LEENANE TEMPLETON PTY LIMITED PRIVACY POLICY

Purpose and scope

This privacy policy applies to Leenane Templeton Holdings Pty Limited (ABN 87 166 046 911) and any entity owned or controlled by Leenane Templeton Holdings Pty Limited, collectively “LT”.

LT respects your privacy and is committed to protecting your personal information.

This policy explains how LT handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Cth) (“Privacy Act”).

This policy is not intended to cover categories of personal information that are not covered by the Privacy Act.

This policy was last reviewed on 1 April 2026.

Collection of personal information

LT collects and holds personal information from clients, employees, job applicants, contractors and other individuals. We use this information when it is necessary to provide professional services to our clients and for business purposes.

The main types of personal information LT collects and holds relate to the contact details and organisational roles of our clients, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing professional services to our clients, we may collect and hold more detailed personal information (for instance financial details if we are engaged to perform financial services, or credit information).

We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face to face meetings, email messages, telephone conversations, when you use our websites or our social media, or by third parties. If you contact us, we may keep a record of that contact.

If you choose not to provide us with personal information, we may not be able to perform certain tasks or services.

Where required by law, LT will obtain consent before collecting, using or disclosing personal information in certain circumstances.

We also collect personal information about individuals from others. This may include personal information:

• provided to us by clients, or other third parties, when providing them with products and services. If this occurs, we rely on the person or client providing us with the personal information having the necessary authority to do so;
• about prospective employees, current employees, and contractors collected through regular and confidential background, reference, clearance and sanctions checks, including checks conducted by our service providers; and
• collected from publicly available sources, such as information about officers and directors in the Annual Reports of publicly listed companies.

Our purposes for collecting, using, holding, and disclosing personal information

The main purposes for which we collect, hold, use and disclose personal information are:

• to provide our services;
• to comply with the terms of our client engagements;
• to respond to an individual’s request;
• to communicate and maintain contact with clients;
• to keep clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we are holding (as described below under Marketing communications);
• for general management and reporting purposes, such as invoicing and account management;
• if you are an LT employee, or contractor, to ensure your compliance with LT policies, professional standards, and applicable laws;
• to develop and implement methodologies, services, products and technology (including artificial intelligence and machine learning enabled technology);
• for recruitment purposes and for purposes related to the employment of our personnel;
• to enhance the security of our systems and communications, and to protect against unauthorised access to data, and other potential threats. This includes implementing data loss prevention tools and related security measures to safeguard personal information, such as automated scans to identify harmful emails (e.g., phishing attempts);
• to conduct regular background, clearance and sanctions checks, including as required or requested for the purpose of client engagements and to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• other purposes related to our business; and
• where required or permitted by law, regulation, rule or professional standard.

LT does not routinely use or disclose personal information to other organisations unless:

• use or disclosure is permitted by this policy;
• we believe it is necessary to provide you with a product or service which you have requested;
• to protect the rights, property or personal safety of any member of the public or a customer of LT or the interests of LT;
• some or all of the assets or operations of LT are or may be transferred to another party as part of the sale of some or all of LT’s business;
• you give your consent; or
• such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.

LT uses a range of third-party providers to help us maximise the quality and efficiency of our services and our business operations.  This means that individuals and organisations outside of LT will sometimes have access to personal information held by us and may collect or use it from, or on behalf of, LT. This may include:

• any data processors processing your information on our behalf;
• where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the purposes described above;
• any agent, contractor or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;
• any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;
• government agencies, statutory authorities and industry regulators;
• our auditors, consultants, accountants, lawyers or other financial or professional advisers; and / or
• our sub-contractors or third-party service or product providers as may be determined to be necessary or appropriate.

We may also share non-personal, deidentified and aggregated information for research or promotional purposes.

We do not sell to or trade personal information with third parties.

We require our service providers to adhere to our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes.

If we collect, hold or use personal information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the Privacy Act.

Destroying or deidentifying personal information

We will take reasonable steps to securely destroy personal information or ensure it is deidentified if we no longer need the information for any of the purposes outlined above.

Marketing communications

We may collect, hold and use personal information about individuals to market our services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by emailing us at info@LT.com.au.  Alternatively, if we have contacted you by email, you may use the unsubscribe function in that email to notify us that you do not want to receive further marketing information from us by email.

Privacy on our website

This policy also applies to any personal information we collect via our website at www.LT.com.au and other related LT websites in addition to personal information you provide to us directly.

Website Privacy, Cookies, Analytics and Communications

This section explains how we manage personal information collected through our websites, digital tools, communications and online advertising activities.

• Website Privacy and Security
• Cookies and Similar Technologies
• Analytics and Online Advertising
• Email Communications and Direct Marketing
• Overseas Disclosure
• Third-Party Websites

Protection of personal information

Leenane Templeton and its related businesses and websites (LT, we, us or our) take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.

The security measures we use may include physical, administrative and technical safeguards such as restricted access controls, password protection, secure systems, internal policies and procedures, staff training, and the use of reputable third-party technology and storage providers.

Personal information we collect may be stored in electronic systems, cloud-based platforms, or on servers operated by our third-party service providers, including service providers located in Australia and overseas.

While we take reasonable steps to protect personal information, no method of transmission over the internet and no method of electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted to us online or stored by us electronically.

Risks of using the internet

You acknowledge that there are inherent risks associated with transmitting information over the internet, including by email and through website forms.

If you provide information to us by electronic means, you do so at your own risk. Although we take reasonable steps to protect information once it is received, LT does not warrant the security of any information transmitted to or from our websites, by email, or through third-party digital platforms.

Cookies and similar technologies

Our websites may use cookies, pixels, tags and similar technologies to enable website functionality, remember user preferences, measure website traffic, improve performance, analyse user behaviour, and support our marketing and advertising activities.

A cookie is a small text file placed on your browser or device when you visit a website. These technologies may collect information such as:
• browser type and browser settings
• device type and operating system
• pages viewed and time spent on pages
• date and time of visits
• referring website or traffic source
• approximate location information derived from technical data
• interactions with our website, forms, pages and advertisements.

Cookies and similar technologies do not usually identify you by name. However, in some circumstances, information collected through these technologies may be linked with other information we hold about you.

You may be able to manage or disable cookies through your browser settings. However, if you disable cookies or similar technologies, some parts of our websites may not function properly and your user experience may be affected.

Where required, LT may provide cookie consent or preference tools to allow users to manage non-essential cookies.

Google Analytics and other website analytics tools

LT may use Google Analytics and other analytics tools to collect and analyse information about how visitors use our websites. This helps us understand website traffic, improve website functionality, measure content performance, and enhance the user experience.

Analytics tools may collect information including:
• pages visited
• time spent on pages and on the website
• click paths and on-site behaviour
• technical information about devices, browsers and operating systems
• referral sources, including whether a visitor arrived via a search engine, advertisement or third-party website
• event and engagement data
• approximate geographic location derived from technical information.

This information may be collected using cookies, scripts, tags or similar technologies.

Where Google Analytics is used, information generated through its tools may be transmitted to and processed by Google or its related entities on servers located outside Australia. LT may also use privacy controls and settings made available within analytics platforms, including settings relating to retention and data management.

Google Ads, conversion tracking and remarketing

LT may use Google Ads and associated advertising technologies, including the Google tag, conversion tracking, enhanced measurement tools, remarketing features and audience-based advertising tools, to promote our services and measure the effectiveness of our advertising campaigns.

These tools may use cookies, pixels, tags or similar technologies to:
• record when a user visits our website after clicking an advertisement
• measure website enquiries, form submissions, calls, bookings or other conversions
• assess the performance of advertising campaigns
• build audiences for future advertising campaigns
• show more relevant advertisements to users based on prior visits to our websites or interactions with our online content.

Where remarketing or audience features are enabled, advertisements for LT may appear on third-party websites, apps or platforms based on a user’s previous interactions with our websites.

Advertising and analytics technologies may involve the collection or use of identifiers, browser information, website activity data and other online usage information. This information may be used by LT and third-party providers, including Google, for reporting, attribution, campaign optimisation and audience development.

Users may be able to manage advertising preferences through their browser settings, cookie settings, or tools made available by Google or other digital advertising providers.

Overseas disclosure and third-party service providers

LT may disclose or make available personal information to third-party service providers that assist us with website hosting, data storage, analytics, advertising, communications, IT support, CRM systems, email systems, cloud services and related business operations.

Some of these service providers may be located outside Australia or may store or process information on servers located outside Australia, including in the United States or other countries.

Where LT discloses personal information overseas, we will take reasonable steps, where required by law, to ensure that the overseas recipient handles the information in a manner consistent with the Australian Privacy Principles.

Email communications

LT may use your contact details to communicate with you for business, service, administrative and relationship management purposes. This may include:
• responding to enquiries
• providing information about our services
• sending engagement-related communications
• arranging appointments or meetings
• delivering service updates, newsletters, reminders or administrative notices
• managing our professional relationship with you.

We may also send commercial electronic messages about our services where permitted by law.

Direct marketing

LT may use personal information to send direct marketing communications about services, events, updates, publications or other information that we consider may be of interest to you, where permitted under the Privacy Act 1988 (Cth) and other applicable laws, including the Spam Act 2003 (Cth).

Direct marketing communications may be sent by email or other electronic means.

You may opt out of receiving marketing communications from us at any time by:
• clicking the unsubscribe link in an email communication, where available, or
• contacting us using the contact details set out in this Privacy Policy.

LT will give effect to unsubscribe requests within a reasonable period and in accordance with applicable law.

If you opt out of direct marketing communications, we may still send you non-marketing messages where necessary to provide services, respond to enquiries, administer our relationship with you, or comply with legal or regulatory obligations. This is more likely to be directly from your accountant or administrative support.

Third-party links

Our websites may contain links to third-party websites for convenience or informational purposes. Those websites are not owned or controlled by LT unless expressly stated otherwise.

LT is not responsible for the privacy practices, security, content or accuracy of third-party websites. Accessing those websites is at your own risk, and you should review the relevant privacy policy and terms of use of any third-party site before providing personal information.

Websites associated with LT may include, without limitation:
• self-managedsuperfund.com.au
• financialplanner-newcastle.com.au
• newcastle-accountants.com.au
• leenanetempleton.com.au

Security of Personal Information

LT will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. We also require our employees and data processors to respect the confidentiality of any personal information held by LT.

We use reasonable organisational, technical and administrative measures and security safeguards to protect, as is reasonable in the circumstances, the personal information we hold from misuse, loss, interference and/or unauthorised access, use, disclosure or alteration of information under our control.

Where practicable, we implement measures to require organisations to whom disclosure is made to comply with applicable data protection and privacy laws. If a third party is given access to personal information, we take reasonable steps to ensure that the information is held securely and used only for the purpose of providing the relevant service or activity.

If LT becomes aware of an eligible data breach under the Privacy Act, we will investigate the incident and, where required, notify affected individuals and the Office of the Australian Information Commissioner.

Access to Information, Corrections and Concerns

We will provide access to personal information upon request by an individual, except in the limited circumstances in which we are permitted by law to withhold this information (for instance, where granting access would infringe another person’s privacy).

Please contact us by emailing info@LT.com.au if at any time you:

• want to know what personal information we hold about you;
• believe that information we hold about you is incorrect or out of date;
• have concerns about how we are handling your personal information;
• wish to have your personal information deleted;
• wish to suppress or limit our use of your personal information that has been previously provided to us; or
• have reason to believe that your interaction with us is no longer secure for any reason.

When you make a request to access personal information, we may require you to provide some form of identification (such as a driver’s licence or passport) so we can verify that you are the person to whom the information relates.

If LT becomes aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns.

We encourage you to contact us in the first instance if you have any concerns about privacy.  We will endeavour to resolve your issue as soon as practicable and within a period which does not exceed 30 days.

However, if you are not satisfied with our handling of your concern, you may make a complaint to the Australian Information Commissioner (www.oaic.gov.au).

Effect of policy

We may update this Privacy Policy at any time by publishing an updated version on our website: www.LT.com.au.

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