The WOW! ADVISORS GROUP is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). This policy sets out how WOW! ADVISORS GROUP handles personal information.

This Privacy Policy applies to the activities of:

• WOW! Advisors & Business Accountants
• MediSuccess
• CrystalClear Bookkeeping
• Hitesh Mohanlal conducted as a consultant, trainer or presenter.

These businesses together will be referred to herein as WOW! ADVISORS GROUP, we or us.

The Privacy Policy sets out how we collect, use and disclose Personal Data that you have provided to us through our websites, mobile applications Apps or otherwise. WOW! ADVISORS GROUP processes Personal Data both as a Processor and as a Controller, as defined in the GDPR.

This privacy policy does not apply to personal information collected by WOW! ADVISORS GROUP that is exempt under the Privacy Act, for example employee records.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, whether through our websites and Apps or otherwise, you accept and agree to the practices described in this Privacy Policy.

This Privacy Policy supplements, but does not supersede or replace, any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are in addition to any rights we may have at law to collect, use or disclose your Personal Data.

Our privacy policy will be reviewed regularly to take account of changes in legislation, technology, and our operations and practices. We aim to ensure the policy is appropriate to the changing environment. We may make changes to these practices from time to time. Any changes we make will be posted and will apply to your activities and information from the posting date, going forward. We therefore, encourage you to check back regularly for updated information on the handling of your Personal Data.

Requesting a copy of WOW! ADVISORS GROUP Privacy Policy:

Our privacy policy is available by following links to the policy on our website. However, on request, we may be able to provide you with a copy of the policy in an alternate format. If you have any enquiries or would like to make a request for a copy of the policy, please contact our Privacy Officer (refer to contact details below).

1. Purposes For Collecting, Holding, Using and Disclosing Personal Information:

We only collect, hold, use and disclose personal information which is reasonably necessary to ensure that we are able to provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use and disclose your personal information.

In this Privacy Policy, Personal Data refers to any data, whether true or not, about an individual who can be identified:

(a) from that data, or
(b) from that data and other information to which we have or are likely to have access, including data in our records as they may be updated from time to time.

Depending on your level of engagement with our activities, we may collect some or all of the following data:

• Full name;
• Dates of birth;
• Gender;
• Tax file numbers and other government related identifiers;
• Assets and liabilities;
• Educational qualifications and employment history;
• Personal income;
• Visa and work permit status;
• Bank account details;
• Shareholdings and details of investments;
• Superannuation details;
• Tax and financial statements;
• Information regarding insurance;
• Personal information about your spouse and dependents;
• Personal Contact Numbers;
• Personal Email Address;
• Passport or other Identification Numbers;
• Home Address;
• Company Name;
• Company Information;
• Company Address;
• Company Email Address;
• Tax file numbers, ABN Numbers and ACN numbers;
• Credit /Debit Card Details;
• Bank Account Numbers;
• Social Media Accounts and posts;
• Network or Transactional Data;
• Web Browser Type or Version;
• Operating System;
• Photographs or Video;
• A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
• IP Addresses;
• Demographics;
• People who are associated to you such as family or business associates or business contacts;

It may be necessary in some circumstances for WOW! ADVISORS GROUP to collect sensitive information about you in order to provide specific services. The types of sensitive information we may collect include:

• Health status;
• Ethnic origin;
• Details of any membership/s to professional associations;
• Criminal record.

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfill the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.

2. Collection of Personal Data

Generally, we collect Personal Data in the following ways:

• When you become a client or contact us about becoming a potential client of the practice;
• We are contacted by a third party to contact you;
• When you register a user account or contact us via the WOW! ADVISORS GROUP members website or App;
• When you conduct any online transactions (such as making contact, a booking or purchase of one of our products or services);
• When you download or use any of our Apps;
• When you apply to any of our programmes;
• When you use a cookie-enabled browser to visit any WOW! ADVISORS GROUP website or use any WOW! ADVISORS GROUP – operated App;
• When you enter or respond to our promotions, initiatives or contests (including but not limited to registering to attend an in-person or online event being conducted by us);
• When you subscribe to our mailing lists for email subscription, postal mail contacts, or other forms of regular or occasional communication with us;
• When you interact with members of our WOW! ADVISORS GROUP Team via telephone calls, emails, letters or face-to-face meetings, when you submit a comment or question to us using a Contact Us or similar feature on our websites, or when you contact us and disclose your Personal Data in any other way such as social media;
• When your images are captured by us during video calls we conduct, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
• When you provide or offer to provide volunteer services to us, whether as part of a team project or on an individual basis;
• When we solicit information about you and receive your Personal Data from third parties such as government authorities; and
• When you submit your Personal Data to us for any other reason.

When you browse our website or use our Apps, you generally do so anonymously, On our website or Apps, we do not automatically collect Personal Data, such as your email address, unless you affirmatively provide that information or log in with your account credentials.

If you provide us with any Personal Data relating to a third party (including but not limited to information about your customers, spouse, children, parents and/or employees), by submitting such information to us, you represent that you have obtained the consent of that third party to you providing us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. A failure on your part to do so may result in our inability to provide you with the products and services you have requested.

3. Collection, Holding, Using and Disclosing of Personal Information:

(a) Collection – General:

When we collect, hold, use and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under Australian law or a court/tribunal order.

(b) Collection – Marketing Purpose:

If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via such number(s), then from time to time, WOW! Advisors Group may contact you. If you have provided an email address you may receive emails from time to time.

We may also send gifts and free content using traditional mail services.

In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data.

If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

You have a choice to withdraw your consent for receiving marketing or promotional materials/communication from us.

Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during that time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services you have requested from WOW! Advisors Group.

Under GDPR, we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following conditions applies:

a) You have given consent to the processing of your personal data for one or more specific purposes;
b) Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) Processing is necessary for compliance with a legal obligation to which we are subject;
d) Processing is necessary to protect the vital interests of you or of another natural person;
e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller; and/or;
f) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

(c) Collection of Someone Else’s Personal Information:

You should only provide us with someone else’s personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us. In providing such information you agree that you have obtained the relevant consent and this is authorised to do so.

(d) Unsolicited Personal Information:

There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients.

In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully in accordance with the APPs or GDPR. If the information was not lawfully obtained it will be destroyed or de- identified. We will try to notify the relevant person, whose information has been mistakenly received, if this situation arises.

4. Security of Personal Information

Safeguarding the privacy of your information is important to us. We hold personal information in a combination of secure computer storage facilities and paper based files, and take steps to protect the personal information we hold from misuse, loss, interference, unauthorised access, modification or disclosure.

WOW! ADVISORS GROUP trains its employees carefully on handling personal information and confidentiality of such information.

Once we have no purpose for holding your personal information, we will take all reasonable steps to destroy or de- identify the information.

Our websites and Apps may contain links to other websites or Apps operated by third parties. We are not responsible for any of the privacy practices of websites or Apps operated by third parties that are linked to our websites/Apps. We encourage you to learn about the privacy policies of such third parties. Some of these third party websites/Apps may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website/App, you should check the applicable Personal Data policies of the third party website/App to determine how they will handle any information they collect from you.

Under data breach legislation we are obliged to inform the Information Commissioner of any such breaches which are required to be reported under law. In the event of a data breach we will do everything we can to limit and reduce the risk of that breach and work with our IT suppliers and the Information Commissioner to inform you if your data has been breached.

5. Disclosure of Personal Information Overseas & Sharing Personal Information Within the WOW! ADVISORS GROUP Network

(a) Disclosure amongst and within the WOW! ADVISORS GROUP:

To meet the purposes for which your personal information has been collected we may disclose your information to others in the WOW! ADVISORS GROUP.

(b) Disclosure overseas:

WOW! ADVISORS GROUP utilises some service providers overseas to process data and help deliver services to you. We may disclose your personal information to these providers from time to time. Such overseas disclosure would be to Philippines or another country as advised. When required, your personal information will only be disclosed to an overseas person or business in the following circumstances:

• Where the overseas recipient has signed a contract with us which creates legal obligations to comply with Australian Privacy Law & GDPR
• If the recipient is subject to similar privacy law as Australian privacy law GDPR, and you are able to personally access avenues to enforce the protection of those laws;
• If you consent for WOW! ADVISORS GROUP to disclose the information after we provide you with full information; or
• If the disclosure is required or authorised by or under an Australian law or a court/tribunal order.

On collection of your personal information, we will inform you whether it is likely we will disclose the information to an overseas recipient and, if so, where those recipients are likely to be located.

(c) Disclosure to third party service providers.

WOW! ADVISORS GROUP utilises third party providers (such as IT providers and market researchers) for its business and to deliver services to you. It may be necessary for us to disclose non-sensitive personal information to these providers from time to time. Such disclosure will be in accordance with this Privacy Policy and the APPs.

6. Your Right to Withhold & Modify information

You may access certain areas of Our Site without providing any data at all. However, to use all the features and functions available on Our Site, you may be required to submit or allow for the collection of certain data. If you:

a. Have any questions or feedback relating to your Personal Data or our Privacy Policy;
b. Would like to withdraw your consent to any use of your Personal Data as set forth in this Privacy Policy; or
c. Would like to obtain access to and, if appropriate, correct your Personal Data records, you can do so:

By emailing us, at hitesh@hiteshmohanlal.com.au

By calling us, at +61 73161 9548

You may also write to our Data Protection Officer as follows:

Data Protection Officer
WOW! Advisors & Business Accountants
PO Box 2117
Runcorn, Qld 4113

Please note that if your Personal Data has been provided to us by a third party, you should contact that third party directly to make any queries, to provide feedback, or to file any access and correction requests on your behalf.

7. Privacy On Our Websites

The WOW! ADVISORS GROUP website uses Google Analytics or other third party software to analyse aggregate user behaviour. Google Analytics and such other software uses first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant WOW! ADVISORS GROUP access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased.

The information is collected using first party cookies, meaning that only WOW! ADVISORS GROUP is able to access your information. Your information may be aggregated with information from other users for the purpose of improving our website and offerings. We will not associate any data gathered from our website with any personally identifiable information, unless you explicitly submit that information (e.g. your email address) via our online information form.

8. GDPR

In addition to the above GDPR legislation gives you the following rights. Please note that GDPR regulation is under the jurisdiction of EU member states and these rights apply to those in the EU. These rights may not be relevant if you are not in an EU member state.

• Right to be informed – We must inform you when your data is collected and the purpose for which it is intended.
• Right of access – We must allow you to view the data we have gathered on you.
• Right to rectification – You have the right to correct erroneous information about yourself in our data records.
• Right of erasure – You have the right to request the deletion of personal data held on you, although this right is not absolute.
• Right to restrict processing – You can request the suppression of your personal data file, or restrict its processing.
• Right to data portability – You have the right to take the data we have collected on you and share it elsewhere, eg. to get a better customer deal.
• Right to object – You have the right to object and prevent your data being used for particular purposes.
• Rights related to automatic decision-making – You may only be profiled with your explicit consent, where this is necessary to enter into a contract or where such processing is authorised by the state.

Outside GDPR you have the right to access any personal information regarding you that WOW! ADVISORS GROUP holds. This is subject to some limited exceptions, which the Privacy Officer can provide further information on.

Such requests should be made in writing to the Privacy Officer. We will acknowledge your request within 14 days and respond to it within a reasonable time.

WOW! ADVISORS GROUP may charge a fee only to cover the cost of locating, retrieving, reviewing and copying any material requested. We will not charge any fee to make the request or to for us to give effect to the request.

9. Correction of Personal Information

WOW! ADVISORS GROUP endeavours to ensure that the personal information it holds is accurate and up-to-date.

You are able to make a request to correct the information by contacting our Privacy Officer, or by telephoning or emailing us with your corrected information. In some limited circumstances your request may be refused or partially refused.

10. Procedure If Your Request To Access or Correct is Refused

There may be limited circumstances where your request is refused or partially refused.

If this occurs we will give you a written notice that sets out:

• The reasons for the refusal, including the reasons why access cannot be granted in an alternative way (except where it would be unreasonable to provide those reasons);
• How to make a complaint about the refusal;
• Any other matter as prescribed by the regulations.

If your request to correct is refused you have the option of submitting a statement associated with your personal
information. For more information contact the Privacy Officer.

11. How to Make a Complaint

If you consider that any action of WOW! ADVISORS GROUP breaches this policy or the Australian Privacy Principles, you are able to make a complaint. Once we have received your complaint, it will be assessed and acted upon within a reasonable time.

To make a complaint please contact our Privacy Officer. If you are not satisfied with our response to your complaint, you may contact the Office of the Privacy Commissioner or if under GDPR with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement.