Kinds of Information collected
2.1. Aspiron Consulting Group may collect both personal and sensitive information about 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 (expressed or implied) and if the information is reasonably necessary for us to provide our services.
Collection of Personal Information
3.1. Aspiron Consulting Group 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:
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.
3.7. Where you provide us with personal information of third parties (for example, your spouse, children, business partners, affiliated entities, employees, contractors, customers, clients, associates) you warrant to us that the relevant individuals (or entities) 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.
Use of Personal Information
4.1. How we use your personal information varies based on the services we provide. 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 law.
4.2. Generally, we may use your personal information:
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).
Disclosure of Personal Information
5.1. We may disclose your personal information:
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, subsidiary or another Aspiron Consulting Group associate (based either domestically or internationally), which is necessary to deliver your requested items or services to you.
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 Aspiron Consulting Group is acquired or merged with another entity.
5.5. Aspiron Consulting Group 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 or withdrawn. 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 Aspiron Consulting Group 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.
5.7. Aspiron Consulting Group routinely contracts with a range of third party providers for the provision of services to our practice. Some of these third party providers may hold or transfer your personal information. Third party providers that are currently engaged / used by us whom we believe may hold or transfer your personal information include:
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 with your consent.
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, (b) medical history, (c) ethnicity, (d) sexual orientation, (e) political affiliations etc.
6.3. Aspiron Consulting Group will not collect your tax file number unless you, or your agent have provided such information to us directly. You may revoke your consent in writing for us to use your tax file number at any time if you are no longer a client of Aspiron Consulting Group, in which case, we will only retain your tax file number for any purpose required by law or under any contract with our associates.
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, or (c) as required by law. We will not disclose sensitive information to other members or associates of Aspiron Consulting Group without your prior written consent.
6.5. Information regarding your tax file number will only be disclosed to you personally or as authorised / instructed by you, 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).
7.1. We may use or disclose your personal information for direct marketing purposes, being:
7.2. If you have consented to receive information from us or have initiated communication with us, your e-mail address and other information that you provide may be recorded. Aspiron Consulting Group may, from time to time, use your personal information, such as your address and contact details, to provide you with information updates, marketing updates or information about the services that we offer.
7.3. 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 us at the contact details in paragraph 14 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.
Use of pseudonyms and unique identifiers
8.1. 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.
8.2. In certain circumstances, we may deem it necessary to assign you a unique identifier to allow us to carry out our functions efficiently. A unique identifier will only be assigned to individuals whose identity has been clearly established.
9.2. Your information may be held in our servers located in Australia or overseas. Your information may also be accessible to our contractors, agents and service providers located in Australia or overseas with external access.
9.3. You agree to such cross-border transfers of your personal information.
9.4. Aspiron Consulting Group also uses a number of software applications and tools for storing and sharing your information to associates, third party service providers, contractors or agents. This can include, but is not limited to, the use of search engines, electronic file transfer systems, cloud storage and online payment facilities.
Collection of Credit Information
We may provide credit to you from time to time (for example, by giving you time to pay our account for services) and this may involve the collection of credit information. We may collect credit information about you (a) directly from you or from persons acting on your behalf (including via application forms submitted by you or on your behalf), and (b) from third parties, including credit reporting bodies and other credit providers, to assist us in determining whether we will provide credit to you.
Use and disclosure of Credit Information
11.1. With your express consent, as required by law or court order and otherwise in accordance with Part IIIA of the Privacy Act 1988 (Cth), we may use or disclose the credit information we have collected to:
11.2. We may use or disclose credit information we have collected about you for the following purposes:
11.3. We may also use credit information we hold about you for internal management purposes and to respond to queries or complaints about our treatment of your credit information. We may disclose your credit information to credit reporting bodies if you fail to make payments to us or if you commit a serious credit infringement.
11.4. The credit reporting policies for such credit reporting bodies will be available on their websites. You have the right to contact any credit reporting bodies to whom we disclose your credit information and request that they do not (a) use your credit information for pre-screening purposes to determine your eligibility to receive direct marketing from credit providers, and (b) use or disclose your credit information if you have been or are likely to be a victim of fraud.
11.5. We will not collect credit information by unlawful means or means that are unfair or intrude to an unreasonable extent upon your personal affairs.
Holding and security of your Personal Information and Credit Information
12.1. Aspiron Consulting Group endeavours 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.
12.2. 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.
12.3. 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:
12.4. 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.
Accessing and correcting Personal Information and Credit Information
13.1. We rely on the accuracy of the personal information and credit information you provide to us.
13.2. We may take steps to correct information held if we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
13.4. 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.
13.5. 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.
How to access and correct your Personal Information
14.1. You may access and / or request that your personal information be edited or corrected by contacting a director of Aspiron Consulting Group
14.2. 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.
Third party websites
15.1. 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.
Changes to policy and complaints
16.1. 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:
Privacy Compliance Officer
Aspiron Consulting Group
Suite 516, Level 5, 100 Victoria Parade
EAST MELBOURNE VIC 3002
16.2. Aspiron Consulting Group will, within fourteen days, respond to you and attempt to resolve with you your issues as they pertain to your personal information.
16.3. 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:
Updating this Policy