SECTION 1 - INTRODUCTION

Lincolns (ACN 93 100 932 431) offers accounting services in Australia.

In the course of our business in Australia, we collect personal information. This privacy policy has been developed to ensure that such information is handled appropriately.

We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way that personal information must be treated.

This privacy policy also incorporates our policy on managing credit information (see Section 7).

Who does the privacy policy apply to?

This policy applies to any person in relation to whom we currently hold, or may in the future collect, personal information.

What information does the privacy policy apply to?

This policy applies to personal information. In broad terms, 'personal information' is information or opinions relating to a particular individual who can be identified.

Information is not personal information where the information cannot be linked to an identifiable individual.

SECTION 2 - HOW DO WE MANAGE THE PERSONAL INFORMATION WE COLLECT?

We manage the personal information we collect in numerous ways, such as by:

• implementing procedures for identifying and managing privacy risks;

• implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;

• providing staff with training on privacy issues;

• appropriately supervising staff who regularly handle personal information;

• implementing mechanisms to ensure any agents, contractors or service providers who deal with us comply with the APPs;

• implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints; and

• appointing a privacy officer within the business to monitor privacy compliance.

Subject to our professional obligations, we will take reasonable steps to destroy or de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.

In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us. If you wish to use a pseudonym or remain anonymous you should notify us when

making first enquiries or providing initial instructions. We will use our best endeavours to deal with your request, subject to our professional obligations and ability to perform the accounting services for you without using your name. In most cases, our professional obligations will require you to deal with us using your real name.

SECTION 3 - WHAT KINDS OF INFORMATION DO WE COLLECT AND HOLD?

Personal information

The personal information we may collect and hold about you differs, depending on whether you are a client, service provider, contractor, agent or a prospective employee or prospective service provider or contractor, but may include:

• sensitive information (see below);

• contact information;

• financial information;

• date and place of birth;

• employment arrangements and history;

• tax returns and tax file numbers;

• insurance information;

• credit information;

• banking details; and

• any other personal information required to perform the accounting services for you or to engage you.

Sensitive information

‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.

We may collect sensitive information if it is relevant in providing accounting services or engaging you, which may include any of the following:

• health information;

• racial or ethnic origin;

• criminal records;

• membership of professional or trade associations;

• membership of trade unions;

We will not collect sensitive information without the individual’s consent to which the information relates unless permitted under the Privacy Act.

SECTION 4 - HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?

Our usual approach to collecting personal information is to collect it directly from the individual concerned directly or through our website.

We may also collect personal information in other ways, such as:

• from government bodies (such as the Australian Taxation Office and the Australian Securities and Investment Commission);

• from paid search providers and public registers;

• through referrals from individuals or other entities;

• from your other advisers;

• from your related entities;

• from banks and financial institutions;

• from other credit providers;

• through marketing and business development events; and

• from third party providers, suppliers and creditors.

How do we hold personal information?

Our usual approach to holding personal information includes holding that personal information:

• physically, at our premises;

• electronically;

• on secure online servers;

• on a private cloud; and

• by a third party data storage provider

We secure the personal information we hold in numerous ways, including:

• using systems to limit access;

• using secure servers to store personal information;

• using unique usernames, passwords and other protections on systems that can access personal information; and

• holding certain sensitive documents securely.

SECTION 5 - WHY DO WE COLLECT, HOLD, USE OR DISCLOSE PERSONAL INFORMATION?

We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided or the individual from whom we are collecting the information but is generally as follows:

• in the case of clients – to provide accounting services to you or your business;

• in the case of contractors, service providers, and agents – to assist us in providing our services to our clients;

• in the case of potential employees and potential service providers and contractors – to assess your suitability for employment or engagement.

Personal information may also be used or disclosed by us for secondary purposes that are within an individual’s reasonable expectations and that are related to the primary purpose of collection.

We may also collect and use clients’ personal information:

• to keep records of transactions to assist in future enquiries and enhance our client relationship with you;

• to verify your identity;

• to send you special offers in relation to our services;

• to provide you with updates and alerts that are relevant to you or your business;

• to refer you to other advisers; and

• to invite you to events.

We may collect and use contractors’, service providers’ and agents’ personal information:

• to conduct checks to ensure that the contractor, service provider or agent and prospective employee, contractor and service provider can perform or is performing the services to our standards; and

• for payment purposes.

We may disclose personal information to:

• contractors, service providers and agents including third party technology providers we engage from time to time, such as our data storage providers and email filter providers;

• employers of individuals;

• government bodies (such as the Australian Taxation Office and the Australian Securities and Investment Commission);

• our external auditors;

• banks;

• your advisers or other referral partners in order to provide the accounting services to you, or to assist our functions or activities (such as law firms);

• our related entities; and

• insurance providers and brokers.

Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.

SECTION 6 - WILL WE DISCLOSE PERSONAL INFORMATION OUTSIDE AUSTRALIA?

We may disclose personal information outside of Australia if you provide specific instructions for us to do so or if we engage overseas entities to assist us to provide accounting services to you in the most efficient way.

We do not generally disclose your personal information to overseas recipients, apart from through the use of cloud providers or other outsourced information technology services which may have data centres located overseas.

For example, we may choose to use software providers including: