Privacy Policy Statement

The BBB Partners group is a provider of financial services.

The BBB Partners group incorporates a number of entities including BBB Partners Pty Ltd and BBB Finance Pty Ltd. The main services provided by the group are Accounting, Taxation, Planning and Structuring (BBB Partners), and Financial Planning (BBB Financial Services) and Credit Assistance (BBB Finance).

This Privacy Statement sets out the BBB Partners group’s policy with respect to the way in which we collect, use and disclose information about you, including through our website at www.bbbpartners.com.au. The BBB Partners group adopts and is bound by the Australian Privacy Principles contained in Privacy Act 1988 (Cth) (“the Act”).

We understand and appreciate that you are concerned about privacy, particularly in relation to the use and disclosure of Personal Information. We are committed to providing a high level of privacy in relation to all Personal Information that is collected by us.

This Privacy Policy applies to the BBB Partners group but not to other companies or organisations or websites to which the BBB Partners group is linked. For the sake of clarity, this Privacy Policy covers Personal Information collected and used by us in relation to any of the following:

our clients or prospective clients;
our suppliers or prospective suppliers; and
our employees and independent contractors or any person who applies to become an employee or independent contractor.

An act done or practice engaged in us as an employer that is directly related to an ’employee record’ is exempt from the Privacy Act. An ’employee record’ means a record of personal information relating to the employment of our employees. It includes health information and personal information relating to:

the engagement, training, disciplining,
resignation or termination of employment of an employee;
the terms and conditions of employment of an employee;
the employee’s performance or conduct;
hours of employment, salary or wages;
personal and emergency contact details;
the employee’s membership of a professional or trade association or trade union membership;
the employee’s recreation, long service, sick, maternity, paternity or other leave; and the employee’s taxation, banking or superannuation affairs.

Having said that, we treat the Personal Information of our employees with absolute confidentiality and strict controls are exercised over who has access to such records. We will not disclose your employee records to any third party other than as permitted by law or this privacy policy, without your prior consent.

Your Consent

You consent to your Personal Information being used in accordance with this Privacy Policy by any one or more of the following:

making enquiries about or engaging us to provide our goods or services;
attending our offices;
providing us with your contact details;
by way of written agreement with us;
visiting our website or making an online enquiry;
by visiting any website or social media site established by us, including but not limited to Facebook, Twitter, Pinterest, Instagram, Google+, Youtube and Linked in (“Social Media Sites”); and
participating in any activity on a Social Media Site including but not limited to entering competitions, subscribing to our blog, posting, pinning, or uploading any material on any Social Media Site, following, liking and/or commenting on us or anything on any Social Media Site (“Social Media Activity”).

What Personal Information do we collect from you?

For the purposes of this Privacy Policy, “Personal Information” is information or an opinion about you as an identified individual or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not it is recorded in a material form.

The type of Personal Information collected by us may differ, depending on whether you are or would like to become a client, supplier or employee or independent contractor. Generally, the type of Personal Information collected by us includes your name, address, mobile and telephone numbers, facsimile number and email address, date of birth, tax file numbers and financial information incidental to the services or products that we provide to you.

We may also require details of your company’s ABN and/or ACN, financial information including bank account and credit card details, your employer and occupation details.

Via Social media Sites, we may be able to obtain other information about you which may itself constitute Personal Information or which, when combined with other information, is capable of identifying you, including photos, videos and other information that you include on our Social Media Sites or sites linked to our Social Media Sites (“Other Sites”). The level of information to which we have access may depend on your privacy settings on such Other Sites.

In some circumstances, you may deal with us anonymously or using a pseudonym. However, in most circumstances it is impracticable to do so because if you do not provide us with the Personal Information that we require or if you provide it in a way that does not identify you, we are likely to be unable to carry out the services or supply the goods requested by you.

How do we collect your Personal Information?

We collect Personal Information in a number of ways, including:

when you provide us with such information including via telephone, email, business cards, application forms, customer satisfaction surveys, contracts or any other document provided by you to us;
when you enquire about or engage us to provide our goods or services;
from third parties such as credit reporting agencies;
from publicly available sources of information;
through analysis of the Social Media sites conducted by us or by third parties on our behalf;
any other collection of or incidental or directly or indirectly related to the goods or services we may be able to provide to you, on behalf of ourselves or others; and
from our own records.

Through our website we can obtain Personal Information if you send such information in an email or when you complete an online enquiry. When you look at our websites, we may make a record of your visit. The following information may be logged for statistical purposes and for the purposes of marketing and advertising to you:

your internet protocol address;
the date and time of your visit to our site;
the pages that you have accessed and the documents downloaded; and
the type of browser you were using.

Any such statistical analysis does not identify you.

Tracking technologies such as cookies may be used on our website to recognise a user’s browser each time that user visits our site and to track which pages the user visits whilst on our site and also to send advertisements to your internet protocol address which are relevant to the pages you have visited. Cookies are pieces of information that a website transfers to a computer’s hard drive for record keeping purposes. Most web browsers are set to accept tracking technologies such as cookies. These tracking technologies do not personally identify the user. If you do not wish to receive any cookies you may set your browser to refuse them. However, your use of our website may be affected.

How do we use your Personal Information?

Any Personal Information that we collect will be used by us so that we can provide you with the services that you have requested or otherwise to enable us to carry out our functions as professional accounting and financial service providers, including:

responding to your enquiries and feedback regarding our business, our products and services;
monitoring the performance of our business;
marketing including email marketing, promotional and educative activities including to advise you about products, services, opportunities and relevant issues that may be of interest to you;
enforcing the terms and conditions of our engagement with you;
conducting appropriate credit checks;
ensuring compliance with statutory obligations.

Identifiers issued by Government agencies, such as Tax File Numbers, will not be used by us internally as a basis of identity.

Direct Marketing

We regularly forward to you general information and newsletters, including via email, so that you are kept updated in relation to various accounting and taxation issues and services we provide. In each email or marketing newsletter that you receive from us, we will attach simple instructions on how you can immediately unsubscribe from our mailing list. In any event, you can opt out from receiving promotional material by emailing our Privacy Officer and asking to be removed from the mailing list. Our contact details are set out below. There is no fee due to us for any such deletion.

How is your Personal Information disclosed by BBB Partners?

We do not and will not rent, sell or otherwise disclose your Personal Information to any other company or organisation, without your prior consent, where that consent is required by law.

You do, however, consent to our use and disclosure of your Personal Information in the following ways and for the following purposes:

between our related entities;
of or incidental providing our products and services to you;
to promoting and marketing our products and services to you, including but not limited to advising you about new products that we believe may be of interest to you;
to financiers or mortgage brokers, subject to receiving your prior written consent;
to third parties to whom we outsource any of our functions, including payroll, database management and client satisfaction surveys from time to time;
of or incidental to a sale of all or part of our business to a third party; and
as required by law.

Disclosure of your Personal Information via Social Media Sites

By engaging in any Social Media Activity on our Social Media Sites, you agree to and are subject to the terms and conditions of such Social Media Sites. Any Personal Information pinned or posted or uploaded by you onto Social Media Sites can be disclosed in accordance with the terms and conditions and privacy policies of such Social Media Sites.

Generally, photos and other material pinned or posted to Social Media Sites will be able to be viewed by the general public, in Australia and internationally. Such photos and other material may be re-pinned and re-posted by others indefinitely and will be visible by anyone visiting the locations to which the photos or other material have been re-pinned. You may be able to remove the photos or other material that you have pinned or posted from the location at which you pinned or posted it. However, any material that has been re-pinned will be out of our control and neither you nor we will be able to remove it from any re-pinned location. We are not responsible for any material that has been re-pinned or re-posted.

We reserve the right to remove any photos, comments or other material that is in any way inappropriate or offensive (in our opinion) from our Social Media Sites.

Cross Border Disclosure

Your personal information may be disclosed to other services providers that may include:

Financial product providers
Financial planning software providers
Administration and paraplanning service providers
IT service providers

The sharing of data is done only when required to facilitate the efficient and effective provision of financial services. In the event that data is shared, both with onshore or offshore providers in the Philippines, it is only done with adherence to the highest levels of data security and with those who adhere to the highest security rating of ISO-27001 and adherence to the Australian Privacy Act (1988).

If you consent to disclosure of some of your Personal Information in this manner, we are not required to take steps as are reasonable in the circumstances to ensure that such organisations do not breach the APPs in relation to the disclosed information. Having been informed of the possibility that such disclosure may occur, you consent to that disclosure by undertaking or continuing to undertake the type of activities indicating your consent, as specified above.

Security

We are committed to ensuring the security of your Personal Information and we will take all reasonable steps to protect this Information from misuse, interference, loss, unauthorised access, modification or disclosure, including:

ensuring the physical security of our premises and databases/records;
restricting access to personnel who need that information in order for us to be able to provide our products and services;
technological measures, such as computer passwords, data back-up, anti-virus software and firewalls; and
storage of some information through a reputable external service providers which may include cloud service providers.

Please note that our website does not provide systems for secure transmission of Personal Information across the internet, except where otherwise indicated. You should be aware that there are inherent risks in transmitting Personal Information via the internet.

Our website contains links to other websites. We have no control over the privacy practices employed at other websites and we accept no responsibility for Personal Information provided via unsecured websites.

We cannot provide any guarantee with respect to the security of your Personal Information and we will not be liable for any breach of security or unintended loss or disclosure of information due to the website being linked to the Internet.

How to check or change your details

Our Privacy Officer will ensure that your Personal Information is accurate, complete and up to date and relevant to the purposes for which we are able to use your Personal Information.

If you wish to view the Personal Information we hold about you, please send your request to the Privacy Officer by email, mail or fax using the contact details at the end of this Privacy Policy. A fee may apply for such access. If we deny your request for access, we will let you know why.

If you wish to amend your Personal Information because it is inaccurate, out of date, incomplete, irrelevant or misleading, or if you wish your Personal Information to be deleted, please contact our Privacy Officer.

Complaints

If you believe that we have not complied with our obligations pursuant to the Act, or have a complaint about the use or disclosure of your Personal Information by us, please contact our Privacy Officer.

Our Privacy Officer is responsible for liaising with you to ensure that the issues you have raised are fully examined and that your complaint is handled in accordance with this process. We will treat the process, and all the details of your complaint, in strict confidence. If we need to discuss any issues arising from your complaint with a third party we will obtain your consent first.

We will always try to give you a fair opportunity to explain your case. You should make your initial complaint as clear as possible. We may want to meet you in person to discuss your concerns and try to find a satisfactory solution.

What action will we take in response to your complaint?

We will endeavour to resolve your complaint as soon as possible, but the length of time will depend on the nature and complexity of the issues you have raised. You will receive acknowledgement of receipt of the complaint from us within five business days. We will give you an estimate of how long it may take us to deal with the matter but we will endeavour to finalise the matter within 30 days.

After assessing your complaint, we will decide what action (if any) we should take in response.

Some of the things that we decide to do include:

take steps to rectify the problem or issue you have raised;
provide you with additional information or advice so you can understand what happened and how we have dealt with it; and/or
Take steps to change our policies or procedures if your complaint identifies a problem in the way we are doing things.

If we have not resolved a complaint about our collection, use or disclosure of your Personal Information to your satisfaction, you may wish to escalate the matter to the Privacy Commissioner via an online privacy complaint form which can be found at: http://www.oaic.gov.au/privacy/making-a-privacy-complaint.

If you have a complaint about the professional advice you have been given by us and we have not been able to resolve the matter to your satisfaction, you may wish to contact Financial Ombudsman Service to commence external dispute resolution proceedings with us. Information can be found at: http://www.fos.org.au/resolving-disputes/before-you-lodge-a-dispute/

Changes to our Privacy Policy

From time to time we may decide to amend or update this Privacy Policy. When this occurs, we will post the new version of the Privacy Policy on our website. We encourage you to review this Privacy Policy from time to time so that you remain informed as to how we are protecting your Personal Information.

Privacy Officer Details

BBB Partners
8th Floor
60 Albert Road
South Melbourne Vic 3205

Privacy Officer: Mr Andrew Holdsworth
Telephone No: 03 9693 7777
Facsimile No: 03 9693 7733
Email: aholdsworth@bbbpartners.com.au

Privacy Collection Notice: Webpage – Contact Us

BBB Partners Pty Ltd and its associated companies request certain personal information which may include your name, phone number, email address and areas of interest in order to assist you with your enquiry. Without such personal information, we may be unable to assist you with your enquiry.

Your name and email address may be added to our databases. This may involve disclosure to third parties who manage our databases and email marketing. Your information may be added to our email marketing list in order to provide you with other information that may be of interest to you.

We may disclose your Personal Information to overseas recipients. This may also occur as an unintended consequence of using software or email marketing programs which are hosted or housed overseas, such as Mail Chimp or Survey Monkey in USA. You will be able to opt-out any time from our email marketing program.

Our privacy policy contains information about how you may access the personal information we hold about you and information about how to seek correction of such information, if necessary.

Our privacy policy also contains information about how you may complain about an alleged breach of the Australian Privacy Principles, and how we will deal with such a complaint.

Our privacy policy can be viewed without charge at www.bbbpartners.com.au/privacy. Alternatively, please contact our Privacy Officer, Andrew Holdsworth, on (03) 9693 7777 and we will send or email you a free copy.