Mulcahy & Co Privacy Policy

Commitment

Mulcahy & Co, including the entities listed in Annexure A, is dedicated to providing exceptional client service while prioritising your privacy. We understand how important privacy is to you. In accordance with the Privacy Amendment (Enhancing Privacy Protection) Act 2012, we adhere to the Australian Privacy Principles (APPs) and strive to comply with them fully. For more details on privacy in Australia, please visit the Office of the Australian Information Commissioner at privacy.gov.au. This Privacy Policy outlines how we collect, use, store, disclose, and share your personal information. We recommend checking our website periodically for updates to this policy.

Your Information

As a financial service provider, Mulcahy & Co is required to gather personal information to meet certain legislative and regulatory obligations under Section 961B of the Corporations Act and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. This information may include:

• Your name, contact details, date of birth, and tax file number
• Information about your dependents and family commitments
• Your occupation and employment history
• Your financial needs and goals
• Your assets, liabilities, income, expenses, insurances, and social security entitlements

Collection

We collect personal information directly from you or from authorised third parties. You have the right to refuse consent for us to collect information from third parties.

Use

Your personal information is primarily used to provide you with tailored advice. We may also use your information for related purposes that you would reasonably expect, including providing the other entities in Mulcahy & Co with details to provide you with the opportunity to access their services or advice also (presuming you don’t already). Occasionally, we may send you direct marketing materials. If you wish to stop receiving these communications, you can opt out at any time by contacting us or clicking the unsubscribe link in our emails. We keep records of how we obtained your personal information for marketing and will strive to fulfill your requests within two weeks. We maintain a register of individuals who do not wish to receive direct marketing materials.

Disclosure of Personal Information

To meet your specific needs and in line with common business practices, we may disclose your personal information to:

• Superannuation fund trustees, insurance providers, fund managers, and other product providers
• Compliance consultants
• Paraplanning contractors or temporary staff during peak periods
• Mailing houses
• Insurance reference bureaus and loss adjusters
• Your authorised professional advisers, such as solicitors or accountants
• Information technology service providers
• Another authorised representative of Mulcahy & Co if necessary
• Potential purchasers of our business for due diligence
• Government and regulatory authorities as required by law

All employees and contractors must maintain the confidentiality of your personal information. The Australian Securities and Investments Commission has the authority to inspect certain personal information we hold about you, and we collect information for reporting purposes as required by AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

Cross-Border Disclosure of Personal Information

We may disclose or store your personal information to parties located overseas, such as third-party contractors in the Philippines, for administrative functions and to various servers not located in Australia. We ensure the safe storage of personal information on servers located in Australia and comply with the Privacy Act 1988 regarding cross-border disclosures.

Storage and Security

Your personal information is stored securely in client files or electronically, accessible only to authorised personnel. We treat personal information as confidential, with sensitive information held in high confidentiality. We are legally required to retain personal information for seven years. Even if you cease to be a client, we will securely store your information for that period before destroying it.

Accuracy

Mulcahy & Co takes precautions to ensure your personal information is accurate and up-to-date. We encourage you to:

• Inform us of any inaccuracies
• Update us with any changes promptly

Providing inaccurate or incomplete information may hinder our ability to deliver the products or services you require.

Unsolicited Contact

We typically do not collect unsolicited personal information. If we receive such information, we will assess whether it could have been collected lawfully. If not, we will destroy or de-identify the information as permitted by law.

Your Access

You have the right to access your personal information, with certain legal exceptions. Please submit your request in writing for security purposes, and we will respond by providing copies, inspection opportunities, or summaries of the information. If charges apply, we will inform you beforehand. Access may be denied under specific circumstances, including threats to health, privacy concerns for others, or legal proceedings. If we refuse your request, we will provide a written explanation.

Using Government Issued Numbers

We may collect government issued numbers like your tax file number when required, but we do not use or disclose this information without your consent unless mandated by law.

Sensitive Information

We will not collect sensitive information about you without your consent, which includes details about your racial or ethnic origin, political opinions, religious beliefs, health, or sexual orientation. If we conduct direct marketing, we will only use sensitive information with your consent, except where collection is required by law or necessary for legal claims.

Our Website

Mulcahy & Co’s website may link to third-party sites, which have their own privacy policies beyond our control. You may register to receive newsletters, during which we will collect your name and email address, ensuring your information is protected. If you wish to unsubscribe or update your registration, please email us, and we will respond within five working days. Our website uses cookies for an improved user experience, but you can opt out by adjusting your browser settings.

Complaints Resolution

If you believe your privacy rights have been breached, please contact our Privacy Officer. We will investigate your complaint and respond within seven days. If unsatisfied with the outcome, you can reach out to the Office of the Australian Information Commissioner at www.oaic.gov.au.

Spam Policy

Mulcahy & Co adheres to the Spam Act, which defines spam as unsolicited commercial electronic messages. We ensure our practices comply with the National Privacy Principles when handling personal information.

Internal Procedures for Complaints

Mulcahy & Co follows three key steps in handling complaints about spam:

1. Consent: We only send commercial messages with the recipient's consent.
2. Identification: All electronic messages will clearly identify the sender.
3. Unsubscribe: We include an easy unsubscribe option in all messages and address requests promptly.

Content Compliance

We take reasonable measures to ensure that age-sensitive content is sent only to recipients legally entitled to engage with the promoted products or services.

Contact Us

For any complaints regarding breaches of privacy, please reach out to our Privacy Officer on privacy@mulcahy.com.au or 03 5330 7220.

Annexure A

The entities comprising Mulcahy & Co are:

Mulcahy & Co (Melton) Pty Ltd

Mulcahy & Co Geelong Pty Ltd

Mulcahy & Co IT

Mulcahy & Co Legal Pty Ltd

Mulcahy & Co Marketing Pty Ltd

Mulcahy & Co Mildura Pty Ltd

Mulcahy & Co Toowoomba Pty Ltd

Mulcahy & Co Financial Planning Pty Ltd

Mulcahy & Co Information Technology

Mulcahy & Co Lending Mildura Pty Ltd

Mulcahy & Co Lending Geelong Pty Ltd

Mulcahy & Co No 2 Pty Ltd

Mulcahy & Co Sunshine Coast Pty Ltd

Mulcahy & Co Accounting Services Pty Ltd

Mulcahy & Co Financial Services Pty Ltd

Mulcahy & Co Agri Solutions

Mulcahy & Co Financial Planning Geelong Pty Ltd

Mulcahy & Co Financial Planning Mildura Pty Ltd

Mulcahy & Co Lending Sunshine Coast Pty Ltd

Mulcahy & Co Agri Solutions Australia Pty Ltd

Mulcahy & Co Financial Planning Sunshine Coast Pty Ltd

Mulcahy & Co Succession & Estate Planning Pty Ltd