Privacy Policy

1. Purpose of this Policy

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us. We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).

2. The Kinds of Personal Information We Collect

The types of personal information we may collect will depend on the nature of our engagement and interactions with you. Examples of personal information we may collect and hold include but are not limited to the following:

• name;
• company name;
• residency;
• date of birth;
• country of residence;
• job title and employer;
• Tax File Number;
• employee record information;
• CV, resume or application related behaviour;
• contact details such as address and 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
• online interactions with our website, publications, alerts and social media activity.

Casa Advisory also collects certain information not directly provided by third parties, such as an IP address, browsing pattern on the site, click stream, and the status of cookies placed on a computer. Casa Advisory does not collect any personal information other than information reasonably necessary for, or directly relating to, the primary purpose for which Casa Advisory has been engaged or may be engaged, or its other functions and activities.

3. How We Collect Personal Information

As much as possible, Casa Advisory only collects 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.

Casa Advisory may from time to time collect personal information from alternative sources, including:

• concerning an associate of a client or prospective client (e.g. a spouse or 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 collect 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 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 court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc.).

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. We also log IP addresses to help diagnose problems with our server and to administer the site.

If you prefer not to accept a cookie, you can set your web browser to warn you before accepting any cookies or refuse all cookies by turning them off in your browser settings.

If Casa Advisory collects 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. 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 an application form with Casa Advisory;
• where information is collected from publicly available sources including Freedom of Information Act 1982 (Cth) searches, court judgments, directorship and bankruptcy searches, and social media platforms; or
• as otherwise required or authorised by law.

Unsolicited information: In the event Casa Advisory collects personal information in circumstances where we have not requested or solicited that information, and it is determined that the personal information is not required, we will destroy the information or ensure that it is de-identified. Where unsolicited information relates to potential future employment, Casa Advisory may retain it on its human resource records at its discretion.

4. How We Use Your Personal Information

Casa Advisory may use and disclose personal information about an individual for the "primary purpose" of collection — that is, the dominant or fundamental purpose for which that information is collected. This includes facilitating our internal business processes, communicating with clients and external parties, providing ongoing marketing information about our products and services, complying with our legal obligations, and dealing with enquiries and complaints.

In certain circumstances, the law may permit or require us to use or disclose personal information for other purposes where a client would reasonably expect us to do so and the purpose is related to the purpose of collection.

For tax clients, Tax File Numbers can only be collected by tax agents and accountants, used only to conduct the client's affairs, and disclosed only to the client and the Australian Tax Office.

5. Disclosure of Personal Information

Casa Advisory will ordinarily make the following disclosures of your personal information where necessary to support the delivery of client services or other related activities:

• third party service providers utilised in connection with any administrative matters;
• service providers (including IT service providers and consultants) who assist Casa Advisory in providing or marketing our services;
• related entities and related bodies corporate of Casa Advisory;
• third parties in connection with the sale of any part of Casa Advisory's business;
• our contractors and agents;
• superannuation details to a fund administrator;
• Tax File Number Declaration to the Australian Taxation Office;
• where Casa Advisory is required by law to comply with court orders, subpoenas or other legislation; and
• your superannuation company.

We may also use or disclose your personal information without seeking additional consent where: it is for a purpose related to the primary purpose of collection and you would reasonably expect such use; it is reasonably necessary to lessen a serious threat to an individual's life, health or safety; we have reason to suspect unlawful activity; or it is required or authorised by law.

Overseas disclosures: Where we disclose your personal information to third parties who may store or transfer information outside of Australia, we will only do so to countries with laws that substantially protect your personal information in a manner consistent with the Australian Privacy Principles, and/or we will take reasonable steps to require that overseas recipients protect your personal information accordingly.

6. Sensitive Information

Sensitive information includes details about your racial or ethnic origin, political opinions, religious beliefs, criminal record, or health information. Our policy is to avoid collecting sensitive information wherever possible. However, if it is necessary to provide our services, we will seek your consent and take all reasonable steps to ensure it is securely protected.

7. Storage and Security

We are committed to ensuring that the personal information we collect 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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

8. Website and Cookies

We may use cookies on our site from time to time. Cookies are text files placed in your browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If you choose to provide our site with personal information, this information may be linked to the data stored in the cookie.

We may also use web beacons (also known as Clear GIFs) — small pieces of code placed on a web page to monitor visitor behaviour and collect data about how a web page is viewed. For example, web beacons can be used to count visitors or to deliver a cookie to the browser of a visitor viewing that page.

9. Accessing and Correcting Your Information

Choice and consent: By providing personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You are not required to provide personal information to us; however, if you do not, it may affect your use of this site or the services offered on or through it.

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. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.

Correction: 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. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Unsubscribe: To unsubscribe from our email database or opt out of communications (including marketing communications), please contact us using the details below or opt out using the opt-out facilities provided in the communication.

10. Complaints

If you believe we have breached the Australian Privacy Principles and wish to make a complaint, please submit it to us in writing. We will promptly investigate your complaint and aim to provide a written response within 30 days of receipt.