Privacy Policy

1. Introduction

At Martin & Martin Consulting Pty Ltd (“Martin & Martin”), we are committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, use, disclose, store and protect your personal information when you engage our services or interact with us. By using our services, you agree to the terms of this Privacy Policy.

2. What Personal Information We Collect

We may collect the following types of personal information, depending on your engagement with us:

• We may also collect sensitive information, such as health or membership data, where required and only with your consent or where authorised or required by law.
• Full name, date of birth, address, phone number and email address
• Tax File Number (TFN), ABN, bank account details
• Financial, superannuation and employment information
• Information related to your business, shareholdings, or trust structures
• Information about your spouse and dependants (for tax purposes)
• Any other information required to provide our services
• We may also collect sensitive information, such as health or membership data, where required and only with your consent or where authorised or required by law.

3. How We Collect Personal Information

We collect personal information in several ways, including:

• Directly from you, such as during meetings, phone calls, emails or forms
• Through third parties, such as the ATO, ASIC, financial institutions and legal representatives
• From cloud-based applications we use to deliver services
• From publicly available sources or government registers
• Through our website or online communications
• For AML/CTF purposes, from identity verification providers, government registers and databases, sanctions and politically exposed persons (PEP) screening providers, beneficial ownership registers and other third-party sources where necessary to complete customer or personnel due diligence

4. Why We Collect and Use Personal Information

We collect and use your information for purposes including:

• Providing accounting, tax, business advisory and compliance services
• Complying with our legal, regulatory and professional obligations, including our obligations as registered tax agents under the Tax Agent Services Act 2009
• Communicating with you and responding to your enquiries
• Managing our business, systems and professional relationships
• Conducting client due diligence and identity verification
• Sending you updates, newsletters or industry insights, which you may opt out of at any time

5. Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Obligations

Martin & Martin is subject to obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) when we provide designated services. This section explains how we collect, use and disclose personal information for AML/CTF purposes.

Identity Verification and Customer Due Diligence

We may be required to collect and verify personal information about clients and, in some cases, their associates, beneficial owners or authorised representatives before or during the provision of certain services. These checks are known as customer due diligence (CDD) and may be required before we can provide those services.

For CDD purposes, we may collect:

• Name, date of birth and residential address
• Identity document details
• Beneficial ownership and control information
• Information used to assess AML/CTF risk, including politically exposed person (PEP) status and sanctions screening results
• Other information required by the AML/CTF Act or related rules

Disclosure to AUSTRAC and Other Authorities

We may disclose personal information to AUSTRAC, regulators, law enforcement agencies, verification providers and screening providers where required or authorised for AML/CTF compliance. This may include reports required under the AML/CTF Act, such as suspicious matter reports, threshold transaction reports and international funds transfer instructions.

Tipping-Off Restrictions

The AML/CTF Act restricts what we can disclose about suspicious matter reports and related investigations. Where these restrictions apply, we may be unable to provide a collection notice, respond to some access or correction requests, or communicate in the usual way.

Personnel Due Diligence

We may also collect and handle personal information about employees, contractors and other personnel for AML/CTF personnel due diligence. This information is handled in accordance with the Privacy Act and our AML/CTF obligations.

Data Minimisation for AML/CTF Purposes

We limit the collection, use and disclosure of personal information for AML/CTF purposes to what is reasonably necessary to comply with our legal obligations and carry out related business activities.

6. Disclosure of Personal Information

We may disclose your personal information to:

• Government agencies (e.g. ATO, ASIC)
• Third-party software providers (e.g. Xero, FYI Docs, BGL, Microsoft 365, FuseSign, ATOmate)
• Financial institutions, superannuation funds, or insurance providers
• Your authorised representatives or legal advisers
• Our IT service providers and external contractors (including offshore accounting staff)
• Our professional advisers, insurers, and legal representatives
• Third parties when required by law or with your consent

All third parties are required to handle your information confidentially and securely. We do not sell or trade your personal information.

7. Cross-Border Disclosure

Some of your personal information may be accessed by our offshore accounting staff located in the Philippines or stored in cloud systems with data centres located outside Australia.

Where this occurs, we take reasonable steps to ensure that overseas recipients protect your personal information in accordance with Australian privacy laws or equivalent safeguards, including through confidentiality agreements, vendor privacy policies and data security protocols.

8. Data Security and Storage

We store your personal information securely using physical, electronic and procedural safeguards, including staff privacy training, to ensure confidentiality and proper handling of information.

We retain your information only for as long as necessary to fulfil the purposes outlined in this policy or as required by law, including retention periods under taxation and financial services legislation.

9. Access and Correction

You have the right to request access to the personal information we hold about you and to request corrections if it is inaccurate, out-of-date, incomplete, or misleading.

To make a request, please contact us using the details in section 14. We will respond within a reasonable period and may need to verify your identity. We do not charge a fee for access or correction unless the request is complex or resource-intensive.

10. Complaints

If you believe we have breached your privacy or mishandled your personal information, you can contact us using the details below. We take all complaints seriously and will respond within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | Phone: 1300 363 992

11. Notifiable Data Breaches

In the event of an eligible data breach, where personal information is lost, accessed or disclosed without authorisation and is likely to result in serious harm, we will:

• Promptly assess the breach
• Notify affected individuals and the OAIC
• Take steps to contain and remediate the breach

12. Direct Marketing

We may use your personal information to send newsletters or service updates. You can opt out at any time by clicking “Unsubscribe” in the email or contacting us directly at info@martinandmartin.com.au. We will only send marketing communications in accordance with the Privacy Act and the Spam Act.

13. Use of Cloud and Third-party Services

We conduct due diligence on all third-party providers and cloud services to ensure they meet our privacy and security standards. Contracts include obligations to protect personal information.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or your personal information, please contact:

Martin & Martin Consulting Pty Ltd

5 Theatre Place, Canterbury VIC 3126

P: 03 8809 3666

E: info@martinandmartin.com.au

W: www.martinandmartin.com.au

15. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website. We encourage you to review it periodically.

Effective Date: 1 July 2026

This Privacy Policy is intended to comply with applicable privacy laws and regulations. We are committed to maintaining high standards of privacy and security for our clients’ information.