Privacy policy.

1. About this policy

Trinity Partners Taxation Service Pty Ltd (Trinity Partners, we, us, our) provides accounting, taxation, bookkeeping, payroll, CFO and advisory, and related digital services from 854A Pittwater Road, Dee Why NSW 2099.

We respect your privacy. This policy explains how we collect, hold, use and disclose personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), the Privacy (Tax File Number) Rule 2015, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), and our confidentiality obligations as registered tax and BAS agents under the Tax Agent Services Act 2009 (Cth) Code of Professional Conduct.

This policy applies to our clients and prospective clients, their related entities, employees, beneficiaries and associates, visitors to trinitypartners.com.au, suppliers, and job applicants.

2. What personal information we collect

Depending on the services we provide, we may collect:

• Identity and contact details — name, date of birth, address, phone, email, occupation, and signatures.
• Identification and verification information — details from driver licences, passports, Medicare cards or other documents, and the results of identity verification checks.
• Tax and government identifiers — tax file numbers (TFNs), ABNs, ACNs, director IDs, and ATO, ASIC and AUSTRAC reference numbers.
• Financial information — income, assets and liabilities, bank and investment statements, loans, superannuation and SMSF details, property and share records, business accounts and transactions.
• Employment and payroll information — for our payroll clients: employee names, contact details, TFN declarations, pay rates, leave, superannuation fund details and bank account details for salary payments.
• Family and related-party information — spouse, dependants, trust beneficiaries, company officeholders and shareholders, where needed for tax, trust, company or AML/CTF purposes.
• Sensitive information — only where reasonably necessary and with your consent or where the law allows, for example health information relevant to a medical expense claim or disability-related concession, or membership of a professional or trade association.
• Payment information — direct debit and billing details processed by our payment provider (see section 7). We do not store full card numbers on our systems.
• Website and communication information — enquiries and form submissions, booking details, IP address, browser and device data, cookies, and records of our emails, calls and meetings.

3. How we collect it

We collect personal information directly from you where practical — in meetings, by phone and email, through our website forms and online sign-up, through client portals, and from documents you provide.

We may also collect it from third parties where you have authorised us or the law permits, including the Australian Taxation Office (ATO), ASIC, your bank or financial institution (including bank feeds into accounting software), your employer, your previous accountant, your financial planner, mortgage broker or lawyer, superannuation funds, and identity verification providers.

If we receive personal information we did not ask for, we will decide whether we could have collected it lawfully. If not, we will destroy or de-identify it where lawful and reasonable to do so.

4. Why we collect, use and disclose it

We collect, use and disclose personal information to:

• prepare and lodge tax returns, BAS, IAS, FBT, payroll (STP) and other statutory obligations;
• provide accounting, bookkeeping, SMSF, company secretarial, CFO, advisory and training services;
• verify your identity and meet our customer due diligence, record-keeping and reporting obligations under the AML/CTF Act;
• communicate with you, including booking appointments and sending reminders about deadlines;
• act on your behalf with the ATO, ASIC, and other government agencies;
• invoice you and collect payment;
• meet our professional, insurance, quality review and legal obligations;
• manage and improve our services and website; and
• send you newsletters, tax updates and information about our services (see section 10).

We only use or disclose your information for the purpose it was collected, a related purpose you would reasonably expect, or otherwise with your consent or as required or authorised by law.

If you do not provide the information we request, we may be unable to provide our services, lodge on your behalf, or complete the identity checks the law requires before we can act for you.

5. Tax file numbers

We collect TFNs only for purposes authorised by taxation, personal assistance or superannuation law, such as lodging tax returns and processing payroll. We handle TFNs in line with the Privacy (Tax File Number) Rule 2015: we do not use TFNs to identify you for other purposes, we restrict access to staff who need them, and we securely destroy or de-identify TFN information when it is no longer required.

6. Anti-money laundering and identity verification

From 1 July 2026, accountants who provide certain "designated services" (for example, forming companies or trusts, acting as a company officeholder, or assisting with the sale or purchase of a business or real estate) are reporting entities under the AML/CTF Act. When we provide those services we must:

• verify the identity of our clients, their beneficial owners and people acting on their behalf, and in some cases the source of funds or wealth;
• conduct ongoing due diligence;
• keep records of our due diligence for seven years after the business relationship ends; and
• report certain matters to AUSTRAC.

The law may prevent us from telling you that we have made a report to AUSTRAC. We record the details needed from your identification documents rather than keeping full copies, unless another law requires us to keep a copy.

7. Who we disclose it to

We may disclose personal information to:

• government agencies, including the ATO, ASIC, AUSTRAC, the Tax Practitioners Board and state revenue offices;
• your other advisers and service providers where you have authorised it, such as financial planners, lawyers, mortgage brokers, banks, auditors and SMSF auditors;
• our professional bodies, professional indemnity insurers and quality reviewers;
• contractors and consultants who help us deliver services, bound by confidentiality obligations; and
• providers of the software and cloud services we use to run our practice, including Xero, MYOB and QuickBooks (accounting and bookkeeping); Microsoft 365 and Google Workspace (email and document storage); Stripe (direct debit payments); Calendly (appointment bookings); Fireflies.ai (meeting notes, where you have been told a meeting is being recorded); Anthropic (Claude) (AI assistant); Fly.io (hosting of our online proposal and client portal); and WordPress, Jetpack and Google Analytics (website, forms and analytics).

We do not sell personal information.

8. Overseas disclosure and cloud storage

We store most client files and emails in Australia. Some of our software providers store or process data overseas:

• Microsoft 365 (email, Teams, SharePoint and OneDrive) — stored in Australia.
• Fly.io (our online proposal and client portal) — stored in Sydney, Australia.
• Google Workspace (Google Drive and related apps) — may be stored or processed in the United States and other countries where Google has data centres.
• Fireflies.ai (meeting recordings and notes) — stored and processed in the United States.
• Anthropic (Claude) (AI assistant) — stored in the United States, and may be processed in the United States, Europe, Asia or Australia.
• Other providers listed in section 7 may also store or process data in the United States or other countries.

Before disclosing personal information overseas, we take reasonable steps to ensure the recipient handles it in a way consistent with the APPs, for example by choosing reputable providers with appropriate security and contractual privacy protections.

9. Automated decision-making and AI tools

We use software that automates parts of our work, such as bank-feed transaction coding, data extraction from receipts and invoices, and AI-assisted tools for drafting, summarising and meeting notes. A qualified member of our team reviews this work.

We do not make decisions that could significantly affect your rights or interests solely by a computer program. If that changes, we will update this policy to describe the kinds of personal information used and the kinds of decisions made, as required by the Privacy Act from 10 December 2026.

We do not enter TFNs or identity documents into public AI tools, and we only use AI tools under business terms that do not permit your information to be used to train the provider's models.

10. Marketing

We may send you tax updates, newsletters and information about our services by email, SMS or post. You can opt out at any time using the unsubscribe link or by contacting us. We comply with the Spam Act 2003 (Cth). Opting out of marketing does not stop service-related messages, such as lodgement reminders.

11. Our website and cookies

Our website uses cookies and similar technologies, including Google Analytics and Google Tag Manager, to understand how visitors use the site and to improve it. This information is generally aggregated and does not identify you. You can disable cookies in your browser, although parts of the site may not work as intended.

When you complete a form, book a call or sign up for a plan on our website, we collect the details you enter so we can respond and provide the service. Our website may link to third-party sites (such as Calendly and Stripe); their own privacy policies apply.

12. Security and retention

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. Our measures include multi-factor authentication, access restricted by role, encrypted cloud systems, secure client portals for sending documents, staff confidentiality obligations and training, and secure destruction of paper records.

We keep personal information for as long as needed for the purpose it was collected and to meet legal and professional requirements — generally at least five years for tax records and seven years for AML/CTF records and client files. After that, we securely destroy or de-identify it.

Please avoid sending TFNs or identity documents by unencrypted email; ask us for a secure upload link instead.

13. Data breaches

If we experience a data breach that is likely to result in serious harm to anyone, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme, and tell you what steps you can take to protect yourself. We will also notify the ATO where a breach involves tax information.

14. Dealing with us anonymously

You can make a general enquiry without identifying yourself or by using a pseudonym. However, we need to identify you to provide professional services or act for you with the ATO and other agencies.

15. Accessing and correcting your information

You can ask to access the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Contact our Privacy Officer (section 17). We will respond within 30 days. We do not charge for a request, but may charge a reasonable fee for the cost of providing access. If we refuse a request, we will explain why in writing, unless it would be unreasonable to do so.

16. Complaints

If you believe we have breached your privacy, please contact our Privacy Officer in writing with details of your concern. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days.

If you are not satisfied with our response, you can contact:

• Office of the Australian Information Commissioner (OAIC) — www.oaic.gov.au, phone 1300 363 992
• Tax Practitioners Board — www.tpb.gov.au, for concerns about our conduct as a tax or BAS agent

17. Contact us

Privacy Officer, Trinity Partners
854A Pittwater Road, Dee Why NSW 2099
Phone: (02) 9045 1511
Email: [email protected]

18. Changes to this policy

We review this policy regularly and will publish updates on our website. This version is effective from 31 October 2026.

Liability limited by a scheme approved under professional standards legislation.