Privacy Policy

Introduction

Peak Strategies (WA) Pty Ltd (ACN 140 896 804) as trustee for the Thornett Family Trust (ABN 48 204 282) is a business registered in Australia offering a range of specialist accounting, taxation, valuations, and complimentary services to our pharmacy clients.

In this Privacy Policy we will refer to Peak Strategies (WA) Pty Ltd as trustee for the Thornett Family Trust as “Peak Strategies ”, “we”, “us” and “our”.

This is Peak Strategies’ Australian Privacy Principles’ Privacy Policy. It explains how Peak Strategies respectively approaches the important issues of privacy and the management of your Personal Information.

Please contact Peak Strategies Privacy Officer (details Are at the end of this Privacy Policy) if you require any further information regarding our Privacy Policy.

Peak Strategies provides the following range of professional accounting and advisory services:

Tax and Compliance

Pharmacy Bookkeeping

Business Advisory

Pharmacy Marketing

Business Growth Strategies

Mentoring

(collectively, the “Services”)

By choosing to participate or deal with us, engage our Services and/or by using our Website (“Website”), you consent and agree to Peak Strategies’ Privacy Policy as follows:

The Australian Privacy Principles

In 2014, the Australian Government updated the Privacy Act 1988 (Cth) (“Act”), to further enhance the protection and handling of an individual’s privacy and personal information. These principles replace the previous National Privacy Principles that operated from 2001. You can find out more about the Australian Privacy Principles by calling the Office of the Australian Information Commissioner on 1300 363 992 or reading about them at www.oaic.gov.au.

Under the Act, “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.

Peak Strategies respects and upholds your right to privacy protection under the Australian Privacy Principles in regulating how we collect, use, disclose and hold your Personal Information. We have a detailed policy and set of procedures to ensure that only authorised employees have access to your Personal Information, that it remains confidential and is only used for appropriate purposes and in accordance with this Privacy Policy.

Please note that our Privacy Policy is not intended to cover categories of Personal Information that are not covered by the Act.

THE PERSONAL INFORMATION WE COLLECT, AND WHY WE COLLECT IT

Information we get when you use our Services or Website.

The main types of Personal Information Peak Strategies collects and holds relate to the contact details and organisational roles of our employees, clients, suppliers and other business contacts. Typically, this information includes names, birth dates, addresses, telephone numbers, e-mail addresses and job titles.

In the course of providing professional services to our clients, we may collect and hold more detailed Personal Information, for example:

· where relevant to the Services we are providing you, your financial information about your assets, occupation and income, bank account balances, account activities, payment history;

· government identifiers such as Tax File Number, drivers’ license, passport and Medicare numbers and visa/work permit status;

· ID information such as your name, postal or email address, telephone numbers, and date of birth;

· other contact details such as social media handles;

· shareholdings and details of investments;

· details of superannuation and insurance arrangements;

· educational qualifications, employment history and salary; and/or

· Personal Information about a spouse and dependents.

When you use our Website, we collect information about which of those services you have used and how you have used them. We might know, for instance, that you a visited a certain page, saw a specific ad for a certain period of time. Here is a fuller explanation of the types of information we collect when you use our services:

· Usage Information. We collect information about your activity through our Services. For example, we may collect information about how you interact with our Services or which queries you submit.

· Content Information. We collect content, queries and responses that you engage with via our Services and Website, such as custom content, and information about the content you create or provide, such as if the recipient has viewed the content and the metadata that is provided with the content.

· Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with our Website we may offer through one of our partners, such as advertising and commerce features.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. To learn more about how we use cookies and your choices, and about how third parties use these technologies on our Services, please check out the “Visiting our Website” section of this Privacy Policy.

· Log Information. We also collect log information when you use our Website or Services. That information includes, among other things:

details about how you have used our Services;

device information, such as your web browser type and language;

access times;

pages viewed;

IP addresses;

identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and

pages you visited before or after navigating to our website.

When the Law authorises or requires us to collect information

We may collect information about you because we are required or authorised by law to collect it.

Information we collect from third parties

We may collect information about you from other users, our affiliates, and third parties.

Your personal and sensitive information is only collected as is necessary for a function or activity, or to enable us to carry out our work and deliver our Services.

We may use your Personal Information to send you information about our work or to let you know about our Services. Each time we send you a direct marketing communication we will provide you with a simple way to “opt out” of receiving similar communications in the future.

You can also let us know that you do not wish to receive any further communications by contacting Peak Strategies ’s Privacy Officer.

Peak Strategies will not collect sensitive information about health, racial or ethnic origins, political opinions or memberships, religious or philosophical beliefs, trade association or union memberships, sexual preferences or criminal records unless you have consented to give this information and it is relevant to our work and Services.

For example, sometimes we need to collect sensitive information about you, for instance if we need to assist with certain insurance applications. This could include things like medical checks, medical consultation reports or other information about your health.

We will always collect such information in a non-intrusive, lawful and fair manner. We will offer you the option of not identifying yourself or of using a pseudonym where it is practical to do so.

Opting out or modifying your information

If you want to change any information that you have previously given us, or if you want to opt out of future communications please contact Peak Strategies’ Privacy Officer as detailed below.

How we collect your Personal Information

We collect your Personal Information when you provide it to Peak Strategies in a number of ways including but not limited to:

· directly from you e.g. being engaged as our client, when we provide you with Services, through the Website, from a job application or resume, or application forms;

· as authorised by you providing us with your Personal Information;

· by voluntary completion of surveys or forms;

· from public domain e.g. your business’ website;

· from authorised third-party data sources and data lists for the purposes of conducting our Services;

· from your other personal or business, advisors, partners, associates and employers; or

· by your usage of the Website e.g. the pages that you visit, what links you click by contacting us by post, telephone, email, or other electronic methods.

Sometimes we collect information about you from other sources. We do this only if it is necessary to do so. Instances of when we may need to collect information from other source include where:

· we cannot readily contact you and we rely on publicly available information to update your contact details; or

· at your request, we exchange information with your legal, financial or other professional advisors or other representatives.

In some cases, you might provide Personal Information to us by entering it into our cloud-based Services because you want us to host that information for you. Alternatively, your information may be disclosed to us by an organisation with whom you interact and to which we provide a cloud-based Service.

When we collect or hold Personal Information in this way, it is only used or disclosed for the purpose contemplated by you or the organisation that has disclosed that information to enable us to provide the work or Services sought.

Personal Information may be stored on our web servers but will only be accessed by us to provide technical support, or to carry out other functions reasonably necessary to provide the work or Services. This Personal Information will not be disclosed in any other way without your written consent.

What do we do when we get information we did not ask for?

Where we receive unsolicited Personal Information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we will handle this information the same way we do with other information we seek from you. If not, we will ensure we do the right thing and destroy or de-identify it.

When will we notify you that we have received your information?

When we receive Personal Information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your Personal Information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we use your Personal Information?

We may use your Personal Information for the following purposes:

· giving you information about a Service;

· considering whether you are eligible for a Service;

· processing your application and providing you with Service;

· administering the product or service we provide you, which includes answering your requests and complaints, varying products and services and managing our relevant product portfolios;

· identifying you or verifying your authority to act on behalf of a third party;

· telling you about other products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, IM/DM, mail, or any other electronic means including via social networking forums), unless you tell us not to;

· assisting in arrangements with other organisations in relation to a product or service we make available to you;

· allowing us to run our business and perform administrative and operational tasks, such as:

training employees;

developing and marketing products and services;

risk management;

systems development and testing, including our websites and other online channels.

undertaking planning, research and statistical analysis;

determining whether a beneficiary will be paid a benefit;

preventing or investigating any fraud or crime, or any suspected fraud or crime;

as required by law, regulation or codes binding us;

maintaining a database of third parties, to, amongst other things, track and make payments of commissions and other amounts to them;

managing our relationship with you;

investigating and dealing with suspected or actual unlawful activity;

assisting in improving industry standards relating to accountancy services; and

assisting with recovering amounts owing to us; and

for any purpose for which you have given your consent.

Please also note, owing to the ever-changing nature of technology and to provide optimal support to you, we may use different third-party support software and platforms from time to time. To that, any such data stored or processed will also subject to the privacy policies of those relevant individual third parties and platforms as may vary.

We may use your Personal Information to the extent that is reasonably necessary to carry out the Services including for the following purposes:

· to deliver and improve our Services and the Website;

· to provide personalised and direct marketing content to your email address, mobile phones, portable computing and other digital technology devices;

· to compile analytics in sizing or quantifying market opportunity;

· to predict market opportunity forecasting and resource allocation; and

· to disclose to other businesses who assist us or our clients in providing services or who perform functions on our clients’ behalf.

How we keep your Personal Information secure

Our premises are in secure buildings with restricted access.

To further and better secure your Personal Information, we have partnered with Accelerate IT details of any relevant practice management software/platform?] to help safeguard your data.

Practice Protect employs a “secure platform to manage all of Peak Strategies ’s employee’s passwords. None of our employees know their cloud app passwords, they only know their own minimum 16 character “passphrase” to first access the Practice Protect platform. Once on the platform, they can securely access the various cloud apps needed to carry out their daily work. If a team member leaves, their access to the Practice Protect platform is simply switched off.

All our passwords are regularly updated “passphrases”, with a minimum of 16 characters. Coupled with ‘two factor authentication’ (“2FA”), this adds extra layers of security to help secure our business and your personal data.

Additionally, the Accelerate IT will refuse access if the person logging on is not within a prescribed geo-location. This further reduces the risk of an unauthorised person offshore or interstate accessing our systems even if they do improperly get hold of a team member’s logon credentials and get past 2FA.

To learn more about how Practice Protect helps to protect your Personal Information, please go to Accelerate IT website.

We frequently update our anti-virus and malware software in order to protect our systems (and the data contained in those systems) from computer viruses. In addition, all our employees are required, as a condition of employment, to treat Personal Information held by Peak Strategies as confidential.

Whilst we store your Personal Information in our onsite servers, there may be some circumstances where your Personal Information is stored on a remote, “Cloud” or offsite server. These cloud servers may be situated outside of Australia.

If we store your Personal Information on a remote, “Cloud” or offsite server we will endeavour to protect your Personal Information through security measures such as password protection and encryption.

We retain and store your Personal Information (whether onsite, offsite or on the Cloud) indefinitely, unless you instruct us otherwise.

Destroying Personal Information

We may destroy or de-identify the Personal Information provided by you once it is no longer needed for our Services. However, we may, in addition to the reasons already disclosed in this Privacy Policy, in certain circumstances be required by law to retain Personal Information after our Services have been completed.

In this case, the Personal Information will continue to be protected in accordance with this Privacy Policy. If we destroy Personal Information, we will do so by taking reasonable steps and using up-to-date techniques and processes.

Disclosing your Personal Information

We may disclose your Personal Information to third parties but only for the purposes of providing the Services and for the purposes contemplated by your use of the Website.

These third parties may include:

· industry bodies or Professional Associations of which we are a member;

· those involved in providing, managing or administering the product or service we provide to you;

· authorised representatives of the Peak Strategies who sell products or services on our behalf;

· pharmacy, medical professionals, medical facilities or health authorities who verify any health information you may provide;

· valuers, insurers (including lenders’ mortgage insurers and title insurers) , re-insurers, claim assessors and investigators;

· loyalty programme partners;

· financial institutions, such as banks;

· organisations involved in debt collecting, including purchasers of debt;

· fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);

· organisations involved in surveying or registering a security property or which otherwise have an interest in such property;

· real estate agents;

· government or regulatory bodies (including ASIC and the *Australian Tax Office (“ATO”)) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);

· professional intermediaries we use such as accountants, auditors or lawyers and other external advisers;

· guarantors and prospective guarantors of your obligations to us;

· organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;

· organisations that participate with us in payments systems including merchants, payment organisations and organisations that produce statements for us;

· our joint venture partners that conduct business with us;

· organisations involved in a corporate re-organisation or transfer of group assets or business;

· organisations that assist with our product planning, research and development;

· mailing houses and telemarketing agencies who assist us to communicate with you;

· other organisations involved in our normal business practices, including our agents and contractors; and

· where you’ve given your consent;

· digital technology services and platform-providers;

· our partners, agents or contractors;

· our related entities; and

· our professional advisers.

* 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 ATO regarding day to day type matters. If, in the course of our dealings with the ATO, it requests information regarding you that we believe is outside of such matters, e.g. ATO audit, we will request your specific authority before complying with its request.

We may disclose Personal Information for the following purposes:

reporting to government agencies;
to obtain professional, medical or insurance advice;
for urgent health reasons;
to comply with training requirements;
to comply with regulatory or legal requirements; and
to comply with laws or court orders.

When we disclose your Personal Information with a third party, we will require the third party to handle your Personal Information in accordance this Privacy Policy and the Australian Privacy Principles.

Peak Strategies may sometimes use third party service providers to conduct surveys and facilitate information collection. Some of these service providers conduct all or part of their business overseas and so your Personal Information may be transferred overseas as a result.

Peak Strategies conducts a due diligence process before entering into an agreement with these service providers and will take all reasonable steps to ensure that your information is not used in a manner inconsistent with the Australian Privacy Principles.

Web traffic information is disclosed to Google Analytics when you visit our Website. Google stores information across multiple countries. When you communicate with us through a social network service such as Facebook, LinkedIn or Twitter, the social network provider and its partners may collect and hold your Personal Information overseas.

Visiting our Website

Our Website may use “cookies” to improve your experience on our site, to display content more relevant to you within the Website, and to display items added while using online facilities. If you are concerned about the use of these cookies, your browser can be configured to notify you when you receive a cookie, and provide you with the opportunity to accept or reject it. You may refuse all cookies from our Website, however some of its functions may then be unavailable.

Our Website may use statistical information collection tools (such as Google Analytics) to track site visits, navigation and performance within our Website for the purpose of monitoring and improving the site. If you are concerned about the use of these tools, you can configure your browser to send a "Do Not Track" request with your browsing traffic.

Our Website may also use third party cookies and Google Analytics Advertising Features including Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting.

Visitors can opt-out of Google Analytics for Display Advertising and customise Google Display Network ads using the Ads Settings. Further information regarding behavioural advertising, including ways to manage your online privacy, is available at www.youronlinechoices.com.au.

Where you provide your email address to Peak Strategies we will only use it for the purpose provided unless you have consented to us using it for additional purposes, and we will not pass it on to any other person or organisation unless we have disclosed this to you. We may also disclose your information where required by law to do so.

Our Website may contain links to other sites of interest. We do not control, and are not responsible for, the content or privacy practices of those websites. Please check the privacy policies on other websites before you provide your Personal Information to them.

Our Website’s security

By using our Website you acknowledge and agree that the internet is inherently insecure and that you use the internet at your own risk. You acknowledge that you do not hold Peak Strategies liable for any security breaches, viruses or other malicious software that may infect your computer or other internet browsing device, or any loss of data, revenue or otherwise that may occur as a result of using our Website.

We strive to ensure the security of your Personal Information and we take reasonable steps to protect your Personal Information from:

· misuse, interference and loss; and
· unauthorised access, modification or disclosure.

We will review and update our physical and data security measures in light of current technologies. Unfortunately, no data transmission over electronic, mobile data and communication services can be guaranteed to be totally secure.

Our employees and contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us.

We will do everything reasonably within our power and control to prevent unauthorised use or disclosure of your Personal Information. However, we will not be held responsible for events arising from any unauthorised use or access to your Personal Information.

Our Website is secured using industry-standard SSL/TLS technology to encrypt data between your browser and the Website.

Social networking services

We may use social networking services such as Facebook, LinkedIn, Instagram and Twitter to communicate with you and the public about our Services. When you communicate with us using these social networking and digital media services we may collect your Personal Information, but we only use it to help us to communicate with you and the public.

The social networking and digital media services will also handle your Personal Information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Facebook , LinkedIn, Instagram and Twitter on their websites.

Spam Act

We adhere to the Spam Act 2003 (Cth). The Spam Act prohibits the sending of unsolicited emails, SMS and MMS messages for commercial purposes from or within Australia or to people in Australia. The Spam Act also bans the supply and use of software designed to harvest email addresses.

Changes to our Privacy Policy

Peak Strategies may, without notice, amend or modify this Privacy Policy by posting the amended Privacy Notice to our Website.

How to access, correct or update your Personal Information

If you have any complaints, questions or concerns about what information Peak Strategies holds or about the accuracy of that information, please contact Peak Strategies’ Privacy Officer.

If you would like to access the information that we hold about you, or to complain about a possible breach of the Australian Privacy Principles, you can write to Peak Strategies’ Privacy Officer at the address provided below.

We will respond to your complaint or endeavour to give you access to the information requested within two weeks. In order to maintain the confidentiality of your Personal Information, we will ask to meet with you so we can review your specific identification documents before we give you access. If it is not practical for you to meet us in person, we will arrange to check your identification before we send the information out to you.

If the information that we hold about you is incorrect or not up-to-date, we will update it as soon as possible after you have shown us how and why it is incorrect.

In the unlikely event that we are unable to provide you with access to your Personal Information for legal reasons as specified in the Act, we will provide you with reasons for denying access.

If you are not satisfied with Peak Strategies’ response to your complaint, question or concern, you may wish to lodge a complaint with the Office of the Australian Information Commissioner. Further information can be found on the Commissioner’s website (www.oaic.gov.au) or by calling 1300 363 992.

Website accessibility

We are committed to providing an accessible experience for users of our Website. If you encounter any difficulties with our Website, please direct your enquiry to admin@peakstrategies.com.au.

Privacy Officer’s contact details

Peak Strategies ’s Privacy Officer can be contacted by:

Phone: 08 9315 3117
Email: admin@peakstrategies.com.au
Address: Unit 106, 19 Ogilvie Road Mount Pleasant, WA 6153.