Privacy Policy

1. Introduction

1.1 About us

We are a firm of property tax accountants and advisers. We provide tax, accounting, structuring, asset protection and related advisory services to property developers, property investors and small business owners. Our registered office is at 470 St Kilda Road, Ground Floor, Melbourne VIC 3004, and we act for clients across Australia. We are a registered tax agent and our liability is limited by a scheme approved under Professional Standards Legislation.

We are also a reporting entity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (the AML/CTF Act). This means the law requires us to identify and verify our customers, and to keep certain records, before and while we provide some of our services.

1.2 The laws that apply to this policy

This policy is governed by the Privacy Act and the APPs. It also reflects our obligations under Part IIIC of the Privacy Act (the Notifiable Data Breaches scheme), the AML/CTF Act and the AML/CTF Rules, and the Privacy (Tax File Number) Rule 2015. Where we describe a legal obligation in this policy, we describe it in general terms. This policy is not legal advice.

1.3 Who and what this policy applies to

This policy applies to personal information we collect and hold about individuals we deal with, including clients and prospective clients, the individuals associated with our business clients (such as directors, shareholders, trustees, beneficiaries and beneficial owners), and visitors to this website. It applies to personal information we collect through this website, by email, by telephone, through our client onboarding and identity verification processes, and in the course of providing our services.

2. Key terms used in this policy

Personal information

means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not, as defined in the Privacy Act.

Sensitive information

means a special category of personal information, which includes information about an individual’s health, racial or ethnic origin, political or religious beliefs, sexual orientation, criminal record and certain other matters, as defined in the Privacy Act.

Customer due diligence

means the identification, verification and related checks we are required to carry out under the AML/CTF Act before and while we provide certain services. We refer to this as identity verification or customer due diligence in this policy.

Identification information

means the information we use to identify and verify you, such as your full name, date of birth, residential address and the type, number and expiry of an identification document.

OAIC

means the Office of the Australian Information Commissioner, the regulator responsible for privacy in Australia.

3. The personal information we collect and hold

The kinds of personal information we collect and hold depend on your dealings with us. They include the following.

3.1 Identity and contact information

Your full name, residential and postal address, email address, telephone number and date of birth, and, where relevant, the same details for individuals associated with a business client.

3.2 Identification and verification information

Identification information we collect to verify your identity and meet our obligations under the AML/CTF Act. This includes details from identification documents such as your driver licence, passport or other government-issued document, including the document type, number and expiry. Section 6 explains how we handle this information, including that we do not keep copies of your identification documents once your identity has been verified.

3.3 Financial, tax and property information

Information relevant to the services we provide. This may include your tax file number (see section 7), income, assets, liabilities and other financial information, details of your property holdings, developments, transactions and loans, the structures through which you hold property (such as companies, trusts and partnerships), and information about the source of funds or source of wealth where we are required to consider it.

3.4 Information about associated individuals

Where our client is a company, trust, partnership or other entity, we may collect personal information about the individuals connected with it, such as directors, shareholders, partners, trustees, beneficiaries and beneficial owners, so that we can provide our services and meet our customer due diligence obligations.

3.5 Dealings and communications

Records of our communications and dealings with you, including correspondence, file notes, the instructions you give us, and the advice and services we provide.

3.6 Website and technical information

Information collected when you use this website, such as your IP address, device and browser information, and how you use the site. Section 11 explains our use of cookies and similar technologies, and the information you give us through our enquiry and subscription forms.

3.7 Sensitive information

We do not usually collect sensitive information. If we need to collect it, we will only do so where it is reasonably necessary for our services and you have consented, or where we are otherwise permitted or required by law.

3.8 Government related identifiers

Some of the information we collect includes government related identifiers, such as your driver licence number, passport number or tax file number. We do not use or disclose a government related identifier except where the Australian Privacy Principles permit, for example where it is reasonably necessary to verify your identity, and we do not adopt a government related identifier as our own way of identifying you. We handle tax file number information in accordance with the Privacy (Tax File Number) Rule 2015 (see section 7).

3.9 If you do not provide your personal information

If you choose not to provide the personal information we ask for, we may be unable to verify your identity, accept you as a client, or provide some or all of our services to you.

4. How we collect your personal information

Where it is reasonable and practicable, we collect personal information directly from you. We collect it in the following ways.

1. Directly from you, when you contact us, make an enquiry, engage our services, complete our onboarding or instruction forms, or correspond with us by email, telephone or in person.
2. Through this website, including our enquiry and subscription forms, and through cookies and similar technologies (see section 11).
3. Through our identity verification process, which may involve a third-party identity verification provider acting on our behalf (see section 6).
4. From third parties, where you have authorised this or where we are otherwise permitted by law, such as your accountant, solicitor, mortgage broker or other adviser, your representatives, and publicly available sources and government registries.

We collect only the personal information that is reasonably necessary for our functions and activities, including providing our services, verifying your identity and meeting our legal obligations.

4.1 Unsolicited personal information

If we receive personal information about you that we did not ask for, and we could not have collected it under the APPs, we will destroy or de-identify it as soon as practicable, unless it is contained in a Commonwealth record or the law requires us to keep it.

5. Why we collect, hold, use and disclose your personal information

We collect, hold, use and disclose your personal information for purposes connected with our business and our services, including to:

• provide our property tax, accounting, structuring, asset protection and related advisory services to you;
• verify your identity and carry out customer due diligence as required under the AML/CTF Act;
• meet our legal, regulatory and professional obligations, including to AUSTRAC, the Australian Taxation Office and the Tax Practitioners Board;
• communicate with you, respond to your enquiries and manage our relationship with you;
• administer our business, including engagement, billing, record-keeping and quality assurance; and
• where you have consented or where the law permits, send you information and updates about our services (see section 5.2).

We will only use or disclose your personal information for the purpose for which it was collected, a related purpose you would reasonably expect, a purpose you have consented to, or as otherwise permitted or required by law.

5.1 Holding your information

We hold your personal information for as long as we need it for the purposes described in this policy, and for as long as we are required to keep it by law. Section 8 explains how we hold and protect it, and how long we keep it.

5.2 Direct marketing

From time to time we may send you information about our services, including by email and, where you have given SMS consent, by text message. We do this in accordance with the Spam Act 2003 (Cth). You can ask us to stop sending you marketing communications at any time, by using the unsubscribe function in the message or by contacting us using the details in section 19. We do not use or disclose sensitive information for direct marketing, and we do not sell your personal information.

6. Identity verification and our AML/CTF obligations

As a reporting entity under the AML/CTF Act, we are required to identify and verify our customers before we provide certain services, and to carry out ongoing customer due diligence while we act for them. This section explains how we handle the personal information involved.

6.1 What we collect and verify

We collect identification information about you and verify it, for example against a reliable and independent source. Where our client is a company, trust or other entity, we also identify the individuals associated with it, including its beneficial owners. Where we are required to do so, we consider and verify the source of funds or source of wealth involved in a transaction, with particular care where funds are personal borrowings.

6.2 We collect only what is reasonably necessary

We collect only the personal information that is reasonably necessary to verify your identity and to meet our obligations under the AML/CTF Act. We do not collect more identification information than we need for that purpose.

6.3 We keep the verification record, not your identity documents

Once we have verified your identity, we keep a record of that verification. The record includes the relevant details we relied on, such as your name, date of birth and residential address, the type, number and expiry of the identification document, and the method and outcome of the verification. We do not retain copies of your identification documents once your identity has been verified and the verification recorded. Any copies created during the process are destroyed.

6.4 Ongoing monitoring

While we act for you, we carry out ongoing customer due diligence. This may include keeping your information up to date and reviewing transactions and the services we provide, so that we can meet our obligations under the AML/CTF Act.

6.5 Identity verification providers

We may carry out identity verification using a third-party identity verification provider. Where we do, the provider acts on our behalf and is required to handle your personal information only for that purpose and in accordance with applicable privacy laws.

7. Tax file numbers

Because we provide tax services, we may collect and use your tax file number. We handle tax file number information in accordance with the Privacy Act and the Privacy (Tax File Number) Rule 2015. We collect, use and disclose your tax file number only for lawful tax-related purposes, we take reasonable steps to protect it, and we do not use it to identify you for any other purpose. You are not required by law to give us your tax file number, although this may affect the services we can provide and your tax position.

8. How we hold and protect your personal information

8.1 How we hold it

We hold personal information in electronic form in our practice management, accounting and document systems, and, where relevant, in physical form. We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

8.2 The steps we take

These steps include storing information in secure systems, restricting access to information to those who need it to do their work, requiring our personnel and service providers to keep information confidential, and securing the environments in which our work is carried out. No method of transmission or storage is completely secure. While we take reasonable steps to protect your personal information, we cannot guarantee its absolute security.

8.3 How long we keep it

We keep personal information for as long as we need it for the purposes set out in this policy, and for as long as the law requires. We are required to keep certain records under the AML/CTF Act, including records of customer identity verification, for seven years. We are also subject to record-keeping obligations under tax and other laws.

8.4 Destroying and de-identifying information

We take reasonable steps to destroy or de-identify personal information when we no longer need it for any purpose for which it may be used or disclosed under the APPs, and we are not required by law to keep it.

9. How and to whom we disclose your personal information

We may disclose your personal information to the following, for the purposes set out in this policy.

1. Our service providers, including our information technology, software, hosting and document storage providers, any identity verification provider we engage, and our email and client communication providers. These providers are required to protect your information and to use it only for the purposes for which we engage them.
2. Government agencies and regulators, including AUSTRAC, the Australian Taxation Office and the Tax Practitioners Board, where we are authorised or required by law to do so.
3. Your other advisers or representatives, such as your solicitor, mortgage broker or financial adviser, where you have authorised this.
4. Other parties where you have consented, or where we are otherwise permitted or required by law.

We do not sell your personal information. Section 10 explains how your information is held and accessed outside Australia.

10. Where your information is held and overseas handling

We operate through personnel located in the Philippines. As a result, the personal information we hold is accessed, handled and stored overseas, in the Philippines. The Privacy Act applies to this information in full, because we are an Australian company and the Act applies to our handling of personal information wherever it occurs. We take reasonable steps to keep the offshore environment in which we work secure. This handling is carried out by us, through our own personnel, rather than by disclosing your information to a separate organisation overseas.

Some of our service providers may also store or process personal information outside Australia. For example, the analytics tools we use on this website (see section 11) may process website usage information overseas. Where we disclose personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, and we remain accountable for it.

If we later engage a separate overseas provider to carry out part of our customer due diligence, such as a third-party identity verification provider that stores information in another country, we will take reasonable steps to protect that information and we will update this policy to identify the countries involved.

11. Cookies and our website

11.1 Information collected through this website

When you visit this website, we may collect information about your visit, such as your IP address, device and browser information, the pages you view and how you use the site. When you complete an enquiry or subscription form, we collect the information you provide, which may include your name, email address, telephone number and, where you give it, your SMS consent.

11.2 Cookies and analytics

We use cookies and similar technologies, including tag management and analytics tools such as Google Tag Manager and Google Analytics, to help this website function and to understand how it is used. You can set your browser to refuse some or all cookies, or to alert you when cookies are being used, although some parts of the website may not work properly as a result.

11.3 Third-party links

This website may contain links to other websites. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.

12. Automated decision-making

We may use automated tools to assist with parts of our processes, such as identity verification. Where automated tools are used, a person remains responsible for any decision that significantly affects you. From 10 December 2026, additional transparency requirements about automated decision-making apply under the Privacy Act, and we will update this policy to reflect those requirements.

13. Keeping your information accurate

We take reasonable steps to make sure the personal information we collect, use and disclose is accurate, up to date, complete and relevant. Please let us know if your details change, or if you believe the information we hold about you is not accurate, so that we can correct our records.

14. Accessing and correcting your personal information

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact us using the details in section 19.

We will respond to your request within a reasonable period. We may need to verify your identity before giving you access. There is no charge for making a request, although we may charge a reasonable fee for giving access in some circumstances, and we will tell you about any fee in advance. If we refuse access or correction, we will tell you why in writing, except where it would be unreasonable to do so, and how you can complain.

15. Dealing with us anonymously

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym, for example when making a general enquiry. In many cases, however, we will be unable to provide our services or meet our obligations under the AML/CTF Act unless you identify yourself and we verify your identity.

16. Making a privacy complaint

If you have a concern or complaint about how we have handled your personal information, please contact us using the details in section 19. We will acknowledge your complaint and respond within a reasonable period, usually within 30 days. We may ask you for further information to help us investigate.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

• Website: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

17. Notifiable data breaches

We have procedures in place to identify, contain and assess data breaches. If a data breach involving your personal information is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act.

18. Changes to this policy

We may update this policy from time to time to reflect changes in our practices or in the law. The current version will be available on this website. We will provide a copy of this policy free of charge on request, and in an alternative format if you need one. This policy is effective from 1 July 2026.

19. How to contact us

If you have any questions about this policy, or you wish to access or correct your personal information or make a complaint, please contact us:

Property Tax Solutions Pty Ltd
Attention: The Privacy Officer
Post: 470 St Kilda Road, Ground Floor, Melbourne VIC 3004
Email: michael.armstrong@propertytaxsolutions.com.au
Telephone: +61 3 8080 9254