SBB Partners Privacy Policy
1. Privacy Commitment
SBB Partners Pty Ltd (We, Us or Our) recognise the importance of protecting your privacy and the personal information in our care. We have created this Privacy Policy in order to demonstrate our firm commitment to your privacy.
This Privacy Policy represents how we manage your personal information in accordance with the Privacy Act 1988 (Cth). Our Privacy Policy seeks to safeguard the privacy of your personal information in accordance with the Australian Privacy Principles (APPs). This Privacy Policy sets out the kind of information we hold and how we collect, hold, use and disclose that information (including personal information and sensitive information). We may also agree with you from time to time other uses or disclosures of your personal information. We will not deal with your personal information other than in accordance with this policy unless we notify you first and obtain your consent.
This Privacy Policy also includes a link to our Credit Information Management Policy which sets out how we collect, hold, use and disclose Credit Information to comply with our credit reporting obligations under the Acts, the Credit Reporting Code registered under section 26S(1) of the Privacy Act 1988 (Cth).
In addition to this Privacy Policy, we may also have specific and additional privacy provisions that apply to certain activities or promotions. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions provided to you will apply.
By using our website, applications and services, or otherwise providing us with your information, you consent to our collecting, holding, using and disclosing your personal information as described in this Privacy Policy or as otherwise agreed with you.
This Privacy Policy may be amended or revised at any time. The revised Policy will take effect when it is uploaded on our Website. This Privacy Policy represents the latest version of the Privacy Policy as at 1 October 2023.
2. Kinds of Information collected
2.1. We may collect both personal and sensitive information from you.
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 We will collect your personal information directly from you, online and from third parties (including our affiliates). You consent to us collecting your personal information from you, online and from third parties (including our affiliates). This consent is an ongoing consent until you with withdraw that consent by notice to us in writing.
3.2 We may collect your information to provide services to you and to ensure that you receive the best possible service, to market to you (including opportunities from our affiliates that we identify may be of interest to you), to provide to our affiliates to ensure that our affiliates can provide services to you and to ensure that you receive the best possible service from our affiliates. If we do not collect personal information about you this will affect our ability to provide services to you, our ability to market to you about opportunities that we think will benefit you and our affiliates’ ability to provide services to you.
3.3 Sources we will collect personal information about you include:
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);
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 (including our affiliates);
from external sources where the information is publicly and readily available;
from our affiliates who hold personal information about you to help us and our affiliates provide services to you;
from third parties where it is more convenient or otherwise unreasonable or impractical to collect such personal information from you directly (including our affiliates); and
from third parties that are government organisations (such as the Australian Securities and Investments Commission or the Australian Taxation Office).
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 and taxation 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 services you require from us.
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 third party has consented to you disclosing their personal information to us.
3.8 We endeavour not to collect personal information by unlawful means or means that are unfair.
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 Act.
4.2 Generally, the reason we may use your personal information include:
as necessary for us or our affiliates 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 us or our affiliates agreeing to provide services to you;
to send you marketing communications from us or from our affiliates;
for customer relationship management purposes and to supply to you the services which you have requested or we think are relevant to you (including services that are offered by our affiliates) having regard to our knowledge of you and discussions with you;
to send you statements and invoices and collect payments from you;
for recruitment purposes;
to analyse client needs and improve the services we and our affiliates 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, including recommending to you or helping to facilitate the provision of services to you by our affiliates.
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, facsimile 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 see paragraphs 7 and 13 of this Privacy Policy.
5. Disclosure of Personal Information
5.1 We may disclose your personal information, and you consent to the disclosure of your personal information:
to our contractors, agents and service providers (for example, information technology contractors, debt collection agencies, event managers and recruitment and human resources consultants) 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 our affiliates for the purpose of those our affiliates providing you with information about their services and promotions and so our affiliates can provide services to you;
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;
in connection with any sale of us or any affiliate of ours; and
to our professional advisers but only so they can advise us in respect of the same.
5.2 Unless you have otherwise consented, 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 of ours, which is necessary to deliver your requested items, to market to you or provide services to you. We will endeavour to make sure that our disclosure to our affiliates only occurs where the affiliate has a privacy policy which complies with the APPs.
5.3 We 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 we or our affiliates are acquired or merged with another entity.
5.5 We will attempt to ensure that we do not disclose your personal information to a third party (including our affiliates) where consent for such disclosure has not been given.
5.6 Please note that if at any time we are 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. Collection, use and disclosure of Sensitive Information
6.1 We will only collect sensitive information from you directly as reasonably necessary to provide services to you and so that our affiliates can provide service to you or otherwise as permitted by the Act. You consent to our using of your sensitive information for this purpose.
6.2 As an example, and without limiting the types of sensitive information we collect, we may collect the following sensitive information (a) tax file number and (b) medical history.
6.3 We will only collect your tax file number for a purpose permitted by law and otherwise for us or an affiliate to provide services to you. You are not required to provide us or our affiliates with your tax file number, however, if you do not provide us with your tax file number, we or our affiliates may not be able to provide services to you.
6.4 Subject to paragraph 6.5, 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, which may include ensuring that us or our affiliates can provide services to you or (c) as required by law.
6.5 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).
7. Direct marketing
7.1 We may use or disclose your personal information for direct marketing purposes, and you consent to us use or disclose your personal information for direct marketing purposes, being:
to promote our services and the services of our affiliates and provide you with information and marketing materials about other services provided by us and our affiliates that may be of interest to you;
to provide information relevant to you, your type of business or other area of expertise or interest; and
to provide you with the opportunity to attend complimentary reviews by our affiliates, seminars, conferences or other events that may be of interest to you.
7.2 If you subscribe to receive information from our Website, then your e-mail address and other information that you provide will be recorded. We 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 and our affiliates offer.
7.3 If you do not wish to receive Direct Marketing communications from us or our affiliates, you can ‘opt out’ by clicking the ‘Unsubscribe’ link in our or our affiliates emails or other electronic communications, or sending an email to us at the contact details in paragraph 13 below 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.
8. Use of pseudonyms and unique identifiers
In general, you are not required to provide personal information to us. Where reasonably practicable, you may have the option of not identifying yourself, or of using a pseudonym, when dealing with us in relation to a particular matter. However, if you wish to receive information about our services, events, industry updates or to apply for employment, it may not be practical for you to use a pseudonym or otherwise not identify yourself and we may require you to provide certain personal information or Credit Information. If you do not provide some or all of the personal information or Credit Information requested, we may not be able to provide you with some or all of the services you request.
9. Cross-border disclosure
9.1 Personal, sensitive and Credit Information which we collect may be stored and processed in and transferred between the countries abroad in which we have service providers. This disclosure enables the use of your information in accordance with this Privacy Policy.
9.2 Your information may be held in our servers located in Australia. Your information may also be accessible to our contractors, agents and service providers located in America, the United Kingdom and the Philippines and where our contractors, agents and service providers utilise offshore providers, to any jurisdiction that they may use.
9.3 You agree to such cross-border transfers of your personal information.
9.4 We also use a number of different software and tools for storing and sharing your information to our affiliates, third party service providers (including our affiliates), contractors or agents. This can include, but is not limited to, the use of internal search engines, electronic file transfer systems and online payment facilities.
10. Collection of Credit Information and use and disclosure of Credit Information
Please refer to our Credit Information Management Policy as to how we will collect, use and disclosure your Credit Information.
11. Holding and security of your Personal Information and Credit Information
11.1 We endeavour to take all reasonable steps to keep secure any personal or sensitive information which we hold about you, and to keep this information accurate and up to date.
11.2 However, as the internet is not a secure environment, any information that you send to us via that method is sent at your own risk.
11.3 The security and privacy of your personal information is our priority. We may store your personal information and Credit Information in hard copy or electronic format. We take reasonable steps to:
ensure that any personal information or Credit Information we hold or disclose about you is up to date, complete and correct; and
protect your personal information and Credit Information from misuse, interference, loss, and unauthorised access, modification and disclosure using electronic and physical security measures such as:
(a) we lock our premises and have reception desks that are staffed to minimise the risk of unauthorised access to our premises;
(b) placing passwords and varying access levels on databases to limit access and protect electronic information; and
(c) the use of firewalls, encryption, passwords and digital certificates.
11.4 We will destroy or delete any of your personal information or Credit Information which we no longer need to retain noting that we are required by law to retain certain information for a number of years after we have ceased providing the services. If you email us any information (including personal information or Credit Information), it is sent at your own risk as it may not necessarily be secure against interception.
12. Accessing and correcting Personal Information and Credit Information
12.1. We rely on the accuracy of the personal information and Credit Information you provide to us.
12.2. We may take steps to correct information held if we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
12.3. On your request, except to the extent that we are lawfully able to refuse such a request, we will provide you with access to personal information and Credit Information that we hold about you. All requests about the personal information or Credit Information that we hold should be made by email or in writing to us (see paragraph 13 of this Privacy Policy for our contact details). We will try to respond to your request within a reasonable period.
12.4 If you satisfy us that personal information or Credit Information that we hold about you is misleading, inaccurate, out of date or incomplete, except to the extent that we are lawfully able to refuse such a request, we will correct the personal information and Credit Information that we hold about you. If it is reasonable and practicable to do so, we will give you access to your personal information and Credit Information in the manner that you request. We do not generally charge for providing such access but may do so in certain circumstances.
12.5 In the event that we deny access to or refuse to correct your personal information or Credit Information that we hold, we will provide you with written reasons and the mechanisms available to complain about such refusal.
13. How to access and correct your Personal Information
13.1 You may access and/or request that your personal information be edited or corrected by contacting our local office or by writing to one of the following:
Email:
In writing:
The Directors
SBB Partners, Level 1, 122 Wood Street Mackay Qld 4740
13.2 By informing us of any changes to your personal information, you allow us to ensure that your information is accurate, up-to-date and complete.
13.3. There are no fees associated with making a request to access or correct your information. We may, however, charge a reasonable fee for processing the request, to account for locating the information and supplying it to you.
14. Third party websites
14.1 When you leave our Website, you will be going to websites that are beyond our control. Our Policy does not apply to third party websites (including the websites of our affiliates).
14.2. We confirm that this Privacy Policy only governs the handling of your personal information by us. We encourage you to read the privacy policies of any third party websites (including the websites of our affiliates) before disclosing or consenting to the disclosure by us of any personal information to those entities.
15. Changes to policy and complaints
15.1 If you believe that we have breached our privacy or credit reporting obligations under the Act, or you are unsatisfied with the manner in which we have dealt with your personal information, you may make a complaint by emailing or writing to us at:
Email:
In writing:
The Directors
SBB Partners, Level 1, 122 Wood Street Mackay Qld 4740
15.2 We will use our best endeavours to, within fourteen days, respond to you and attempt to resolve with you your issues as they pertain to your personal information.
15.3 If you are still unsatisfied, you may wish to direct your complaint to the Office of the Australian Information Commission at http://www.oaic.gov.au/ or alternatively:
Phone: 1300 363 992
In writing: The Office of the Australian Information Commissioner
GPO Box 5288, Sydney NSW 2001
16. Updating this Policy
We may update this Privacy Policy from time to time by positing a new version on our website. Please check this page to ensure that you are familiar with any changes that may have arisen.
17. Meanings
In this Privacy Policy:
17.1. Act mean the Privacy Act 1988 (Cth);
17.2. Affiliates means any entity in which we (1) hold any interest (whether directly or indirectly) or (2) have at least one common director or (3) have a relationship with that is used for the purpose of providing better services to our clients.
17.3. Credit Information includes identification information (for example, name, date of birth, driver’s licence number, current and recent addresses and employment details), historical details of credit (including type and amount of credit sought or obtained) and repayment history, information about applications for credit, information about defaults and payment arrangements, details of insolvency proceedings, bankruptcy agreements, judgements and arrangements with creditors, information relating to activities and credit worthiness in Australia, information recorded on the National Personal Insolvency Index and opinions of credit providers regarding serious credit infringements;
17.4. Credit Information Management Policy means our Credit Information Management Policy as amended from time to time and available at https://www.sbbpartners.com.au/credit-information-management-policy.
17.5. Personal Information means information (including an opinion) about an individual whose identity is apparent or can reasonably be ascertained from the information whether true or not and whether or not recorded in a material form;
17.6. Sensitive Information has the meaning given by the Act and includes Personal Information which relates to an individual’s racial or ethnic origins, religious beliefs or affiliations, trade association, trade union membership, sexual orientation, criminal record and information as to an individual’s health or biometric information.
17.7. Website means all of the pages located on the website you are currently viewing, being https://www.sbbpartners.com.au/ which relate to us.
Version 1.3: 1 October 2023