Privacy Policy

This Privacy Policy applies to Moore Australia and any Moore Australia partnership and includes any entity carrying on business in Australia that is part of the Moore Australia group of entities (MA, us, we, our). At MA, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us. This policy explains how we comply with the Australian Privacy Principles (APP) as contained in the Privacy Act 1988 (Cth) (Privacy Act) and details how we may collect, use, disclose, store, handle and protect your personal information. This policy also explains how you may gain access to, or make complaints about, the personal information we hold about you.

This Privacy Policy sits alongside our Terms and Conditions.

What is personal information?

In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act. In general terms, personal information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable from that information, or other information combined with that information.

Some types of personal information are classified as ‘sensitive information’, which are subject to additional protection under the Privacy Act. Examples of sensitive information include information about your racial or ethnic origin, political opinions, membership of a political association or a trade union, or criminal record.

Some types of personal information are credit information under the Privacy Act. Credit information is not sensitive information, but we take additional care when dealing with your credit information.

What types of personal information do we collect?

The kinds of personal information we collect about you will depend on the purpose for which the personal information is collected in our provision of audit, accounting, tax and business advisory services (our services). This can include:

• in the case of any transaction you have entered into with us (and depending on the services you or your organisation have contracted us to provide, or any services you or your organisation are interested in) – your name, residential address, email addresses, phone numbers, banking details, date of birth, investment details, payroll details, taxation details and other related accounting and financial services information;
• if you have requested to receive news about exclusive offers, promotions, or events from us – your name, mailing or street address, email address, and telephone number(s);
• if you have contacted us to make a complaint, provide feedback, submit an enquiry, request a call-back – your name, mailing or street address, email address, and telephone number(s);
• in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers; and
• in the case of our suppliers and distributors – your name, mailing or street address, email address, and telephone number(s).

We may collect sensitive information from you if you engage MA or seek employment with MA, including in relation to your criminal record, political membership, membership of a professional or trade association, and membership of a trade union. If we collect sensitive information from you, we will only use it for the purpose collected. Additionally, we may share your sensitive information with your consent to third parties, namely the Australian Taxation Office (ATO) and the Australian Securities & Investments Commission (ASIC).

We collect and use credit information for the purpose of providing our service to you. Credit information we may collect includes information relating to:

(a) identification information about the individual; or
(b) consumer credit liability information about the individual; or
(c) repayment history information about the individual; or
(d) financial hardship information about the individual; or
(e) a statement that an information request has been made in relation to the individual by a credit provider, mortgage insurer or trade insurer; or
(f) the type of consumer credit or commercial credit, and the amount of credit, sought in an application:

a. that has been made by the individual to a credit provider; and
b. in connection with which the provider has made an information request in relation to the individual; or

(g) default information about the individual; or
(h) payment information about the individual; or
(i) new arrangement information about the individual; or
(j) court proceedings information about the individual; or
(k) personal insolvency information about the individual; or
(l) publicly available information about the individual:

a. that relates to the individual’s activities in Australia or the external Territories and the individual’s credit worthiness; and

b. that is not court proceedings information about the individual or information about the individual that is entered or recorded on the National Personal Insolvency Index.

In most cases, we will collect credit information directly from you. In some instances, our service providers and related bodies corporate to whom we disclose your credit information, may be located overseas. We may disclose your information to such overseas entities for a relevant purpose described above. The countries in which these service providers and related companies are located may vary from time to time, but include the Philippines, India, and the United States of America.

We may share your credit information with your consent to third parties, namely the ATO and ASIC. We also collect technical information and general analytics, such as web browser type and browsing preferences, Internet service provider, referring/exit pages, date/time stamps, IP address, time zone and geolocation data (if applicable), some of which is collected automatically, arising from your use of our website, which is the website located at the domain moore-australia.com.au operated by us, as well as information about your usage of our website when browsing (see: “How do we collect personal information” below).

How do we collect personal information?

We collect your personal information directly from you, including when you:

• access or use our website;
• use our services (including from correspondence that you submit to us, telephone calls and face-to-face meetings with us, emails and hardcopy forms);
• sign up to receive news and exclusive offers, promotions, or events;
• enter surveys, competitions, promotions or request information or material from us;
• make inquiries about us or our services or otherwise communicate with us by email, by telephone, in person, via a website or otherwise; and
• apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties.

In limited circumstances, we may collect personal information about you from publicly available sources (such as the Internet) and from third parties (such as mutual contacts or your referees during the recruitment process if you apply for a job with us). We may also collect personal information through third parties such as through Federal Government departments, through our service providers or through promotional and marketing activities.

Whilst we will always maintain robust privacy practices, we are not responsible for the privacy practices of third parties, including ATO and ASIC, so you should review their relevant privacy policy to satisfy yourself as to how they protect and handle your personal information.

We also use the following technologies to collect technical information and general analytics:

• cookies, which are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;
• log files, which track actions occurring on our website; and
• web beacons, tags, and pixels, which are electronic files used to record information about how you browse our website.

You may disable your web browser from accepting cookies and other tracking technologies used to collect technical information and general analytics when browsing our website. If you do so, you can still access our website, but it may impact your user experience.

In addition to our cookies, certain third parties may deliver cookies to your device for a variety of reasons. For example, we sometimes use various web analytics tools that help us to understand how visitors engage with our website. Any third party links or advertising on our website may also use cookies; you may receive these cookies by clicking on the link to the third party site or advertising. We do not control the collection or use of information by these third parties, and these third party cookies are not subject to this Privacy Policy. You should contact these companies directly if you have any questions about their collection and/or use of information. When linking to any other site, you should always check the relevant website’s privacy policy before providing any personal information.

Can you choose not to disclose your personal information?

You can choose not to disclose your personal information when viewing our website. However, if you engage MA, we will be required to collect personal information as the use of your true identity is a legal requirement and it is impracticable for us to deal with you on an anonymised basis.

If we cannot collect personal information about you or if you use a pseudonym, we will not able to provide you with the information or assistance you require.

How do we use your personal information?

We use your personal information for the purposes for which it was collected, including managing our business and providing our services to you, including to:

• provide our services to our customers or to receive goods or services from third parties;
• enable the proper operation and functionality of our services;
• verify your identity (for example, if you request access to the personal information we hold about you);
• consider you for a job at MA (whether as an employee or contractor) or other relationships with us;
• communicate with you, and to address any issues or complaints that we or you may have regarding our relationship and our services;
• prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our services;
• comply with our legal obligations such as notifying you of matters that we may be required by law to do so;
• identify opportunities to improve our services and to improve our service to you;
• gain insights about you so that we can serve you better, understand your preferences and interests, personalise your experience and/or enhance services you are offered and receive;
• for direct marketing purposes (see “Direct Marketing Communications” below); and
• contact you regarding any of the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

We may also use your personal information for related purposes to which you have consented, or as otherwise permitted or required by law, such as our administrative and accounting functions, credit checks, processing your payments, obtaining product registrations and approvals, providing you with information about other services provided by us, market research, client satisfaction surveys, newsletter communications, statistical collation and website traffic analysis.

Technical information and general analytics is used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are using our website, and to improve our website and our products and services.

To whom do we disclose personal information?

We may need to disclose your personal information to third party service providers in connection with the purposes described above (see the “How do we use your personal information?” section).

This may include disclosing your personal information to the following types of third parties:

• our related companies;
• any potential third party acquirer of our business or assets, and advisors to that third party;
• our professional advisors (such as lawyers, accountants or auditors) and insurers
• our employees, contractors and third party service providers who assist us in performing our functions and activities e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, software and service providers, telecommunications providers and IT support services providers;
• organisations authorised by us to conduct promotional, research or marketing activities;
• third parties to whom you have authorised us to disclose your information (e.g. referees or account nominees); and
• any other person as required or permitted by law, including government departments and enforcement bodies including ASIC, APRA, AFSA, and the ATO.

We use third party service providers to provide us with web analytics services, such as Google Analytics. You can read more about how Google Analytics uses your personal information here.

If we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.

Direct marketing communications

We may send you direct marketing communications (either through mail, SMS or email), including any news and exclusive offers, promotions, or events.

You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the direct marketing communications.

How do we store your personal information?

Your personal information is held and stored on paper, by electronic means or both. Electronic means include, physical servers located on premises, servers maintained by cloud services providers, laptops, desktop computers, tablets and other mobile devices. We have physical, electronic and procedural safeguards in place for personal information and we take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorised access, modification and disclosure. We do not combine or link personal information we hold about you with other personal information about you from third party sources.

Does personal information leave Australia?

Our business is affiliated with other businesses located overseas. In the course of doing business with you, we may disclose some of your personal information to overseas recipients. However, we will only do so where:

• it is necessary to complete the transaction you have entered into or for us to complete the services we are providing; and
• we use our best endeavours to ensure overseas providers comply with our data handling policies and procedures under the APPs; or
• it is otherwise required by law.

Currently, we (and our network entities) may disclose personal information to overseas recipients located in India, Philippines, USA, South Africa and Sri Lanka.

Our software providers may be located overseas. While doing business with you, we may disclose some of your personal information to overseas software providers including where –

• it is necessary to complete the transaction for which you have engaged us; or
• for us to complete the services we are providing.

Where we transfer your personal information overseas to software providers, we will use our best endeavours to ensure that the overseas recipient handles your personal information in a manner that is compliant with the APPs, or equivalent provisions, e.g. the EU General Data Protection Regulation (GDPR).

How do we protect your personal information?

We implement reasonable measures to protect and safeguard your personal information from misuse, loss, theft and unauthorised access, modification or disclosure.

We maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Please be aware that you transmit your personal information to us online at your own risk and are encouraged to exercise care in sending personal information via the internet. Please notify us immediately if you know or reasonably suspect that your personal information has been subject to any data breach, breach of security or other unauthorised activity.

How long do we keep your personal information?

Generally, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy) unless a longer retention period is required by law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security.

When personal information is no longer required, we will take reasonable steps to delete the personal information from our systems or de-identify the personal information.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us at [email protected], or the Privacy Officer of the MA entity with which you engage. We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us at [email protected], or the Privacy Officer of the MA entity with which you engage. Where we agree that the information needs to be corrected, we will update it. If we do not agree, you can request that we make a record of your correction request with the relevant information.

Questions or complaints?

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your personal information, please contact us at:

Moore Australia (SA/NT)
Level 2, 180 Flinders Street
Adelaide SA 5000
Phone: 08 8224 3305
Email: privacyofficerSA@ moore-australia.com.au

Moore Australia (VIC)
Level 44, 600 Bourke Street
Melbourne VIC 3000
Phone: 03 9608 0194
Email: [email protected]

Moore Australia (WA)
Level 15 Exchange Tower
2 The Esplanade
Perth WA 6000
Phone: 08 9225 5355
Email: privacyofficerWA@ moore-australia.com.au

Moore Australia (QLD/NNSW)
Level 12, 10 Eagle Street
Brisbane Qld 4000
Phone: 07 3340 3800
Email: [email protected]

National
Level 44, 600 Bourke Street
Melbourne VIC 3000
Phone: 0427 177 119
Email: [email protected]

We are committed to resolving any complaints reasonably and to ensuring that we are doing the right thing by our customers. We will make all reasonable inquiries and your complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.

If you feel that your complaint is not handled in a satisfactory manner or have further concerns about the way we handle your personal information, under the Privacy Act, you may refer your complaint to the Office of the Australian Information Commissioner, the details of which are set out below:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Website: www.oaic.gov.au
Email: [email protected]

Privacy Policy Updates

This Privacy Policy is not a static document. We may, from time to time, make changes and updates to this Privacy Policy to keep up-to-date with legal requirements and the way we operate our business. The most current and up to date MA Privacy Policy will always appear on our website. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes. We suggest that you check back regularly. If we make significant changes to our Privacy Policy, we will seek to inform you by notice on our website or by email.