Sammut Bulow Group Pty Ltd trading as Sammut Bulow - Privacy Policy
1. Privacy Commitment
Sammut Bulow Group Pty Ltd trading as Sammut Bulow (We, Us or Our) recognise the importance of
protecting your privacy and the personal information in our care. We have created this Privacy Policy in
order to demonstrate our firm commitment to your privacy.
This Privacy Policy represents how we manage your personal information in accordance with the Privacy
Act 1988 (Cth). Our Privacy Policy seeks to safeguard the privacy of your personal information in
accordance with the Australian Privacy Principles (APPs). This Privacy Policy sets out the kind of
information we hold and how we collect, hold, use and disclose that information (including personal
information and sensitive information). We may also agree with you from time to time other uses or
disclosures of your personal information. We will not deal with your personal information other than in
accordance with this policy unless we notify you first and obtain your consent.
This Privacy Policy also includes a link to our Credit Information Management Policy which sets out how
we collect, hold, use and disclose Credit Information to comply with our credit reporting obligations
under the Acts, the Credit Reporting Code registered under section 26S(1) of the Privacy Act 1988 (Cth).
In addition to this Privacy Policy, we may also have specific and additional privacy provisions that apply
to certain activities or promotions. In the event of any inconsistency between the provisions of this
Privacy Policy and those other specific and additional provisions, the specific and additional provisions
provided to you will apply.
By using our website, applications and services, or otherwise providing us with your information, you
consent to our collecting, holding, using and disclosing your personal information as described in this
Privacy Policy or as otherwise agreed with you.
This Privacy Policy may be amended or revised at any time. The revised Policy will take effect when it is
uploaded on our Website. This Privacy Policy represents the latest version of the Privacy Policy as at 1
October 2023.
Kinds of Information collected
2.1. We may collect both personal and sensitive information from you.
2.2. Personal information is any information about you that identifies you or by which your identity may
be reasonably determined. The kinds of personal information that may be collected from you
includes, but is not limited to, your full name, address, phone number, email address and payment
details. By collecting this personal information, we are able to contact you when necessary, identify
and protect your information from unauthorised use and provide the best possible service.
2.3. Sensitive information includes information or an opinion about an individual’s race, religion,
political or trade association, among others. The kinds of sensitive information we may collect from
you can include, but is not limited to your tax file number, medical history or affiliations. We will
only collect sensitive information in circumstances where you have consented to the collection and
if the information is reasonably necessary for us to provide our services.
Collection of Personal Information
3.1. We will collect your personal information directly from you, online and from third parties (including
our affiliates). You consent to us collecting your personal information from you, online and from
third parties (including our affiliates). This consent is an ongoing consent until you with withdraw
that consent by notice to us in writing.
3.2. We may collect your information to provide services to you and to ensure that you receive the best
possible service, to market to you (including opportunities from our affiliates that we identify may
be of interest to you), to provide to our affiliates to ensure that our affiliates can provide services to
you and to ensure that you receive the best possible service from our affiliates. If we do not collect
personal information about you this will affect our ability to provide services to you, our ability to
market to you about opportunities that we think will benefit you and our affiliates’ ability to provide
services to you.
3.3. Sources we will collect personal information about you include:
• from you (including via online enquiry forms you submit, our direct discussions with you, any
emails, blogs, letters, faxes or other correspondence you send to us and when you subscribe to
our online publications);
• if you have created an online account including an account to facilitate file transfers or payment
information with us, from your use of that online account;
• from any person authorised by you to provide such personal information to us (such as your
professional advisors or personal representatives);
• from third party contractors and suppliers we engage to help us provide services (including our
affiliates);
• from external sources where the information is publicly and readily available;
• from our affiliates who hold personal information about you to help us and our affiliates provide
services to you;
• from third parties where it is more convenient or otherwise unreasonable or impractical to
collect such personal information from you directly (including our affiliates); and
• from third parties that are government organisations (such as the Australian Securities and
Investments Commission or the Australian Taxation Office).
3.4. As an example, and without limiting the types of personal information we collect, we may collect
the following personal information (a) name, address, and contact details such as telephone
number and email address, (b) details of your interests in or ownership of entities or control of
trusts, and (c) accounting and taxation information such as your tax file number, bank account
details, credit card details and details of your investments.
3.5. We will only collect information relating to your tax file number for purposes authorised by law.
You are not obliged to provide your tax file number to us but if you fail to do so, we may be unable
to provide you with the services you require from us.
3.6. Through use of our Website, we may automatically record details including your internet address,
domain name and the date and time of your visit to our Website (including the web pages viewed),
your browser and operating system. If you link to our Website from another website then that
information may also be recorded. We may also use cookies that are small pieces of information
that allow an organisation to track websites browsed by you. If you do not want to allow cookies to
be used to collect information, you may disable cookies on your computer by changing the security
and privacy settings in your browser. However, if you do disable cookies, you may not be able to
interact with our website or take advantage of the improved functionality that cookies enable.
3.7. Where you provide us with personal information of third parties (for example, your spouse) you
warrant to us that the relevant third party has consented to you disclosing their personal
information to us.
3.8. We endeavour not to collect personal information by unlawful means or means that are unfair.
Use of Personal Information
4.1. How we use your personal information varies based on the services we are providing. We will only
use your personal information for the purpose it was obtained unless you consent to its use for
another purpose or where an exception applies under the Act.
4.2. Generally, the reason we may use your personal information include:
• as necessary for us or our affiliates to provide services to you;
• in administering our Website;
• in order to enable your access to our Website services;
• to perform due diligence and conflict checks prior to us or our affiliates agreeing to provide
services to you;
• to send you marketing communications from us or from our affiliates;
• for customer relationship management purposes and to supply to you the services which you
have requested or we think are relevant to you (including services that are offered by our
affiliates) having regard to our knowledge of you and discussions with you;
• to send you statements and invoices and collect payments from you;
• for recruitment purposes;
• to analyse client needs and improve the services we and our affiliates provide;
• for audit, regulatory and compliance purposes;
• for industry accreditation purposes;
• for accounting and administrative purposes (including to process transactions, provide
accounting services, facilitate our internal business operations and comply with our legal or
regulatory obligations); and
• for other purposes related to our provision of business advisory services to you, including
recommending to you or helping to facilitate the provision of services to you by our affiliates.
4.3. We may use personally identifiable information in a summative form to improve our services and
make them more responsive to the needs of our customers. This statistical compilation and
analysis of information may also be used by us or provided to others as a summary report for
marketing, advertising or research purposes.
4.4. Information other than personal information collected when you visit our Website may be used to
monitor usage of and decide how to improve and promote our Website, products and services
(including online advertising).
4.5. We may also use the information collected to provide to you information (via email, facsimile or
post) that has been requested by you personally. If at any time you receive material that you did
not request and do not want to receive any such material anymore, please see paragraphs 7 and
13 of this Privacy Policy.
Disclosure of Personal Information
5.1. We may disclose your personal information, and you consent to the disclosure of your personal
information:
• to our contractors, agents and service providers (for example, information technology
contractors, debt collection agencies, event managers and recruitment and human resources
consultants) but only (a) for the purpose of providing services to you, (b) as necessary to
facilitate the operation of our business, and/or (c) for the purpose of storing your personal
information;
• to the Australian Taxation Office, the Australian Securities and Investments Commission and
other government bodies as required by law or as necessary to provide services to you;
• to our affiliates for the purpose of those our affiliates providing you with information about their
services and promotions and so our affiliates can provide services to you;
• as required or authorised by law or to meet our professional standards;
• where disclosure is necessary to prevent or lessen a serious threat such as public health or
safety;
• to any person with your consent;
• where your information is publicly available;
• where your information has been de-identified in a form or for statistical or research purposes;
• in connection with any sale of us or any affiliate of ours; and
• to our professional advisers but only so they can advise us in respect of the same.
Unless you have otherwise consented, we will not sell, transfer, assign or rent your personal
information. In order to operate the Website and to deliver to you the service which you have
requested, we may sometimes share your personal information with an affiliate of ours, which is
necessary to deliver your requested items, to market to you or provide services to you. We will
endeavour to make sure that our disclosure to our affiliates only occurs where the affiliate has a
privacy policy which complies with the APPs.
5.3. We may need to disclose your personal information where you have consented to us doing so in
providing you with our service or where disclosure is necessary to achieve the purpose for which it
was submitted.
5.4. We may need to disclose or transfer your personal information if we or our affiliates are acquired
or merged with another entity.
5.5. We will attempt to ensure that we do not disclose your personal information to a third party
(including our affiliates) where consent for such disclosure has not been given.
5.6. Please note that if at any time we are required by law to release information about you, we must
cooperate fully. We may also disclose your information in order to investigate, halt, or take action
regarding illegal activities.
Collection, use and disclosure of Sensitive Information
6.1. We will only collect sensitive information from you directly as reasonably necessary to provide
services to you and so that our affiliates can provide service to you or otherwise as permitted by
the Act. You consent to our using of your sensitive information for this purpose.
6.2. As an example, and without limiting the types of sensitive information we collect, we may collect
the following sensitive information (a) tax file number and (b) medical history.
6.3. We will only collect your tax file number for a purpose permitted by law and otherwise for us or an
affiliate to provide services to you. You are not required to provide us or our affiliates with your tax
file number, however, if you do not provide us with your tax file number, we or our affiliates may
not be able to provide services to you.
6.4. Subject to paragraph 6.5, sensitive information will only be disclosed in accordance with the Act as
follows: (a) for the primary purpose for which it was collected, (b) for a secondary purpose that is
directly related to the primary purpose, which may include ensuring that us or our affiliates can
provide services to you or (c) as required by law.
6.5 Information regarding your tax file number will only be disclosed to you personally and according
to relevant laws (including, where you are an individual, in compliance with the Privacy (Tax File
Number) Rule 2015 made under section 17 of the Act).
Direct marketing
7.1. We may use or disclose your personal information for direct marketing purposes, and you consent
to us use or disclose your personal information for direct marketing purposes, being:
• to promote our services and the services of our affiliates and provide you with information and
marketing materials about other services provided by us and our affiliates that may be of interest
to you;
• to provide information relevant to you, your type of business or other area of expertise or
interest; and
• to provide you with the opportunity to attend complimentary reviews by our affiliates, seminars,
conferences or other events that may be of interest to you.
7.2. If you subscribe to receive information from our Website, then your e-mail address and other
information that you provide will be recorded. We may, from time to time, use your personal
information, such as your address and contact details, to provide you with marketing updates or
information about the services that we and our affiliates offer.
7.3. If you do not wish to receive Direct Marketing communications from us or our affiliates, you can
‘opt out’ by clicking the ‘Unsubscribe’ link in our or our affiliates emails or other electronic
communications, or sending an email to us at the contact details in paragraph 13 below with your
contact details requesting that you no longer receive Direct Marketing materials from us. We will
remove you from our Direct Marketing database as soon as reasonably practicable after receiving
a request but in any event, within 30 days of receiving such a request.
8. Use of pseudonyms and unique identifiers
In general, you are not required to provide personal information to us. Where reasonably practicable,
you may have the option of not identifying yourself, or of using a pseudonym, when dealing with us in
relation to a particular matter. However, if you wish to receive information about our services, events,
industry updates or to apply for employment, it may not be practical for you to use a pseudonym or
otherwise not identify yourself and we may require you to provide certain personal information or Credit
Information. If you do not provide some or all of the personal information or Credit Information
requested, we may not be able to provide you with some or all of the services you request.
9. Cross-border disclosure
9.1. Personal, sensitive and Credit Information which we collect may be stored and processed in and
transferred between the countries abroad in which we have service providers. This disclosure
enables the use of your information in accordance with this Privacy Policy.
9.2. Your information may be held in our servers located in Australia. Your information may also be
accessible to our contractors, agents and service providers located in America, and the Philippines
and where our contractors, agents and service providers utilise offshore providers, to any
jurisdiction that they may use.
9.3. You agree to such cross-border transfers of your personal information.
9.4. We also use a number of different software and tools for storing and sharing your information to
our affiliates, third party service providers (including our affiliates), contractors or agents. This can
include, but is not limited to, the use of internal search engines, electronic file transfer systems and
online payment facilities.
10. Collection of Credit Information and use and disclosure of Credit Information
Please refer to our Credit Information Management Policy as to how we will collect, use and disclosure
your Credit Information.
11. Holding and security of your Personal Information and Credit Information
11.1 We endeavour to take all reasonable steps to keep secure any personal or sensitive information
which we hold about you, and to keep this information accurate and up to date.
11.2 However, as the internet is not a secure environment, any information that you send to us via that
method is sent at your own risk.
11.3 The security and privacy of your personal information is our priority. We may store your personal
information and Credit Information in hard copy or electronic format. We take reasonable steps
to:
• ensure that any personal information or Credit Information we hold or disclose about you is up
to date, complete and correct; and
• protect your personal information and Credit Information from misuse, interference, loss, and
unauthorised access, modification and disclosure using electronic and physical security
measures such as:
(a) we lock our premises and have reception desks that are staffed to minimise the risk of
unauthorised access to our premises;
(b) placing passwords and varying access levels on databases to limit access and protect
electronic information; and
(c) the use of firewalls, encryption, passwords and digital certificates.
11.4 We will destroy or delete any of your personal information or Credit Information which we no longer
need to retain noting that we are required by law to retain certain information for a number of years
after we have ceased providing the services. If you email us any information (including personal
information or Credit Information), it is sent at your own risk as it may not necessarily be secure
against interception.
12. Accessing and correcting Personal Information and Credit Information
12.1.We rely on the accuracy of the personal information and Credit Information you provide to us.
12.2.We may take steps to correct information held if we are satisfied that the information is inaccurate,
out-of-date, incomplete, irrelevant or misleading.
12.3. On your request, except to the extent that we are lawfully able to refuse such a request, we will
provide you with access to personal information and Credit Information that we hold about you. All
requests about the personal information or Credit Information that we hold should be made by
email or in writing to us (see paragraph 13 of this Privacy Policy for our contact details). We will try
to respond to your request within a reasonable period.
12.4. If you satisfy us that personal information or Credit Information that we hold about you is
misleading, inaccurate, out of date or incomplete, except to the extent that we are lawfully able to
refuse such a request, we will correct the personal information and Credit Information that we hold
about you. If it is reasonable and practicable to do so, we will give you access to your personal
information and Credit Information in the manner that you request. We do not generally charge for
providing such access but may do so in certain circumstances.
12.5. In the event that we deny access to or refuse to correct your personal information or Credit
Information that we hold, we will provide you with written reasons and the mechanisms available
to complain about such refusal.
13. How to access and correct your Personal Information
13.1. You may access and/or request that your personal information be edited or corrected by contacting
our local office or by writing to one of the following:
Email: admin@thesbgroup.com.au
In writing: Brad Bulow
Sammut Bulow Group Pty Ltd, Level 1, 164 Brisbane Street, Ipswich Qld 4305
13.2. By informing us of any changes to your personal information, you allow us to ensure that your
information is accurate, up-to-date and complete.
13.3. There are no fees associated with making a request to access or correct your information. We may,
however, charge a reasonable fee for processing the request, to account for locating the
information and supplying it to you.
14. Third party websites
14.1. When you leave our Website, you will be going to websites that are beyond our control. Our Policy
does not apply to third party websites (including the websites of our affiliates).
14.2. We confirm that this Privacy Policy only governs the handling of your personal information by us.
We encourage you to read the privacy policies of any third party websites (including the websites
of our affiliates) before disclosing or consenting to the disclosure by us of any personal information
to those entities.
15. Changes to policy and complaints
15.1. If you believe that we have breached our privacy or credit reporting obligations under the Act, or
you are unsatisfied with the manner in which we have dealt with your personal information, you
may make a complaint by emailing or writing to us at:
Email: admin@thesbgroup.com.au
In writing: Brad Bulow
Sammut Bulow Group Pty Ltd, Level 1, 164 Brisbane Street, Ipswich Qld 4305
15.2. We will use our best endeavours to, within fourteen days, respond to you and attempt to resolve
with you your issues as they pertain to your personal information.
15.3. If you are still unsatisfied, you may wish to direct your complaint to the Office of the Australian
Information Commission at http://www.oaic.gov.au/ or alternatively:
Phone: 1300 363 992
In writing: The Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
16. Updating this Policy
We may update this Privacy Policy from time to time by positing a new version on our website. Please
check this page to ensure that you are familiar with any changes that may have arisen.
17. Meanings
In this Privacy Policy:
17.1. Act mean the Privacy Act 1988 (Cth);
17.2. Affiliates means any entity in which we (1) hold any interest (whether directly or indirectly) or (2)
have at least one common director or (3) have a relationship with that is used for the purpose of
providing better services to our clients.
17.3. Credit Information includes identification information (for example, name, date of birth, driver’s
licence number, current and recent addresses and employment details), historical details of credit
(including type and amount of credit sought or obtained) and repayment history, information about
applications for credit, information about defaults and payment arrangements, details of
insolvency proceedings, bankruptcy agreements, judgements and arrangements with creditors,
information relating to activities and credit worthiness in Australia, information recorded on the
National Personal Insolvency Index and opinions of credit providers regarding serious credit
infringements;
17.4. Credit Information Management Policy means our Credit Information Management Policy as
amended from time to time and available at https://www.thesbgroup.com.au/credit-informationmanagement-
17.5. Personal Information means information (including an opinion) about an individual whose identity
is apparent or can reasonably be ascertained from the information whether true or not and whether
or not recorded in a material form;
17.6. Sensitive Information has the meaning given by the Act and includes Personal Information which
relates to an individual’s racial or ethnic origins, religious beliefs or affiliations, trade association,
trade union membership, sexual orientation, criminal record and information as to an individual’s
health or biometric information.
17.7. Website means all of the pages located on the website you are currently viewing, being
https://www.thesbgroup.com.au/ which relate to us.
Version 1: 1 October 2023
QUICK LINKS
CONTACT DETAILS
Postal: PO Box 2242 NORTH IPSWICH QLD 4305
Office: Level 1, 164 Brisbane St Ipswich, Queensland 4305
Phone: (07) 3812 3400
Email: admin@thesbgroup.com.au
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