Introduction

This document sets out the privacy policy of FSTP Strategy Pty Ltd (ABN 26 695 831 620) (referred to in this privacy policy as 'we', 'us', or 'our').

We take our privacy obligations seriously, and we have created this privacy policy to explain how we collect, store, maintain, use and disclose personal information, and how we comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth).

We are committed to protecting your personal information, so you can contact us using the details at the end of this policy if you have any questions or concerns.

By providing personal information to us, you consent to our collection, storage, maintenance, use and disclosure of personal information in accordance with this privacy policy.

We may change this privacy policy from time to time by posting an updated copy on our website, and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

Types of Personal Information We Collect

Because we provide services to businesses, the personal information we collect is generally limited. The personal information we collect may include:

• your name, job title and role;
• your business name and contact details, including email address, telephone number and business address;
• information about your business, your organisation and its circumstances;
• information contained in instructions, records, financial data and documents you provide to us for the purpose of our services, which may include personal information about your officers, employees, related parties or counterparties;
• billing and payment information;
• correspondence between you and us;
• information you provide in connection with an enquiry, the engagement of our services, or surveys and questionnaires;
• technical information collected when you visit our website, including your IP address, device identity and type, geo-location information, page view statistics and standard web log information; and
• any other information provided by you, or reasonably required by us, in connection with our services.

We do not generally collect sensitive information. If we need to collect sensitive information, we will do so only with your consent or as otherwise permitted by law.

How We Collect Personal Information

We may collect personal information either directly from you, or from third parties, including where you:

• engage us, or enquire about our services;
• provide us with documents, data or instructions for the purposes of our services;
• communicate with us via email, telephone or otherwise;
• submit any of our online forms or interact with our website; or
• are referred to us by, or engage us through, another adviser or organisation.

We may also collect personal information from third parties, such as your other advisers, any organisation through which you engage us, public registers and third party information databases, where it is necessary for the provision of our services.

We may collect technical information when you use or access our website through the use of web analytics tools, 'cookies' or other similar tracking technologies. Cookies are small files that store information on your device. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.

Use of Your Personal Information

We collect, hold and use personal information for the following purposes:

• to provide our transfer pricing and related advisory services to you, or to the organisation through which you engage us;
• to communicate with you and manage our engagement;
• for record keeping, administrative, billing and invoicing purposes;
• to provide information to our contractors, service providers, professional advisers, agents or other third parties who assist us to provide our services;
• to comply with our legal and professional obligations, including under the Tax Agent Services Act 2009 (Cth) and the taxation laws, and to respond to requests from the Australian Taxation Office, the Tax Practitioners Board, courts or other regulators;
• to resolve disputes or enforce our agreements;
• to send you updates or information about our services that may be of interest to you, which you may opt out of at any time using the opt-out facility provided; and
• to respond to your requests and enquiries.

Disclosure of Your Personal Information

We may disclose your personal information to:

• our contractors, service providers and technology providers (including IT, cloud hosting and software providers, which may include AI-assisted tools) who assist us to provide our services;
• your other advisers, or any organisation through which you engage us, where authorised by you or necessary for our services;
• the Australian Taxation Office, the Tax Practitioners Board, courts, tribunals or other regulators or government authorities, where required or authorised by law; and
• other third parties where you have consented, or as otherwise required or permitted by law.

Some of the recipients above, including cloud, technology and AI tool providers, may be located, or store data, outside Australia (including in the United States). Where we disclose personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient handles that information in a manner consistent with the Australian Privacy Principles.

Use of Artificial Intelligence

We may use artificial intelligence (AI) tools to assist us in providing our services, including for research, to streamline tasks, and to analyse financial and other data that may contain personal information.

Where we use AI tools to process personal information, we use enterprise AI tools (such as Google Gemini under our enterprise subscription) on terms which we understand do not permit the AI provider to use that information to train its models. Our confidentiality, security and overseas disclosure obligations set out in this policy apply to any personal information processed using AI tools.

In the course of a client engagement, we will agree how AI tools will be used and offer an opportunity to opt out of their use, in particular in relation to client data. If you have any questions about our use of AI, please contact us using the details below.

Security

We take reasonable steps to ensure your personal information is secure and protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.

If we become aware of a data breach that is likely to result in serious harm, we will respond in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

Retention of Personal Information

We retain personal information only for as long as necessary for the purposes for which it was collected, and to comply with our legal and professional obligations. As a registered tax agent, we are subject to record-keeping requirements under the taxation laws and the requirements of the Tax Practitioners Board, and we may retain records (including information underpinning our advice) for the period necessary to meet those requirements and to evidence and support our advice. When personal information is no longer required, we will take reasonable steps to destroy or de-identify it.

Links

Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites, and we suggest you review the privacy policies of those websites before using them.

Requesting Access or Correcting Your Personal Information

If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below, including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all of your personal information and, where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

Complaints

If you wish to complain about how we handle your personal information, or believe your privacy has been interfered with, please contact us using the details provided below with your name and contact details. We will investigate your complaint promptly and respond within a reasonable timeframe.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

Contact Us

For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Name: Bill Yohana, FSTP Strategy Pty Ltd

Email: byohana@fstp.com.au

Website: www.fstp.com.au