Privacy Policy

Privacy Commitment

We have created this policy in order to demonstrate our firm commitment to your privacy. HBG Pty Ltd subject to and seek to ensure that all personal information we collect is handled in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and the subsequent 2012 and 2016 amendments (Mandatory Data Breach Notification), The General Data Protection Regulation (GDPR) and the APES 110 Code of Ethics for Professional Accountants.

2. Collection of personal information

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

2.2. 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, faxes or other correspondence you send to us and when you subscribe to our online publications);
• from any entity within HBG Pty Ltd or any entity in any other HBG Pty Ltd;
• from any person authorised by you to provide such Personal Information to us (such as your professional advisors or personal representatives);
• 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;
• 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.

2.3. 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.

2.4. 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.

2.5. 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 may also use cookies (small files exchanged between a website server and your computer) on our Website. If you do not want to allow cookies to be used to collect information, you can disable cookies on your computer by changing the security and privacy settings in your browser.

2.6. 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. Use and disclosure of Personal Information

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

• as necessary to provide services to you;
• to perform due diligence and conflict checks prior to agreeing to provide services to you;
• for customer relationship management purposes and to respond to your queries;
• 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 accounting and business advisory services to you.

3.2. 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.