Privacy Policy

Introduction

At Vow Sourcing Pty Ltd ("Vow Sourcing," "we," "us," or "our"), we are committed to protecting your privacy and the confidentiality of your personal information. As a provider of sensitive financial and outsourcing services, we adhere to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Policy details how we manage personal and credit information related to our core services: Outsourcing, Accounting, Bookkeeping, Paraplanning, Virtual Assistant and Mortgage Broker Support Services.

1. Information We Collect

A. Personal Information (PII)

This includes data that can identify an individual:

• Contact Data: Name, job title, company name, address, email address, phone number.
• Financial & Accounting Data: Transaction records, payroll details, asset/liability information, Tax File Numbers (TFNs) for Accounting and Bookkeeping services.
• Sensitive Financial Data (Mortgage Broking & Paraplanning): Income, employment details, financial history, family status, bank account information, liabilities — collected only with consent or when legally required.
• Website Usage Data: IP address, browser type, pages visited, time spent on the website.

B. Credit Eligibility Information (CEI)

For Mortgage Broking services, we may collect and use Credit Eligibility Information (CEI), including credit reporting information obtained from credit reporting bodies (CRBs). This is managed in strict compliance with the credit reporting provisions of the Privacy Act.

2. How and Why We Collect and Use Your Information

We collect personal information through the following methods and for the following purposes:

Directly from You

To respond to inquiries, provide quotes, manage invoicing, and perform Accounting, Bookkeeping, and Paraplanning services.

From Our Clients

To execute outsourcing tasks on your behalf (e.g., processing loan files, data entry, payroll administration).

From Third Parties

Mortgage Broking: from lenders, valuation companies, and CRBs. Paraplanning: from financial product providers.

Website & Technology

To analyse website performance, track user movements, and enhance security and user experience.

3. Data Processing Roles and Responsibilities

When we receive personal information about third parties (e.g., your customers/leads) for Outsourcing or Bookkeeping tasks:

• You (Our Client) remain the Data Controller — responsible for obtaining consent and instructing us on data use.
• Vow Sourcing acts as the Data Processor — handling data according to your lawful written instructions and the service agreement.

4. Disclosure of Information

We do not sell, trade, rent, or lease your personal information for marketing purposes. We may disclose personal information only where necessary:

• Financial Partners: Banks, credit providers, mortgage insurers for Mortgage Broking purposes.
• External Professionals: Auditors, legal advisors, consultants.
• Outsourced Team Members: Trained staff globally who require access to deliver contracted services (e.g., a dedicated bookkeeper).
• Regulatory Authorities: ATO, ASIC, or law enforcement where required by law.

Any transfer of data outside Australia will be done with assurances that recipients adhere to security and privacy standards substantially similar to the APPs.

5. Data Security, Storage, and Retention

We take reasonable steps to protect personal information from misuse, loss, or unauthorised access:

• Security Measures: Encryption, multi-factor authentication, restricted physical access, password-protected internal workstations.
• Confidentiality: All employees and contractors are bound by confidentiality agreements.
• Retention: We retain personal information only as long as necessary to provide services or to meet legal/regulatory obligations (e.g., minimum seven years for financial records). After that, data is securely destroyed or de-identified.

6. Accessing, Correcting, and Deleting Your Information

You have the right to request access to personal information we hold and to request correction of inaccurate, incomplete, or out-of-date data. To request access, correction, or deletion, send a written request to our Data Privacy Officer. We will verify your identity before proceeding.

7. Direct Marketing and Opting Out

We may use your contact details to provide information about services we believe may interest you. You can opt out at any time by clicking the 'unsubscribe' link in marketing emails or by contacting our Data Privacy Officer.

8. Complaints and Concerns

If you believe we have breached the Australian Privacy Principles or have concerns about how we handled your personal information or CEI, contact our Privacy Officer immediately. We will acknowledge your complaint promptly and investigate, providing a formal response within 30 days.

If you remain unsatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner.

9. Contact Us