Modoras Accounting (Gold Coast) Pty Ltd
Respecting your privacy and the law
The privacy of your personal information has always been important to us at Modoras Accounting (Gold Coast) Pty Ltd and our associated and related companies referred to below (the ‘Group’). We are committed to respecting your right to privacy and protecting your personal information. We adhere to the Australian Privacy Principles and any applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with the law and our standards, policies and procedures.
We may also need to share the information with third parties, such as other financial product providers. Also it is a Modoras policy to use the information within the Group’s companies to identify and make available to you other broadly related financial services. This enables Modoras to have an integrated view of you, our clients.
You have the right to request us in writing that your personal information not be provided to other parties, however, that may mean that it is not possible to provide you with the products and services that you have requested. Where we identify this is the case we may inform you in writing.
Members of the Group
- Modoras Pty Ltd ABN 86 068 034 908, Australian Financial Service Licence and Australian Credit Licence Number 233209 (Licensee)
- Modoras Accounting (Gold Coast) Pty Ltd ABN 62 601 145 199 (accounting services)
- Modoras Accounting (QLD) Pty Ltd ABN 81 601 145 215 (accounting services)
- Modoras Accounting (VIC) Pty Ltd ACN 145 368 850 the Trustee for Modoras Accounting (VIC) Unit Trust ABN 37 460 720 728 (accounting services)
- Modoras Accounting (SYD) Pty Ltd trading as Modoras Downes Barrington ABN 18 622 475 521 (accounting services)
- Modoras Wealth Management (QLD) Pty Ltd ABN 66 623 115 668 (financial advising services)
- FinancialLine UMG Pty Ltd ABN 24 741 319 784 (financial advising services)
- FinancialLine Pty Ltd ABN 28 104 193 857 (technology services)
- Enevita Corporate Services Pty Ltd ABN 73 606 822 566 (accounting administration services)
Collecting your personal information
The Group receives, collects or holds your personal information for the purposes of:
- Providing you with services and products (including assessing your application and identifying you);
- Managing and administering the product or service we provide to you; and
- Protecting you against fraud.
Group companies may also collect your personal information for the purpose of promoting and marketing products or services that might be of interest to you.
We collect your personal information when you fill out product or service documentation, an administrative form, or when you give us personal information over the telephone, or through a Group organisation’s website.
We may collect your personal information from third parties such as your employer, or a representative such as a legal adviser or accountant or publicly available sources of information.
The type of personal information we collect and hold
Personal information held by the Group may include identification information such as your name, address, phone numbers, email addresses, Tax File Number (TFN) etc.
Depending on the type of product or service you require or choose, we may also ask you for other personal information about:
- Employment information;
- Marital status and family information or circumstances;
- Financial information such as your superannuation and other investment details;
- Business interests and trust structures;
- Your insurance, credit, financial and bankruptcy history;
- Date of birth and gender;
- Details regarding any circumstances or assets you wish to insure; and
- Other personal information details which are needed depending on the type of financial product or service you require.
Your sensitive information
The collection of sensitive information is restricted by the national Privacy legislation. This includes information such as your racial or ethnic origin, political opinions, association memberships and details of your health, disability etc.
This type of information is only collected with your consent and where required to provide you with the products, services or assistance you may require and the collection of this information is needed to provide these products, services and assistance.
How will we collect your personal information
We collect your personal information:
- Directly from you when you provide information by phone, in person or in documents;
- From third parties including related firms;
- From publicly available sources of information;
- When required to do so by Federal or State legislation;
- The organisations identified within this document.
Security of your information
We hold your personal information in:
- Our computer systems and electronic databases;
- Digital records; and
- In hard copy or paper files.
We protect your personal information by:
- Stand by systems and system backups to deal with any business interruptions;
- Limiting physical access to our offices and premises;
- Limiting physical and electronic access to your personal information and our systems;
- Identifying whether third party providers with whom we deal have appropriate documented policies consistent with the Australian Privacy Principles;
- Maintaining technical security product to protect your personal data; and
- Destroying or de identifying personal data and information, where required by law once such data is no longer required to be maintained by us.
- Staff training and through employment agreements and electronic user identifiers and passwords.
Using and disclosing your personal information
In order for the Group to meet your specific needs, or to comply with the Group’s legal obligations, the Group may need to disclose your personal information to the type of firms and organisations described below. Where your personal information is disclosed to these firms and organisations, we will to the extent possible seek to identify that they also have the appropriate documented privacy policies consistent with the Australian Privacy Principles.
The relevant organisations are those:
- Involved in providing, managing or administering your product or service including
- Banking and finance organisations;
- Financial Planning service providers;
- Trustee or custodial services; and
- Life or General insurance providers.
- Group companies who may wish to promote and market products or services that might be of interest to you.
- Involved in maintaining, reviewing and developing our business systems, procedures and infrastructure.
- Involved in a transfer of all or part of the assets or business of a Group company;
- Involved in the payments system including financial institutions, merchants and payment organisations.
- Which are your representatives including your legal advisers and accountants.
- As required or authorised by law.
- Where you have given your consent.
Other use and disclosure
If your personal information is subject to Australian Privacy Principles, we will only use and disclose your personal information for a secondary purpose if it is related to the primary purpose for which we collected it and where you would reasonably expect us to use or disclose your information for that secondary purpose. In the case of sensitive information, we will only use this information for the secondary purposes if it is directly related to the primary purpose of collection or where we are required, authorised by law or a court tribunal order to disclose your personal information and sensitive information. For example, to a Court in response to a subpoena or to the Australian Taxation Office, Centrelink or to the Australian Transaction Reports and Analysis Centre (“AUSTRAC”).
Use and disclosure of personal information for marketing
The Group is able to assist you in providing a large range of accounting and financial services, products and advice. An important part of our service to you is marketing, by being able to keep you up to date with new services and products which we think may be of benefit and interest to you.
In bringing this information to you, we use a large range of communication tools including mail, telephone, email and other internet based tools as well as direct and group presentations. Third party marketing service providers may combine the personal information we disclosed to them with information that we already hold about you, to provide you with more relevant information about the products and services we can provide you.
Keeping your personal information accurate and up-to-date
We aim to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. This way we can provide you with better service. If you believe your personal information is not accurate, complete or up to date, please contact us.
Protecting your personal information
We store information in different ways including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure.
Your privacy on the Internet
We take care to ensure that the personal information you give us on our websites is protected.
For example, our websites have electronic security systems in place, including the use of firewalls and data encryption. Depending on the Group Company with which you deal, user identifiers, passwords or other access codes may also be used to control access to your personal information.
Please refer to the website of those Group companies with which you transact electronically for more information on their website’s specific privacy and security procedures.
Links to other sites
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.
Overseas Service Providers and disclosure
Companies within our Group will, when necessary, disclose personal information to organisations and persons overseas. Instances when we will do this include:
- When we are authorised or required by an Australian law or a court/tribunal to do so; or
- When we have engaged an overseas service provider to deliver services central to our financial service business operations.
Your personal information will be disclosed to the extent it is necessary to perform our functions or activities.
These external service providers to whom your data may be provided are for our Group’s client service management system and the service providers for this are located in Indonesia and Sri Lanka. This external overseas service provider provides computer system, computer code support and service to the group. Also, our internal document management system is supported by a service provider located both within Australia and overseas in the Philippines.
In addition to the above our Group also utilises external service providers located in Sri Lanka and India, which provides Accounting administration service, and the Philippines, which provides project management, marketing support and database management.
When you visit our website details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
Gaining access to your personal information
You can gain access to the underlying personal information and data the Group holds in relation to you. You can also ask for corrections to be made. If you would like to request confirmation of your personal information we hold please contact us.
There are some circumstances where we are not required to give you access to your personal information. If we refuse your request we will give you written reasons if we deny access or confirmation.
Our response to your request could take up to 30 days from the receipt of your request. If we require further time we will write to you and advise you of the reason for the further time required. If such request incurs a fee, we will advise you of this.
Correction of personal information
You also have the right to request that we correct any inaccurate, out of date, incomplete, irrelevant or misleading personal information we may hold. We will take such steps that we regard as reasonable to make any correction required to ensure the information is accurate, up to date, complete, relevant and not likely to mislead. If we refuse to change or correct your personal information we will provide reasons for the refusal in writing to you. If we refuse to correct or change any personal information, you have a right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take any steps that are reasonable to associate that statement with all the records containing that relevant information.
Using Government identifiers
In certain circumstances we are required to collect government identifiers such as your TFN, Medicare Number or Pension Card number. We do not use or disclose this type of information other than when required or authorised by law or unless you have consented to disclose this information to any third party.
Dealing with us anonymously or through the use of pseudonyms
You have the option of not identifying yourself and dealing with us anonymously or through the use of a pseudonym, where it is lawful and practicable to do so.
Resolving your privacy issues
If you have any issues or a complaint that you wish to raise with the Group about the way in which we collect, use, hold or disclose your personal information or about a breach of the Australian Privacy Principles please use our complaint process so that we can help.
You are always welcome to speak directly to our staff and they will do their best to resolve your issue. Alternatively, you can email your issue to email@example.com, write to us directly or contact us by phone. If investigation is required we will keep you advised of the progress.
If our staff are unable to resolve the matter it will be escalated to an appropriate Senior Manager of the Group.
If we are unable to resolve your issue or complaint immediately, a response to that effect will usually be provided to you within 5 business days. We will endeavour to resolve client complaints within 45 days. However, this may not always be possible.
Modoras will provide you with a written response to the issues in your complaint.
If you are not satisfied with the outcome you may be able to access the services of an ASIC approved external dispute resolution scheme or other body, we have provided contact details of these below:
Office of the Australian Information Commissioner (OAIC)
Complaints must be in writing
Phone 1300 363 992
Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
If you seek any further information from the Modoras Group about this policy, please contact our Privacy Officer reference point below:
Registered Address: Level 3, 50 – 56 Sanders Street
Upper Mt Gravatt QLD 4122
Postal Address: PO Box 6530
Upper Mt Gravatt QLD 4122
Telephone: (07) 3219 2555
Facsimile: (07) 3219 4432