Your Right to Privacy

DK PARTNERS Accountants & Business Advisers respects your privacy and is committed to
treating the personal information we collect in accordance with the Australian Privacy Principles
in the Privacy Act 1988 (Cth) (Privacy Act) and the subsequent 2012 and 2016 amendments
(Mandatory Data Breach Notification), The General Data Protection Regulation (GDPR) and the
APES 110 Code of Ethics for Professional Accountants.

This policy outlines the obligations DK PARTNERS Accountants & Business Advisers has in
managing the personal information we hold about our clients, potential clients, contractors and
others. This includes information such as your name, email address, identification number, or
any other type of information that can reasonably identify an individual, either directly or
indirectly. This policy is not intended to, nor can it, replace the provisions Acts themselves.
The Privacy Policy does not apply to acts or practices that are directly related to employee
records of current or former employees.

Personal information we collect

As a provider of accounting and advisory services it may be necessary, and in some cases be a
legislative and regulatory requirement, for us to collect and hold detailed personal information.
In general, the main types of personal information we collect and hold includes (but is not limited
to):

■ Names
■ Contact details
■ Gender
■ Dates of Birth
■ Employment details and employment history
■ Tax File Numbers
■ Details of your financial circumstances, including bank account details, your assets and
liabilities (both actual and potential), income, expenditure, insurance cover and superannuation
■ Health information (for some types of insurance cover)

We will not collect any personal information about you except when you have knowingly provided
that information to us or authorised a third party to provide that information to us.

How we use your personal information

DK PARTNERS Accountants & Business Advisers acknowledge that your personal information is
highly confidential and to this end the information collected by us will only be used for the
purpose in which it was collected unless you have consented to it being used for another
purpose or if the secondary purpose for which the information is being used or disclosed is
related to the primary purpose and you would reasonably expect such use or disclosure. This
may include to:

■ provide you with products and services during the usual course of our business activities;
■ administer our business activities (including invoicing, account management and recruitment);
■ manage, research and develop our products and services;
■ provide you with information about our products and services, invite you to events or distribute
articles or publications;
■ communicate with you by a variety of measures including, but not limited to, by telephone,
email, SMS or mail; and
■ investigate any complaints.

You have a right not to provide information that can identify you. If, however, you withhold your
personal information, it may not be possible for us to provide you with our products and services,
or alternatively, may affect the adequacy or appropriateness of advice or services provided.
If there is a change of control in our business or a sale or transfer of business assets, we reserve
the right to transfer to the extent permissible at law our user databases, together with any
personal information and non-personal information contained in those databases.

How we collect your personal information

DK PARTNERS Accountants & Business Advisers may collect personal information from you in a
variety of ways, including when you interact with us electronically or in person. This includes, but
is not limited to, when you provide feedback, when you provide information about your personal
or business affairs, change your content or email preference(s), respond to surveys and/or
promotions, provide financial or credit card information, or communicate with your advisor.
We may also receive personal information from third parties and where this is the case, we will
protect it as set out in this Privacy Policy. You have a right to refuse us authorisation to collect
information from a third party.

Sometimes you may provide us with someone else’s personal information, e.g. other members of
your family group. You must not provide that information to us unless you have their consent to
do so. You should also take reasonable steps to inform them of the matters set out in this Privacy
Policy.

Sensitive information

Some of the personal information is “sensitive information” as defined by the Privacy Act.
Sensitive information includes health information, information about your race, ethnic origin,
political opinion, religion, trade union or other professional or trade association membership,
sexual preference(s) and criminal record. We will only collect this information as permitted under
the Privacy Act.

Sensitive information will be used and disclosed only for the purpose for which it was provided or
a directly related secondary purpose, unless you agree otherwise, or where certain other limited
circumstances apply (e.g. where required by law).

Unsolicited personal information

There may be times when we receive personal information that we do not solicit. If this occurs,
we will determine if you have given your consent and the information is necessary for us to
provide our services, or whether the collection is required or authorised by or under an Australian
law or a court/tribunal order. If it is, then the information will be dealt with in accordance with the
Australian Privacy Principles as if the information had been solicited.

If it is determined that you have not consented to the information being disclosed to us and that
there is no requirement at law for us to collect that information, we will destroy or de-identify the
information as soon as practicable, provided it is lawful and reasonable to do so.

Disclosure of personal information

In providing our services we may need to disclose personal information to a third party. This will
be done to the extent that it is permitted by law and set out in this Policy.

Examples of the types of third parties we may disclose personal information to include:

■ member organisations of the DK PARTNERS Accountants & Business Advisers Group
■ companies or individuals contracted to assist us in providing services or who perform functions
on our behalf (such as mailing houses, specialist consultants, barristers and solicitors,
contractors or temporary employees to handle peak period workloads, information technology
service providers, superannuation fund trustees, insurance providers, fund managers, market
research organisations and other product providers)
■ courts, tribunals and regulatory authorities, as required or authorised by law and in accordance
with the Code of Ethics for Professional Accountants
■ auditors or compliance officers, as required by Law or Professional Associations
■ anyone else to whom you consent, such as banks, accountants and other financial institutions.
The Corporations Act has also provided the Australian Securities and Investments Commission
with the authority to inspect certain personal information that is kept on our files about you.
Where such an inspection takes place, this may involve the disclosure of your personal
information to representatives of the Australian Securities and Investments Commission.
Where you engage us to attend to your tax affairs we will assume (unless you advise otherwise)
that you have specifically authorised us to deal directly with the Australian Tax Office (the
“ATO”), the New Zealand Inland Revenue or other taxation agency in a foreign jurisdiction
regarding day to day type matters. If, in the course of our dealings with these bodies, they
request information regarding you that we believe is outside of the scope of our authority, e.g.
Tax Office audit, we will request your specific authority before complying with the relevant
request.

If we are required by law to disclose information about you or your organisation, we must co-
operate fully. However, where it is possible and lawful for us to do so, we will advise you that the
information has been disclosed.

Security of your personal information

DK PARTNERS Accountants & Business Advisers is committed to ensuring that the information
you provide to us is stored securely. In order to prevent unauthorised access or disclosure, we
have put in place suitable physical, electronic and managerial procedures to safeguard and
secure information and protect it from misuse, interference, loss and unauthorised access,
modification and disclosure.

Our employees are required to respect the confidentiality of personal information and the privacy
of individuals, and privacy and data protection training is undertaken. As part of that training, all
employees are required to read this policy and understand their obligations in regard to personal
information.

Each year all employees are required to acknowledge that they have complied with all aspects of
this policy and kept themselves abreast of any changes to this policy.

Where we employ data processors to process personal information on our behalf, we only do so
on the basis that such data processors comply with the requirements under the Australian
Privacy Act and GDPR and have adequate technical measures in place to protect personal
information against unauthorised use, loss and theft.

The transmission and exchange of information made by you is done so at your own risk. We
cannot guarantee the security of any information that you transmit to us, or receive from us.
Although we take measures to safeguard against unauthorised disclosures of information, we
cannot assure you that personal information that we collect will not be disclosed in a manner that
is inconsistent with this Privacy Policy.

Retention of your personal information

We will retain your personal information only as long as necessary to fulfil the purpose for which
it was collected, as required by law and the Australian Privacy Principles, or in accordance with
our documentation retention policies.

Access to your personal information

If you would like a copy of the information which we hold about you or believe that any
information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please
email us at dragan.kalinic@dkpartners.com.au.

We will require you to verify your identity and to specify what information you require.
We reserve the right to refuse to provide you with information that we hold about you, in certain
circumstances set out in the Privacy Act or any other applicable law. If access is denied we will
explain the reason why it is denied.

We endeavour to respond to your request for details of personal information we hold, however
you should anticipate that it may take some time to process your request as there may be a need
to access the information from our archives.
We endeavour to provide you with details of personal information we hold free of charge,
however we reserve the right to charge you a fee for providing you with the information. If we
propose to charge a fee we will advise you in advance.

Keeping personal information up to date

We endeavour to ensure that the personal information we hold is accurate, complete and up-to-
date. Changes inevitably are required and unfortunately errors do occur from time to time. You
should contact us immediately in order to advise us of any changes to the personal information
we hold about you.

Website & Cookies

When you visit our websites

When you come to our website www.dkpartners.com.au, we may collect certain information such
as browser type, operating system, website visited immediately before coming to our site, etc.
This information is used in an aggregated manner to analyse how people use our site, such that
we can improve our service.

We may also collect personal information through subscription applications, event registration
and emails. You are not required to provide personal information via our website, however you
may choose to do so in order to receive communications on our services, apply for an
employment position or receive invitations to events. Information collected via our digital
marketing activities is treated in accordance with this Privacy Policy.

Cookies

We may from time to time use cookies on our websites. Cookies are very small files which a
website uses to identify you when you come back to the site and to store details about your use
of the site.

Cookies are not malicious programs that access or damage your computer. Most web browsers
automatically accept cookies but you can choose to reject cookies by changing your browser
settings. However, this may prevent you from taking full advantage of our websites. Our websites
may from time to time use cookies to analyse website traffic and help us provide a better visitor
experience.

In addition, cookies may be used to serve relevant advertisements to website visitors through
third party services such as Google AdWords. These advertisements may appear on our
websites or other websites you visit.

Third party sites

Our website may from time to time have links to other websites not owned or controlled by us.
These links are meant for your convenience only. Links to third party websites do not constitute
sponsorship or endorsement or approval of these websites. Please be aware that DK
PARTNERS Accountants & Business Advisers is not responsible for the privacy practises of
other such websites. We encourage our users to be aware, when they leave our website, to read
the privacy statements of each and every website that collects personal identifiable information.

Social media platforms

You may wish to participate in the various social media platforms hosted by us and which we
make available to you. These platforms are designed to facilitate and share content. We cannot

be held responsible if you publicly share personal information on these sites that is subsequently
used, misused or otherwise appropriated by another party/entity.

Changes to Privacy Policy

Please be aware that this policy may be updated as and when required, for example, to take into
account new laws, changes to our operations and practices, changes in the business
environment and technology. We may modify this Policy at any time, in our sole discretion and all
modifications will be effective immediately upon our posting of the modifications on our websites.
Please check back from time to time to review our Privacy Policy.
This policy was last updated November 2018.

Complaints about privacy

If you have any complaints about our privacy practices, please feel free to send in details of your
complaints to dragan.kalinic@dkparters.com.au. We take complaints very seriously and will
respond shortly after receiving written notice of your complaint.