Privacy Policy

  • “AML/CTF Act” means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);

    "APPs" means the Australian Privacy Principles set out in Schedule 1 of the Privacy Act;

    “CDD” means customer due diligence;

    “Corporations Act” means the Corporations Act 2001 (Cth);

    “KYC information” means know your customer information, information about a customer collected before providing services as defined in the AML/CTF Act;

    “Lineage Group” means Lineage Group Pty Ltd (ACN 647 362 105) as Trustee for Lineage Group Unit Trust  trading as Lineage Group (ABN 45 909 356 889);

    "personal information" has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;

    "Privacy Act" means the Privacy Act 1988 (Cth);

    "sensitive information" has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an individual’s racial origin, health and political opinions;

    “Services” refers to the services and advice provided by Lineage Group to you;        

    “TASA” means the Tax Agent Services Act 2009 including the Code of Professional Conduct;

    “We”, “ours”, and “us” refers to refers to Lineage Group; and

    “You”, “yours”, and “customer” refers to the customer requesting the Services.

  • Lineage Group values and respects the privacy of the people we deal with.

    We are committed to protecting your privacy and adhere to the Privacy Act and other applicable privacy laws and regulations.

    We reserve the right to change this Privacy Policy from time to time by amending our Privacy Policy as set out below.

    This Privacy Policy outlines how we collect, hold, use and disclose your personal information, and how we manage the quality and security of your personal information. Unless you give us explicit consent otherwise, we will act in accordance with this Privacy Policy regarding our collection and use of your personal information.

    By entering into a service agreement with us or by providing information via our website at www.lineage.group (Website), you consent to our collection and use of your Personal Information in accordance with this Privacy Policy. If you do not agree to the terms of this policy, please notify us immediately by contacting your Engagement Partner. However, if you choose not to provide us with your personal information, we may not be able to provide you with our Services or we may refuse to provide Services to you or terminate our agreement with you.

  • We may collect personal information directly from you so that we are able to deliver the Services or conduct due diligence enquiries before agreeing to provide the Services. This information may relate to you, your employees, your members or customers or related third parties (for example, your spouse or dependents).

    The types of personal information we may collect and retain depends on the nature of our interaction with you and may include:

    • contact information such as your name, postal and email address and phone number;

    • date of birth;

    • employment history and records;

    • Corporate details, including but not limited to, ABN, ACN, registered business address and the names and addresses of company officers, employees, contractors and customers

    • financial records and historical financial data;

    • debit and credit card details, bank account details and billing information;

    • government identifiers;

    • tax file numbers;

    • health information and records;

    • insurance history and current policies held;

    • Information about the Services we have historically provided to you and any feedback you have provided regarding our Services;

    • Information you have provided to us by social networks or mobile applications when you access or engage with our social media platforms; and

    • your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, standard web log information and cookies from your computer.

    We may also collect sensitive information to discharge our legal obligations. ‘Sensitive information’ under the Privacy Act includes criminal records, biometric information that is to be used for the purpose of automated identification or verification.

    The personal or sensitive information we collect about you will be referred as Personal Information in this Privacy Policy.

  • We collect your Personal Information directly from you when you:

    • interact with us via our Website;

    • make an inquiry or request our Services;

    • enter into contracts for our Services;

    • attend any events that we may host or sponsor;

    • visit our business premises;

    • interact with us in person;

    • interact with us through our technology platforms (for example, by uploading documents to a secure client portal); and

    • interact with us via telephone, on social media or messaging platforms such as email, Facebook, LinkedIn, Instagram, etc.

  • We may also collect your personal information from publicly available sources or third parties, for example from your employer, staff, representative(s), family members, business partners, referees, government bodies and professional bodies so that we can deliver to you a more personalised experience and service offering.

    If we collect personal information about you from a third party, we will, where appropriate, request that the third party inform you that we are collecting such information, how we will use and disclose it and that you may contact us to gain access to and correct the information.

    We may use cookies. Cookies are data files transferred onto computers or devices by websites for record-keeping purposes. Cookies recognise when your device has visited our Website before, so we can distinguish you from other users of the website. This improves your website experience. If you prefer having cookies not stored on your device, you can configure your browser to disable cookies before accessing the Lineage Group website. However, if you remove or block cookies on your device, this may compromise your browsing experience on our Website and your ability to use our Website’s functionality.

    We may use relevant analytics services to help us better understand visitor traffic so we can improve our services. Although this information will not ordinarily be personal information because you will not be identified or reasonably identifiable from it, it is possible that under certain circumstances, we may connect it to you.

  • We are committed to keeping your Personal Information secure and protected from misuse, loss or unauthorised access or disclosure. Whilst we take all reasonable measures to protect the Personal Information we hold about you, we cannot guarantee the effectiveness of our data protection or security measures.

    Lineage Group stores personal information using secure cloud storage services provided by Microsoft and other reputable cloud service providers. These providers may store and process data on servers located in Australia or overseas, including in countries such as the United States, Singapore or wherever the relevant data centres are located.

    We take reasonable steps to ensure that our cloud service providers maintain appropriate security standards to protect your personal and sensitive information from misuse, interference, loss, and unauthorised access, modification, or disclosure, including through contractual obligations imposed on those providers.

    Where your personal information is stored or processed overseas, we take reasonable steps to ensure it is handled in accordance with the Australian Privacy Principles, or that the overseas recipient is subject to a substantially similar privacy law with mechanisms for you to enforce your rights.

    By engaging with us, you acknowledge that the use of technology, including cloud and AI systems, carries some inherent risk which cannot be eliminated.  AI is used to support (not replace) our professional care and judgement.

    We will retain your information for as long as it is needed for a permitted purpose or as required by law, after which time it will be archived or destroyed. We may need to retain records containing personal information to comply with record keeping obligations and for other legitimate business purposes (such as quality assurance).

  • Generally, we use your Personal Information for the particular purpose for which it was collected and related purposes which would be reasonably expected by you. We may use your Personal Information for the following purposes:

    • to confirm your identity and provide you with the Services;

    • to provide you with accurate and relevant information about our Services;

    • to assist you in relation to any questions you may have about our Services;

    • to administer our business activities including where necessary for us to provide our Services to you;

    • to send you newsletters or direct marketing campaigns which may align with your preferences and the Services you have previously requested from us directly or using third party platforms, including but not limited to by sending you articles of interest, inviting you to events and seminars and marketing certain services which we provide which we think may be of interest to you;

    • to process your payments for Services and protect your financial information;

    • to follow up regarding any Services we have provided to you.

    • to respond to any requests or complaints you make to us;

    • to perform our legal and regulatory functions and obligations under the Corporations Act, the AML/CTF Act, TASA and other legislation that prescribe functions or obligations on Lineage Group;

    • to disclose it to our advisers or any third parties to whom we are authorised or required by law to disclose your information to; and

    to collect KYC information as part of CDD procedures in compliance with the AML/CTF Act and rules. We may combine data we collect from different sources to achieve the above purposes and to give you a more seamless, consistent, and personalised experience across our Services. For example, proof of identity information may be used for both TASA and AML/CTF Act purposes.

    We may use third‑party platforms such as First AML to assist in processing and analysing Personal Information, in order to deliver services more efficiently and effectively. Any use of your Personal Information through these technologies will remain subject to this Privacy Policy and the APPs.

    We may also use your Personal Information for any other purpose which we state at the time of collection. You are responsible for ensuring that any Personal Information we have in relation to you is current, complete and accurate.

  • In general, we will disclose your Personal Information for the purpose of providing the Services and for the purposes described in section 5 above.

    We may disclose your Personal Information:

    • To third parties, for example, our suppliers, contractors and organisations that provide us with technical and support services such as First AML, third party cloud based service providers and other platform operators where necessary for us to provide our Services to you, for administrative, book keeping, CRM, banking and payments processing, accounting, tax and reporting services including delivery of documents, information or other materials or goods;

    • To third parties where you have expressly asked or permitted us to do so for the purposes of them or us providing further services;

    • To our related bodies corporate, and their respective directors, officers, agents, and employees for processing personal information on our behalf;

    • To our insurers, lawyers, auditors and other professional advisers;

    • To comply with any law enforcement agency, judicial proceeding, court order, or legal process in any jurisdiction that is investigating any breach or suspected breach of any law in any jurisdiction regarding your identity, or other personal or sensitive information provided by you to us;

    • Where disclosure is reasonably necessary to protect our rights or intellectual property or to protect the safety of our employees or the public, as required or permitted by law;

    • To comply with our obligations to courts, tribunals and regulatory authorities as required or authorised by law, such as the Australian Tax Office, the Tax Practitioner’s Board or as otherwise as outlined in our Terms and Conditions and Engagement Letter;

    • To perform our legal and regulatory functions and obligations under the Corporations Act, the AML/CTF Act, TASA and other legislation that prescribe functions or obligations on Lineage Group; and

    • Where we consider disclosure is necessary for the protection and wellbeing of a person.

    When we disclose Personal Information to a third party who is handling it on our behalf, we require that the third party protect your information to the same extent that we do.

  • Whilst we take all due care in ensuring the privacy and security of your personal and sensitive information, the possibility exists that this information could be unlawfully intercepted while in transit over the internet or while stored on our systems or on our website. We disclaim all liability to you to the greatest extent pursuant to law should this occur.

    We will take reasonable steps to destroy or permanently de-identify and anonymise personal and sensitive information if it is no longer needed for the purpose for which the information was disclosed.

    We use cloud platforms and online systems to store and back up personal information. These platforms are selected for their security and reliability; however, we cannot guarantee they are free from risks such as cyberattacks or unauthorised access. By engaging us, you consent to your personal information being stored and transmitted using these technologies.

  • Some third‑party technology providers we use may store, process or access your Personal Information outside Australia including in countries such as the United States, Singapore or wherever the relevant data centres are located.

    Where this occurs, we take reasonable steps to ensure that those providers handle your information in a way that is consistent with the APPs. However, by using our Services, you acknowledge that overseas storage may expose your information to different privacy regimes. 

  • We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you in various forms, including over the phone and by e-mail, SMS and post in accordance with applicable marketing laws such as the Spam Act 2003 (Cth).

    You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

    If you would like us to stop sending you direct marketing communications, you can request this by contacting our Privacy Officer (see contact details in section 14 of this Privacy Policy).

    Please note that there are certain types of communications that you may not be able to opt-out from, such as communications that we are required or permitted by law to send you.

  • Our Website may contain links to other websites operated by third parties. If you access a third party website through our Website, personal information may be collected by that third party website. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.  Third party websites are responsible for informing you about their own privacy practices and procedures. We encourage you to read their privacy policies.

  • You acknowledge that it is your sole responsibility to contact us from time to time to inform us of any changes to your Personal Information to ensure that it is up to date, relevant and of an appropriate quality to enable us to provide the Services to you, including but not limited to

    • your financial information, account and financial information of third party payees, login and other information that we use to facilitate payments and relevant record keeping on your behalf; and

    • when we uploaded or share your information via cloud platforms or other technology systems we make available, to ensure that the technology tools we use process the correct information when assisting us in delivering our services to you.

    If you inform us that your information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal and sensitive information.

    If you wish to make a request to access the personal information we hold about you, you should make a request by contacting the Privacy Officer specified in section 14 below.

  • ‍You can request more specific information from us about how we handle, process or manage the Personal Information we hold about you. Note we may require proof of your identity and full details of your request before we can process the request.

    If you have any queries in relation to this Privacy Policy, or if you wish to correct, update or request access to your Personal Information or have a complaint about a breach of privacy, then please contact our Privacy Officer, as set out below.

    Your enquiry or complaint will be dealt with as soon as possible, but in any case, you will receive return correspondence from us no later than fourteen (14) days after submitting your enquiry or complaint. If we cannot resolve your enquiry complaint within fourteen (14) business days, we will contact you and let you know how long it will take to address your enquiry or complaint.

    Privacy Officer

    ‍Email: hello@lineage.group

    Postal address: Level 12, Como Office Tower, 644 Chapel St, South Yarra VIC 3141

    ‍ ‍

  • We may update this Privacy Policy from time to time. Revised versions of the Lineage privacy policy will be posted on Lineage Group’s website. We will notify you by other means – for example, by placing a notice on the website, if we make material changes to this policy.