WEBSITE PRIVACY POLICY

This Privacy Policy applies to all personal information collected by Heads-up Advisory (ABN: 28 234 537 945) (we, us or our) via the website located at www.huadv.com.au and through the provision of our accounting, taxation, SMSF, and business advisory services.

1. What Personal Information We Collect

The kind of personal information we collect depends on how you engage with us. We may collect:

• Full name, email address, telephone number, and postal address

• Business name, ABN and ACN

• Tax File Numbers (TFNs) — collected only where required for the provision of registered tax agent services

• Financial information including income, expenses, bank account details, investment details, and superannuation information

• Employment details and date of birth

• Technical information including IP address, browser type, device information, and website usage data collected via cookies and analytics tools

• Any other information you voluntarily provide through our contact forms, service enquiry forms, or in the course of providing services

2. How We Collect Personal Information

We collect personal information directly from you through:

• Our website contact and enquiry forms

• Telephone calls, emails, and in-person meetings

• Onboarding documentation and engagement letters

• Cookies and website analytics tools (including Google Analytics, where enabled)

• Third parties where you have authorised us to do so, or as required by law

Where reasonably practicable, we collect personal information directly from you. We will notify you if information is received from a third party.

3. Purpose of Collection

We collect and use your personal information to:

• Provide accounting, taxation, SMSF auditing, and business advisory services

• Meet our obligations as a Registered Tax Agent under the Tax Agent Services Act 2009 (Cth)

• Comply with Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) obligations

• Communicate with you regarding your engagement and our services

• Send tax updates, newsletters, and marketing communications via GoHighLevel (GHL) — you may unsubscribe at any time

• Improve our website and services through analytics

• Meet all applicable legal and regulatory obligations

4. Tax File Number (TFN) Policy

Heads-up Advisory collects TFNs solely for the purpose of providing registered tax agent services as authorised under the Income Tax Assessment Act 1936 (Cth) and the Privacy (Tax File Number) Rule 2015. TFNs will not be disclosed to any third party except as required by law or with your explicit consent. TFNs are stored securely and access is strictly limited to authorised personnel.

5. Use of Technology & AI Tools

Heads-up Advisory uses artificial intelligence (AI) tools and platforms to assist with internal operations, document preparation, and service delivery. We may use models or platforms provided by third-party AI providers.

We are committed to the following safeguards:

• Client personal data and confidential information is not used to train any AI model

• Where AI tools are used, we use enterprise or team versions of platforms that provide contractual data protection commitments

• AI-generated content is reviewed by a qualified professional before being relied upon or provided to clients

The use of AI tools does not alter our professional obligations or the standard of care we owe to our clients.

6. Storage, Security & Retention

We store personal information using a combination of the following platforms, all subject to appropriate data protection commitments:

• Xero, MYOB, and QuickBooks — cloud-based accounting platforms

• Microsoft 365 including SharePoint, OneDrive, and Teams — document storage and collaboration

• Google Drive and Dropbox — cloud storage

• SuiteFile — document management (hosted via Microsoft SharePoint infrastructure)

• GoHighLevel (GHL) — CRM and marketing platform (US-based)

We take reasonable steps to protect your personal information from unauthorised access, misuse, loss, or disclosure through electronic and physical security measures.

Personal information is retained for a minimum of 5 years from the date of last service, consistent with ATO record-keeping requirements under the Income Tax Assessment Act 1997 (Cth) and the Tax Agent Services Act 2009 (Cth). TFN records and AML/CTF records are retained for a minimum of 7 years.

7. Overseas Disclosure

Your personal information may be disclosed to or accessed by recipients located overseas, including:

• India — team members and service providers who assist with business operations and service delivery

• Philippines — service providers who assist with business operations

• United States — GoHighLevel (CRM and marketing platform)

• Other jurisdictions — where third-party cloud platforms (Microsoft, Google, Xero, Dropbox) store or process data

We take reasonable steps to ensure overseas recipients handle your personal information in accordance with the Australian Privacy Principles. You acknowledge that countries outside Australia may not have equivalent privacy protections, and that Australian Privacy Principle 8.1 may not apply in all circumstances.

8. Cookies & Website Analytics

Our website uses cookies and analytics tools (including Google Analytics, where enabled) to collect information about how visitors use our site. This information is used to improve website performance and user experience.

A cookie consent notice is displayed on our website. You may disable cookies through your browser settings; however, this may affect the functionality of certain features. By continuing to use our website, you consent to our use of cookies as described in this policy.

9. Access & Correction

You may request access to, or correction of, the personal information we hold about you at any time. We will respond to your request within a reasonable period. We may decline a request in circumstances prescribed by the Privacy Act 1988 (Cth) and will provide written reasons if we do so.

To make a request, contact our Privacy Officer using the details below.

10. Complaints

If you have a complaint about how we handle your personal information, please contact our Privacy Officer in the first instance. We will investigate and respond within a reasonable timeframe.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.