Privacy Policy

Last updated: 18 August 2026

ACAM is a business services brand operated by Astra Capital Asset Management Pty Ltd (ABN 92 627 079 574), providing bookkeeping, payroll, governance reporting, company secretarial, and related services to business clients ("Services", "we", "us", "our"). This Privacy Policy explains how we collect, use, hold, and disclose personal information when you visit our website, engage us for Services, or otherwise interact with us.

This policy is written to comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). By using our website or engaging our Services, you acknowledge that you have read and understood this policy.

1. The two kinds of personal information we handle

Because of the nature of our Services, we handle personal information in two distinct ways, and it's important to understand the difference:

a) Information about you, as a visitor or prospective client — collected when you browse our website, fill in a contact form, or communicate with us directly.

b) Information we process on behalf of our clients — when a business engages ACAM for bookkeeping, payroll, or company secretarial services, we process personal information about that client's own customers, employees, or contacts (for example, payroll data about a client's staff) strictly on that client's instructions, in order to deliver the Services. In this second case, our client remains responsible for that information under privacy law, and we act as their service provider — we don't use it for our own purposes.

This policy primarily addresses category (a). Where we process information under category (b), our handling of it is governed by our services agreement with the relevant client.

2. Personal information we collect

Depending on how you interact with us, we may collect:

• Contact details — name, business name, email address, phone number, and postal/business address
• Enquiry and communication information — anything you submit through our contact form, or tell us by phone, email, or in person
• Engagement and onboarding information — where you become a client, information needed to provide Services, such as ABN, entity structure, financial and accounting records, and details relevant to bookkeeping, payroll, or ASIC compliance
• Website usage information — pages visited, time spent, referring pages, and general interaction data
• Device and technical information — IP address, browser type, and device information, collected automatically via cookies and similar technologies

We do not collect financial account or payment card details through our website; any such information is collected securely as part of the client engagement process, not via public web forms.

3. How we collect personal information

We collect personal information:

• Directly from you — when you fill in our contact form, email or call us, or engage us as a client
• Automatically — through cookies and similar technologies when you use our website
• From our clients — where we are engaged to deliver bookkeeping, payroll, or governance services, and the client provides us with information (including about their own staff or contacts) needed to perform those Services
• From third parties — such as an accountant, adviser, or other professional a prospective client has asked to contact us on their behalf

4. How we use personal information

We use personal information to:

• Respond to enquiries and provide information about our Services
• Onboard and manage our relationship with clients
• Deliver bookkeeping, payroll, governance reporting, company secretarial, and related Services
• Meet our own legal and regulatory obligations (for example, ASIC or ATO-related reporting we undertake on a client's behalf, under their instruction)
• Improve our website and how we communicate with visitors and clients
• Comply with applicable law, or respond to a legal process

We do not use personal information collected through our website for unrelated marketing purposes without your consent, and we do not sell personal information to third parties.

5. How we disclose personal information

We may disclose personal information to:

• Service providers we engage to help deliver our Services — including cloud-based accounting, payroll, and governance/board-reporting platforms, which may store data on servers located outside Australia. Where this occurs, we take reasonable steps to ensure those providers handle personal information consistently with the Australian Privacy Principles.
• Professional advisers — such as your accountant or legal adviser, where you've asked us to coordinate with them, or where doing so is necessary to deliver the Services
• Regulatory bodies — such as ASIC or the ATO, where required as part of the compliance services we provide
• Our related entities — within the Astra Capital group, where necessary for administrative or compliance purposes
• Where required by law — including in response to a subpoena, court order, or valid regulatory request

We do not disclose personal information for the purposes of another organisation's direct marketing.

6. Cookies and website analytics

Our website may use cookies and similar technologies to understand how visitors use our site and to improve its performance. You can control or disable cookies through your browser settings; doing so may affect some website functionality.

7. Data security and retention

We take reasonable technical and organisational steps to protect personal information from misuse, loss, and unauthorised access. No online transmission or storage system can be guaranteed completely secure, and we recommend not sending highly sensitive information (such as full financial account details) through unsecured channels like standard email.

We retain personal information only as long as reasonably necessary to fulfil the purposes described in this policy, including to meet legal, accounting, or reporting obligations — which, for financial and business records, may require retention for several years under Australian tax and corporations law.

8. Your rights

Under the Australian Privacy Principles, you have the right to:

• Access the personal information we hold about you
• Request correction of personal information that is inaccurate, out of date, or incomplete
• Make a complaint about how we've handled your personal information

To exercise any of these rights, contact us using the details below. We'll respond within a reasonable timeframe, and may need to verify your identity before actioning a request.

If you're not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

9. Overseas disclosure

Some of the third-party platforms we use to deliver our Services may store or process personal information outside Australia. Where this occurs, we take reasonable steps to ensure the overseas recipient handles the information in a manner consistent with the Australian Privacy Principles.

10. Children's information

Our Services are directed at businesses, not children. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information about a child, please contact us and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our practices or for legal or operational reasons. The updated version will be posted on this page with a revised "Last updated" date.

12. Contact us

If you have questions about this Privacy Policy, or wish to exercise any of your rights, please contact us:

ACAM Astra Capital Asset Management Pty Ltd ABN 92 627 079 574 Level 54, ONE ONE ONE, 111 Eagle Street, Brisbane City QLD 4000 Email: clientservices@acam.net.au