Privacy Policy

What Personal Information Do We Collect?

The personal information we collect depends on your relationship with us and the services you or your organisation have engaged us to provide, or are interested in. It may include:

• Name and contact details (phone, mobile, email, residential and postal address);
• Identity information (date of birth, place of birth, occupation, and – where required for identity verification under AML/CTF law – government identifiers such as driver licence or passport details);
• Financial information (income, assets, liabilities, bank account details, taxation records, superannuation details, and other information relevant to the services you've engaged us for);
• Payment and transactional information (including banking and credit card details);
• Company and trust information (director and shareholder details, trustee and beneficiary details, corporate structures) where we provide corporate compliance or trust-related services; and
• Other personal or sensitive information contained in documents or communications you provide to us, or that we are required or permitted to collect by law.

How We Collect Personal Information

We may collect personal information directly from you, or in the course of our dealings with you, including through:

• Correspondence, meetings, phone calls and instructions between you and us;
• Forms and submissions on this website, including contact and enquiry forms;
• Your interactions with our marketing emails and communications (such as link clicks); and
• Registrations for events, webinars or other marketing-related activities.

We may also receive personal information about you from third parties – for example, referrers such as other accountants, lawyers, financial planners or business consultants; government agencies and regulators; your authorised representatives; and publicly available sources.

Identity Verification and Anti-Money Laundering Obligations

From 1 July 2026, Klutch is subject to obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”) as a reporting entity providing designated services. Where this applies, we are required by law to collect and verify identification information about clients and, in some cases, beneficial owners, before or during the provision of certain services. This may include verifying your identity against government records or through an accredited identity verification provider.

We collect, use, hold and disclose this information as required or authorised under the AML/CTF Act, including disclosure to AUSTRAC and other regulatory or law enforcement bodies where required by law.

Artificial Intelligence (AI) Tools

We may use AI tools to assist with tasks such as transcribing or summarising client meetings, drafting or reviewing documents, and supporting internal service-quality and compliance functions. These tools may process personal information you share with us, such as your name, financial circumstances and instructions.

All AI-assisted work is reviewed and approved by a qualified team member before it is provided to you or relied upon – AI tools support our work, they do not replace our professional judgement. We take reasonable steps to ensure your confidential information is not entered into unsecured or publicly accessible AI systems, and we take steps to ensure any AI tools we use:

• Comply with Australian privacy and data security standards;
• Are subject to appropriate access controls and confidentiality obligations;
• Are not used to sell or repurpose your personal information for unrelated commercial purposes; and
• Are reviewed periodically for ongoing compliance.

As AI technology and professional standards continue to evolve, we will update this policy to reflect any material changes to our approach.

Why We Collect, Hold and Use Personal Information

We collect and hold your personal information to:

• Provide our services and carry out related business functions (including planning, file review, internal administration, and our professional and regulatory obligations);
• Meet our obligations under the AML/CTF Act, the Corporations Act 2001 (Cth), taxation law, and other applicable legislation;
• Communicate with you, including for client satisfaction surveys, service updates, and – where you've consented – marketing and educational content;
• Analyse and improve our website and services, including through website traffic analysis; and
• Disclose to third parties where reasonably necessary to provide our services – for example, to software or platform providers we use to deliver services (such as practice management, compliance or corporate registry platforms), other professional advisers assisting with your matter, auditors, or as required or authorised by law.

We may also use or disclose your personal information:

How We Hold and Store Personal Information

Personal information is held on paper, electronically, or both. We take reasonable technical and organisational steps to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure, including:

• Secure, access-controlled premises for physical records;
• Password protection, encryption and firewalls for electronic records;
• Access to personal information restricted to staff and contractors whose role requires it, under confidentiality obligations; and
• Regular data backups and staff training on privacy and information-handling procedures.

Where we use cloud-based or third-party platforms to store or process personal information (for example, practice management, document management or AML/CTF verification software), we take reasonable steps to satisfy ourselves those providers have appropriate security measures in place. Some of these providers may store or process personal information on servers located outside Australia. Where this occurs, we take reasonable steps to ensure the overseas recipient handles your personal information in a manner consistent with the Australian Privacy Principles.

Destruction of Personal Information

We retain personal information for as long as it's required for our business functions or as required by law. As a minimum, we retain client and engagement records for five years, consistent with our record-keeping practices for taxation matters. Some records – including certain AML/CTF identity verification records – must be retained for longer periods specified in the relevant legislation. When information is no longer required, we destroy or de-identify it using secure methods, or return original documents to you where appropriate.

Outsourced and Overseas Service Providers

We may involve third-party contractors or outsourced service providers in delivering our services, including for accounting file preparation and data entry, auditing (including for self-managed super funds), and hosting of data on cloud-based servers.

Where an outsourced or cloud service provider is located overseas, we take reasonable steps to ensure that the Australian Privacy Principles are complied with in respect of any personal information disclosed to that overseas recipient, consistent with our obligations under APP 8. If you'd like more detail about where a particular service provider is located, please contact us.

Access to and Correction of Your Information

You may request access to, or correction of, the personal information we hold about you by contacting us using the details below. We'll respond within a reasonable time and provide access in the manner you've requested, unless it's unreasonable or impracticable to do so. If we can't give you access, or decline to correct information, we'll explain why in writing.

Data Breach

We take any accidental or unauthorised loss, use or disclosure of personal information seriously. We are subject to the Notifiable Data Breaches scheme under the Privacy Act, and will respond to any suspected eligible data breach in accordance with our internal procedures and the guidance of the Office of the Australian Information Commissioner (OAIC).

Cookies and Website Analytics

A cookie is a small data file placed on your device when you visit our website. We use cookies to help our website function, remember your preferences on return visits, and understand how visitors use our site so we can improve it.

We currently use Google Analytics to collect non-identifying information about website visits, including approximate location, browser type, pages viewed, and time and date of visit. This helps us understand how visitors use our website and where we can improve it. Google Analytics data is processed on Google's servers, which may be located overseas; Google's use of this data is governed by its own privacy policy.

You can disable cookies through your browser settings at any time, or opt out of Google Analytics specifically using Google's Analytics Opt-out Browser Add-on.

Our website may contain links to other websites. We're not responsible for the privacy practices of those sites, and recommend you review their privacy policies before providing any information.

Direct Marketing

We may use your personal information to send you direct marketing communications – by email, mail or other means – where you've consented, or where otherwise permitted by law. You can opt out at any time by contacting us or using the unsubscribe facility in the relevant communication.

Complaints

If you have a concern about how we've handled your personal information, please contact our Privacy Officer using the details below. We'll investigate and respond in accordance with the APPs. If you're not satisfied with our response, you may lodge a complaint with the OAIC.

If your complaint relates specifically to a tax agent service we've provided, you may also lodge a complaint with the Tax Practitioners Board (TPB) – we are registered with the TPB as a tax agent, registration number 26350271, and its complaints process is available at tpb.gov.au.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. This policy was last updated on 16 July 2026. Continued use of our website or services after any update means you accept the policy as it applies from time to time.

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