Privacy Policy

I&A PRIVACY POLICY

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to
protecting the privacy of personal information provided to us, or otherwise collected by us when providing our data
analytics services, advanced budgeting and forecasting services, enterprise resources planning related services, robotic
process automation services, I&A admin assist services, strategic consulting services and any other services we may provide
from time to time (together our “Services”) to you. In this Privacy Policy “we”, “us” or “our” means Citadel Capital Group
Pty Ltd (ACN 009 195 322) as trustee for The Ioppolo Trust (ABN 17 057 481 184) and Janti Pty Ltd (ACN 077 791 792) as
trustee for The Lepore Family Trust (ABN 14 146 404 137), trading as Ioppolo and Associates.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not,
about an individual who is identified or reasonably identifiable.

Clients and their staff: As a client of ours, the types of personal information we may collect about you include:

  • your name;
  • the business you work for and your job title;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • details of the services you are interested in;
  • your credit card or other payment details where you sign up to our online Services;
  • your preferences and/or opinions;
  • information you provide to us, including through feedback surveys;
  • details of products and services we have suggested or provided to you and/or that you have enquired about, and our response to you;
  • additional personal information that you provide to us, directly or indirectly, through your use of our
  • Services, associated applications and/or accounts from which you permit us to collect information; and
  • any other personal information requested by us and/or provided by you or a third party.

As a user of our website or cloud-based services:

  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour; and
  • information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information
means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional
associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or
biometric information.

We do not actively request sensitive information about you. If at any time we need to collect sensitive information about
you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised
by law.

How we collect personal information

We collect personal information in a variety of ways, including:

  • Directly: We collect personal information which you directly provide to us, including when you contact us, enter into discussions with us about the Services, when you enter into a contract with us for the Services, when you create a login for our online based Services and when you request our assistance via email or over the telephone.
  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
  • From third parties: We collect personal information from third parties, such as information from business partners or from third party suppliers of products and services, including details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
Collection and use of personal information

Personal information: We may collect, hold, use and disclose personal information for the following purposes:

  • to understand your requirements and suggest products and/or services for you;
  • to provide our Services, including to set up administer and manage the provision of our Services;
  • to contact and communicate with you about our Services;
  • to enable you to access and use our online Services, including allowing you to create and use a login;
  • to enable you to access and use our associated applications and third party sites and applications which may interface or interoperate with our Services;
  • for internal record keeping, administrative, invoicing and billing purposes;
  • for analytics, market research and employee and business development, including to operate and improve our Services, and any associated applications;
  • to offer additional benefits to you;
  • for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you;
  • to comply with our legal obligations and resolve any disputes that we may have;
  • if you have applied for employment with us; to consider your employment application; and
  • if otherwise required or authorised by law.
Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for products or services we have provided to you;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel, LinkedIn or other relevant analytics businesses; and
  • any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure: Where we disclose your personal information to third parties listed above, these third parties may
store, transfer or access personal information outside of Australia.

We will only disclose your personal information to countries with laws which protect your personal information in a way
which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the
circumstances to protect your personal information in accordance with the Australian Privacy Principles.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will
collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide
personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of
our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out
in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and
warrant that you have such person’s consent to provide the personal information to us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of
communications (including marketing communications), please contact us using the details below or opt-out using the optout facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable
for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to
your personal information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or
misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information
found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally
permitted to not correct your personal information.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of
the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our
investigation and the steps we will take in response to your complaint. If you are unhappy with our response, you also have
the right to escalate your complaint by contacting the Office of the Australian Information Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access
or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure
personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us
over the Internet. The transmission and exchange of information is carried out at your own risk.

Cookies

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to
store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable
information. If and when you choose to provide our online Services with personal information, this information may be
linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all
or parts of our online Services.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not
responsible for the protection and privacy of any personal information which you provide whilst visiting those websites.
Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website.
We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at:

Citadel Capital Group Pty Ltd (ACN 009 195 322) as trustee for The Ioppolo Trust (ABN 17 057 481 184) and Janti Pty Ltd
(ACN 077 791 792) as trustee for The Lepore Family Trust (ABN 14 146 404 137) trading as Ioppolo and Associates

Address: Suite 6, Level 1, 12-20 Railway Road, Subiaco, Western Australia 6008
Email: [email protected]
Last update: 27 January 2021
© LegalVision ILP Pty Ltd

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