1 Introduction

First Class Accounts respects the privacy of people we deal with and we have developed this policy to explain how we and our franchisees collect and handle personal information about you in accordance with the Privacy Act 1988 (Cth).

We do not control the collection, use or disclosure of, and may not have access to, the Personal Information held by our franchisees. Our Franchisees are responsible for ensuring that your Personal Information collected by them is handled in accordance with this Privacy Policy and Australian Privacy Principles (“APPs”).

1.2 Definitions

In this policy, some words have a special meaning. Those words and the corresponding meaning are as follows:

First Class Accounts, we, us, our means First Class Financial Group Pty Ltd ACN 147 962 187, its ‘associates’ (as that term is defined and used in the Corporations Act 2001 (Cth)) and our franchisees.

Franchising Services means to process any enquiry or application you make to become a franchisee of ours and/or to the provision of services to you under a franchise agreement you enter into with us.

Personal Information means information or an opinion about an identified natural person, or a natural person who is reasonably identifiable.

Privacy Act means the Privacy Act 1988 (Cth).

Network means the network of First Class Accounts franchisees.

Services means those services you request of us and/or a franchisee in relation to bookkeeping and tax agent services.

Website means the website operated by First Class Accounts.

2 How we collect your Personal Information

2.1 How, what and why we collect your Personal Information

We collect information about you (including, but not limited to, that information set out in the table below) that:

(a) (you give us directly): when you interface and deal directly with either:
  • us or one of our related bodies corporate; or
  • one of our franchisees, for:
  • the provision of the Services;
  • the provision of the Franchising Services; and
  • employment by us or a franchise.

We refer to this information as “Services Information

(b) (we receive from other sources):
  • information we receive from other franchisees in the Network, business partners, sub-contractors, advertising networks, analytics providers, search information providers, third party applications that plug into our Website and/or software utilised in our business and the Network;
  • information we receive from your appointed professional advisors, such as accountants and lawyers;
  • information we receive from any regulator that we are appointed or requested to deal with on your behalf;
  • information we receive from a referee you have listed on any application form with us;
  • information we receive from software you utilise and provide us access to or software we utilise and provide you access to;
  • information about you from publicly available sources including, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory and social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc); and
  • payment providers/merchants.

We refer to this information as “Third Party Information”.

(c) (we collect about you and your device):
  • technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system, platform and type of device; and
  • as you browse our website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the website, and information about how you interact with the website.

We refer to this automatically collected information as “Device Information”.

(d) (you give us directly as a result of being employed by us):
  • medical records and/or information pertaining to existing medical conditions we are required to hold in case of an emergency to assist you; and
  • results of any tests we are required to undertake.

We refer to this information as “Sensitive Information”.

(e) We collect Device Information using the following technologies:
  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, see clause 1.8 of this policy and/or visit http://www.allaboutcookies.org;
  • “Log files” track actions occurring on the Store, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Store.

What information do we collect?

  • name;
  • company name;
  • residency;
  • date of birth;
  • country of residence;
  • job title and employer;
  • Tax File Number;
  • Employee record information;
  • CV, resume or application related behaviour
  • contact details such as address, email address;
  • business/mailing address;
  • title;
  • nature of business;
  • bank account and credit or debit card details;
  • professional advisors;
  • advice received from the client or prospective client that may contain additional personal information, such as family relationships and other business-related connections;
  • qualifications, memberships and other accreditations;
  • financial records;
  • verification of identify documents;
  • memberships or associations;
  • racial or ethnic background, political or religious beliefs; and
  • online interactions with our website, publications, alerts and social media activity.

Why we might collect the information

Bookkeeping and Tax Agent Services

  • to provide you with the Services;
  • to maintain a database of clients;

Franchise Enquiry

  • to you with the Franchising Services;
  • to maintain a database of franchisees;
  • to disclose in marketing materials and our disclosure document;
  • to organise goods and services for you in relation to any contractual arrangement with us;

General

  • to identify you and conduct appropriate identity checks;
  • to communicate with you;
  • to process (or facilitate in the processing) of information with any regulator or appointed advisor in association with the Services, Franchising Services and your employment;
  • to screen our orders for potential risk or fraud;
  • to communicate about and provide you with our current and future products and services;
  • to send you relevant news, promotion and marketing materials, either initiated by us or a third party;
  • to respond to your requests, questions, comments and complaints;
  • to the extent that we consider it is necessary to provide our products and services to you or to improve the products, services and business activities that we undertake;
  • to publish your reviews, forum posts or other content on our Website (or other website operated by us);
  • to invite you to marketing events;
  • to improve and optimise our Services and Franchising Services; and
  • any other reason allowed at law.

Third Party Information

  • to provide you with the Services;
  • to provide you with the Franchising Services;
  • to employ you;
  • to identify you and conduct appropriate identity checks;
  • to communicate with you;
  • to process (or facilitate in the processing) of information with any regulator or appointed advisor in association with the Services, Franchising Services and your employment;
  • to communicate about and provide you with our current and future products and services;
  • to send you relevant news, promotion and marketing materials, either initiated by us or a third party;
  • to respond to your requests, questions, comments and complaints; or
  • any other reason allowed at law.
  • to the extent that we consider it is necessary to provide our products and services to you or to improve the products, services and business activities that we undertake;
  • to publish your reviews, forum posts or other content on our Website (or other website operated by us);
  • to improve and optimise our Services and Franchising Services; and
  • any other reason allowed at law.

Device Information

  • to help us screen for potential risk and fraud;
  • improve and optimise our Website (for example, by generating analytics about how our customers browse and interact with the Website, and to assess the success of our marketing and advertising campaigns);
  • to provide you with local information and alerts about our products and services;
  • to improve our website, goods and services;
  • to comply with local legal restrictions;
  • to gather anonymous statistics;
  • for analytical purposes;
  • to ensure proper function of the Website and our software; or
  • any other reason allowed at law.

Sensitive Information

  • to employ you;
  • to assist you in a medical emergency;
  • to create a safe workplace for you and for others in accordance with our obligations under the Work Health and Safety Act (Qld) 2011; and
  • any other reason required by law.

Information, communication or opinions about any of our products, services, transactions, payment history and business activities.

  • to improve the products, services and business activities that we undertake; or
  • any other reason allowed at law.

Information that may be collected by us or on our behalf via third parties including the date and time of your visit to our website, IP address, documents and pages you access, type of browser and setting, operating system, address of a recurring site you are about to visit; information you submit regarding payment particulars, device identifier, including UDID, device details, pages visited, language selections, cookies, tracking pixels, geographic area and location.

  • to provide you with local information and alerts about our products and services;
  • to improve our website and services;
  • to comply with local legal restrictions;
  • to gather anonymous statistics;
  • for analytical purposes;
  • to ensure proper function of the website and online software; or
  • any other reason allowed at law.

Identifiers (such as business number), citizenship and residency details, details regarding and information provided by your referees, details regarding and information provided by your guarantor(s) and business partner(s), financials/credit/criminal history checks, employment history, education history, identity documents.

  • to employ you;
  • to identify you;
  • to identify any guarantor(s);
  • to conduct identity and criminal checks;
  • to conduct credit checks;
  • any other reason allowed at law.

Other information

  • to provide you with products, services and undertake business activities;
  • as described to you at the point of collection; or
  • any other reason allowed at law.

(f) In some situations, you will have the option to deal with us anonymously or through a pseudonym, however, where you are requesting products, the Services, the Franchising Services and/or employment with or from us, it may become impracticable to provide those products or services to you without verifying your identity. Where you fail to provide us information or where the information provided is incomplete and/or inaccurate, or you choose not to provide us with the information that we have requested, it may affect our ability to provide you with our products and services.

(g) In the event that we receive identifiable information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that information. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified.

2.2 Tax File Number

We will handle your tax file number in accordance with Privacy (Tax File Number) Rule 2015 (Cth).

2.3 Do Not Track settings

Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

2.4 Behavioural Advertising

(a) As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising   Initiative’s  (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it- work.

(b) You can opt out of targeted advertising by using the links below:

(c) Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

2.5 Website analytics

(a) To improve your experience on our Website, we may use ‘cookies’. Cookies are an industry standard and most major web sites use them. A cookie is a small text file that our Website may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our Website.

(b) Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites. When you go to other websites from here, we advise you to be aware and read their privacy policy.

(c) Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

(d) By using our Website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out in this policy. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

3 Disclosure of Personal Information

3.1 Primary Purpose

(a) We will collect and use the Personal Information for the primary purpose(s) as provided in Section 2 of this policy.

(b) As well as abovementioned purpose, the primary purpose includes facilitating our internal business processes, communicating with clients, prospective clients and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations and dealing with enquiries and complaints.

3.2 Secondary Purpose

In certain circumstances, the law may permit or require us to use or disclose Personal Information for other purposes, for instance where a client would reasonably expect us to and the purpose is related to the purpose of collection.

3.3 Disclosing your information

We may share your information with:

(a) any of our ‘associates’ (as that term is defined in section 50AAA of the Corporations Act 2001 (Cth));

(b) third parties including:

  • franchisees;
  • regulators, including Commonwealth and State Governments;
  • superannuation fund administrators;
  • business partners, agents, suppliers and subcontractors;
  • payment providers, such as Direct Deb, Practice Ignition or SmartPay
  • software providers;
  • any other entities disclosed in this policy,

(c) any prospective buyer of any part of our business or assets; or

(d) where we are required to disclose your information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with organisations for the purposes of fraud protection and credit risk reduction.

3.4 Sharing your personal information

(a) We share your Personal Information with third parties to help us use your Personal Information and provide the Services, Franchising Services and/or employ you. Specifically, we share your Personal Information with the following service providers:

(b) We will not share your Sensitive Information unless required by law or in an emergency situation. When you are no longer employed by us, we will delete and remove your Sensitive Information, except to any extent that we are required by law to retain.

(c) Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

4 Storing your Personal Information

4.1 Storing your information

(a) In order to offer the Services, Franchising Services and otherwise employ you we may store and manage data electronically or in paper form.

(b) Where data is stored electronically, it is done so either:

  • on cloud-based servers in Australia;

(c) Your Personal Information is not directly exported by us outside of Australia. However, where one of our third party service providers utilise servers in a jurisdiction other than Australia, your Personal Information may reside on a servers outside of Australia and as determined by those third party providers from time to time. At the date of this policy, we understand our third-party service provider servers are in the Australia

(d) We will take all steps reasonably necessary to ensure that your Personal Information is handled in accordance with the APPs and this policy. Despite our endeavours, the transmission of information through the internet is not completely secure.

(e) Submission of any information to us is an acknowledgement that you agree to such use, storage and disclosure.

4.2 Security of your Personal Information

We take the storage and handling of your Personal Information seriously. To secure your Personal Information, we run regular backups into a secure environment. We have an IT company that regularly monitors our security process

5 Credit information

Mainly First Class Accounts provides 7 day credit, It is up to the individual business to decide if the credit will go beyond this time .

6 Accessing and correcting your Personal Information

(a) You may request access to or correct Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this policy. We will respond to any such request for access to Personal Information within a reasonable timeframe and will provide you access to the Personal Information that we hold pertaining to you, unless we are authorised not to do so by law.

(b) We may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so.

(c) If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant or misleading, please notify our Privacy Officer using the details set out in this policy.

(d) If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. In the event that we decline the request to correct Personal Information, you may request to associate a statement with the information.

7 Complaints

(a) Should you believe that we have not fulfilled our obligations under any relevant law or have not complied with the terms of this policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the coantact details set out in this policy.

(b) We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

(c) If after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Privacy Commissioner:

Officer of the Australian Information Commissioner (OAIC)
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
GPO Box 5218, Sydney, NSW 2001

See the OAIC website for further details: www.oaic.gov.au

8 Contact

If you have any comments, concerns or questions regarding this policy or Personal Information that we hold about you, please contact our Privacy Officer:

Privacy Officer
First Class Accounts
Email: info@firstclassaccounts.com
Citypods 1, 249 Scottsdale Drive, Robina, Qld 4216

We reserve the right to update this policy at any time without notice. Any changes will be published on our Website.

Last revised and updated on 22 May 2020.