that has been requested by you personally. If at any time you receive material that you did not request and do not want to receive any such material anymore, please email us at hello@countongrace.com.au.
5. Disclosure of Personal Information
5.1. We may disclose your personal information:
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;
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;
to third parties with whom we are affiliated for the purpose of those third parties providing you with information about their services and promotions;
as required or authorised by law or to meet our professional standards;
where disclosure is necessary to prevent or lessen a serious threat such as public health or safety;
to any person with your consent;
where your information is publicly available;
where your information has been de-identified in a form or for statistical or research purposes;
to our professional advisers but only so they can advise us in respect of the same.
5.2. We will not sell, transfer, assign or rent your personal information. In order to operate the website and to deliver to you the service which you have requested, we may sometimes share your personal information with an affiliate, which is necessary to deliver your requested items or services to you.
5.3. Count on Grace Pty Ltd may need to disclose your personal information where you have consented to us doing so in providing you with our service or where disclosure is necessary to achieve the purpose for which it was submitted.
5.4. We may need to disclose or transfer your personal information if Count on Grace Pty Ltd is acquired or merged with another entity.
5.5. Count on Grace Pty Ltd will, at all times, attempt to ensure that we do not disclose your personal information to a third party where consent for such disclosure has not been given. In all cases where we may be required to disclose information we will attempt to obtain your direct consent for such disclosure. Where your personal information is disclosed to a third party we will take all reasonable steps to prevent unauthorised use or disclosure of your information.
5.6. Please note that if at any time the Count on Grace Pty Ltd is required by law to release information about you, we must cooperate fully. We may also disclose your information in order to investigate, halt, or take action regarding illegal activities.
6. Security of your personal information
6.1 Count on Grace Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
6.2 The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
7. Collection, use and disclosure of Sensitive Information
7.1. We will only collect sensitive information from you directly as reasonably necessary to provide services to you and with your consent.
7.2. As an example, and without limiting the types of sensitive information we collect, we may collect the sensitive information including your tax file number.
7.3. Count on Grace Pty Ltd will not collect your tax file number unless you have completed a New Client Details Form. You may revoke your consent at any time if you are no longer a client of the Count on Grace Pty Ltd, in which case, we will only retain your tax file number for any purpose required by law or under any contract with its licensee.
7.4. Subject to paragraph 7.5, sensitive information will only be disclosed 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.
7.5. 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).
8. Direct marketing
8.1. We may use or disclose your personal information for direct marketing purposes, being:
to promote our services and provide you with information and marketing materials about other services that may be of interest to you
to provide information relevant to your type of business or other area of expertise or interest; and
to provide you with the opportunity to attend seminars, conferences or other events that may be of interest to you.
8.2. If you subscribe to receive information from our Website, then your e-mail address and other information that you provide will be recorded. Count on Grace Pty Ltd may, from time to time, use your personal information, such as your address and contact details, to provide you with marketing updates or information about the services that we offer.
8.3. If you do not wish to receive Direct Marketing communications from us, you can ‘opt out’ by clicking the ‘Unsubscribe’ link in our emails or other electronic communications, or sending an email to hello@countongrace.com.au with your contact details requesting that you no longer receive Direct Marketing materials from us. We will remove you from our Direct Marketing database as soon as reasonably practicable after receiving a request but in any event, within 30 days of receiving such a request.
9. Access to your personal information
9.1 You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). A small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at hello@countongrace.com.au.
9.2 We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
10. Complaints about privacy
10.1 If you have any complaints about our privacy practices, please feel free to send in details of your complaints to 11 Pandanus Ct, Stanhope Gardens, New South Wales, 2768. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
11. Changes to Privacy Policy
11.1 Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.
12. When you visit our website
12.1 When you come to our website (www.countongrace.com.au) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
12.2 Cookies
We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.
12.3 Third party sites
Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Count on Grace Pty Ltd is not responsible for the privacy practices of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
For any questions and notices, please contact us at:
Count on Grace Pty Ltd
ABN 34 632 076 576
hello@countongrace.com.au
Last Updated: 14th July 2019