This policy explains how Prime Partners Pty Ltd (ABN 35 119 814 318), trading as Prime Partners ("we", "us", "our"), collects, holds, uses and discloses personal information, and how you can access it, correct it or complain. We handle personal information in line with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth). It covers this website, enquiries, job applications, our newsletter and the accounting, tax and advisory services we provide.
1. What we collect
- Contact details: name, email address, phone number and postal or business address.
- Information you give us about your affairs: date of birth, tax file number, employment and income details, financial records, bank account and investment details, insurance details, and details of your business, trust or super fund, as needed for the work you ask us to do.
- Identity information: identity documents and details of who owns and controls a business, where we need to verify identity (see section 4).
- Payment and billing information: invoices, billing addresses and payment details.
- Job applications: your CV, cover letter, work history, qualifications and anything else you choose to send with an application.
- Website information: IP address, device and browser details, the pages you visit and how you arrived (see section 8).
We only collect sensitive information (such as health information) where it is needed for a service you have asked for, for example a medical expense or disability-related tax matter, and with your consent.
2. How we collect it
- Directly from you: through our website forms, by email, phone, in meetings and in the documents you give us.
- From people acting for you or connected with your matter, such as your business partners, family members, financial planner or other advisers. Where we collect information about you from someone else, we take reasonable steps to make sure you know.
- From government agencies and public sources, such as the Australian Taxation Office (ATO) and ASIC, when we act for you.
- Automatically, through cookies and similar tools when you use our website.
You can browse this website without telling us who you are. We cannot usually act for you anonymously or under a pseudonym, because tax and other laws require us to identify our clients.
If we receive personal information we did not ask for and do not need, we destroy or de-identify it as soon as practicable.
3. Why we collect and use it
- To respond to your enquiry.
- To provide the services you engage us for, including tax returns, accounting, business and tax advice, structuring, SMSF administration and R&D Tax Incentive claims, and to deal with government agencies on your behalf.
- To remind you about upcoming tax and compliance deadlines.
- To send you Prime Insights, our newsletter, and invitations to events and webinars, where you have subscribed or would reasonably expect them. Every marketing email has an unsubscribe link, and you can opt out at any time. You will still receive administrative messages about work we are doing for you.
- To consider job applications.
- To bill for our services and run our business.
- To meet our legal and professional obligations.
- To run, secure and improve this website.
We do not use your information for a purpose you would not reasonably expect without your consent, unless the law requires or allows it.
4. Identity checks
Where the law requires, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 for services such as setting up companies and trusts, we verify the identity of our clients and the people who own and control them, keep records of those checks, and report to AUSTRAC.
5. Who we share it with
- Government bodies, as part of the work you engage us for or where the law requires, such as the ATO, ASIC and AusIndustry.
- Service providers that help us deliver our services, which may include business valuations, bookkeeping, R&D tax advice, auditing (including of self-managed super funds), legal advice, specialist tax advice, accounting file preparation and data entry.
- Technology providers that help us run the business, under terms that require them to protect it, including cloud email, document storage and practice software, and the website services listed in section 8.
- Chartered Accountants Australia and New Zealand (CA ANZ), where it needs access to client files to carry out a quality review.
- Other accountants and advisers you engage, with your agreement. This may include telling a new accountant whether any of our invoices are unpaid.
We do not sell, rent or trade personal information.
6. Overseas disclosure
Some of the providers we use store or process information outside Australia, in particular in the United States and New Zealand. We also use service providers in the Philippines to help with administration, bookkeeping and other functions. Cloudflare delivers this website from data centres around the world.
We take reasonable steps to make sure overseas recipients handle personal information in line with the APPs.
7. Automated decisions
We do not make decisions that significantly affect you solely or substantially by automated means. A person makes every decision about your tax affairs, the advice we give you, whether we act for you and job applications.
Our website forms run automatic checks to filter out spam and automated submissions. These checks do not decide anything about you as a client or applicant. If you have contacted us and not heard back within two business days, please email us.
8. Cookies and website services
- Google Analytics 4, loaded through Google Tag Manager, sets cookies to measure which pages are visited, how people arrive and roughly where they are. You can opt out with Google's opt-out browser add-on.
- Cloudflare hosts and protects the website. It processes technical information, such as your IP address, to deliver the site and protect it from attacks. Its Turnstile check helps block spam on our forms, and its Web Analytics counts visits without setting cookies.
- Google reCAPTCHA runs on our enquiry forms to block spam. It is covered by Google's privacy policy and terms.
- Mailchimp holds the names and email addresses of Prime Insights subscribers and sends the newsletter. It may record whether a newsletter is opened or a link is clicked.
- YouTube videos on some pages are embedded in privacy-enhanced mode, which does not set YouTube cookies until you play the video.
- Jotform hosts our income tax return questionnaire, which clients fill in before an appointment.
We do not use advertising or remarketing cookies. You can block or delete cookies in your browser settings, and the site will still work.
9. Security and how long we keep it
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, change or disclosure, and to keep it accurate, complete and up to date. We keep records for as long as we need them to provide our services and as tax, corporations and professional rules require. When we no longer need information and are not required to keep it, we destroy or de-identify it.
If a data breach is likely to cause serious harm, we will notify you and the Office of the Australian Information Commissioner (OAIC) as the Notifiable Data Breaches scheme requires.
10. Access and correction
You can ask for access to the personal information we hold about you, and ask us to correct it. We will respond within 30 days and may need to confirm your identity first. If we cannot give access or make a correction (for example, because the law prevents it or access would unreasonably affect someone else's privacy), we will tell you why in writing.
11. Complaints
If you think we have mishandled your personal information, please write to us first using the details below. We will investigate and respond within 30 days. If you are not satisfied with our response, you can complain to the OAIC:
- Website: www.oaic.gov.au
- Phone: 1300 363 992
12. Changes to this policy
We will update this policy when our practices or the law change, and show the date of the latest version at the top of this page.
13. Contact us
Privacy Officer, Prime Partners Pty Ltd
Email: info@pp.tax
Phone: 02 8378 2421
Post: PO Box 1074, North Sydney NSW 2059
