Privacy Policy

Effective Date: June 16, 2025

Axiraa ("we," "our," or "us") is a business and property consulting firm committed to protecting the privacy of your personal information. This Privacy Policy outlines how we collect, hold, use, and disclose personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth), and our commitment to Artificial Intelligence (AI) integrity standards.

This policy applies to all personal information Axiraa collects, whether through our website, directly from clients, or third-party sources.

1. Open and Transparent Management of Personal Information (APP 1)

Axiraa is committed to managing your personal information openly and transparently. We will regularly review our information handling practices to ensure compliance with the APPs and best practices. This Privacy Policy is available on our website and can be provided in other forms upon request.

2. Anonymity and Pseudonymity (APP 2)

Where it is lawful and practicable, individuals cannot identify themselves, or use a pseudonym, when dealing with Axiraa. However, in most consulting engagements, identifying you is necessary to provide our services effectively.

3. Collection of Solicited Personal Information (APP 3)

3.1 Kinds of Personal Information Collected:

We may collect various personal information reasonably necessary for our functions and activities as a business and property consulting firm. This may include, but is not limited to:

  • Contact Information: Name, address, email address, phone number.

  • Identification Information: Date of birth, driver's license details, passport details (where required for specific services, such as property transactions).

  • Financial Information: Bank details, financial statements, income and expenditure details, tax file numbers (where relevant for financial or business consulting).

  • Business Information: Company details, ABN, business performance data, operational information.

  • Property Information: Property addresses, ownership details, historical data, and valuation information.

  • Professional Information: Occupation, employer, professional qualifications.

  • Communication Records: Correspondence, meeting notes, emails.

  • Website Usage Data: IP address, browser type, pages visited, time spent on site (collected through analytics tools, see section 6.2).

  • Sensitive Information: In limited circumstances, and only with your explicit consent or where required or permitted by law, we may collect sensitive information such as health information (e.g., if relevant to a business succession plan involving an illness), or membership of a professional association.

3.2 How We Collect Personal Information:

We collect personal information in several ways, including:

  • Directly from you: When you engage our services, complete forms, communicate with us via phone, email, or in person, or subscribe to our newsletters.

  • From third parties: We may collect information from publicly available sources (e.g., ASIC, land registries), your other professional advisors (e.g., accountants, lawyers) with your consent, or from data providers if relevant to our consulting services.

  • Through our website: When you visit our website, we may collect certain information automatically as described in Section 6.2.

3.3 Purposes of Collection:

We collect personal information for the following primary purposes:

  • To provide business and property consulting services, including advice, analysis, and recommendations.

  • To manage and administer our client relationships.

  • To communicate with you regarding our services, updates, and relevant industry information.

  • To comply with our legal and regulatory obligations.

  • For internal record-keeping, administrative purposes, and business analysis.

  • For marketing and promotional activities (where you have consented or we are otherwise permitted to do so).

4. Dealing with Unsolicited Personal Information (APP 4)

If we receive unsolicited personal information, we will determine whether we could have lawfully collected the information under APP 3. If we determine that we could not have, and the information is not contained in a Commonwealth record, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

5. Notification of the Collection of Personal Information (APP 5)

When we collect personal information from you or a third party, we will take reasonable steps to notify you of:

  • Our identity and contact details.

  • The fact that we have collected the information and the circumstances of that collection.

  • The purposes for which we collect the information.

  • The main consequences (if any) if all or some of the information is not collected.

  • The organisations or types of organisations to which we may disclose the information.

  • That this Privacy Policy contains information about how you may access and seek correction of your personal information and how you may complain about a breach of the APPs.

  • Whether we are likely to disclose personal information to overseas recipients and, if so, the countries where such recipients are likely to be located (if it is practicable to specify those countries in the policy).

6. Use or Disclosure of Personal Information (APP 6)

We will only use or disclose personal information for the primary purpose for which it was collected, or for a secondary purpose if:

  • You have consented to the use or disclosure.

  • You would reasonably expect us to use or disclose the information for the secondary purpose, and the secondary purpose is related (or directly related for sensitive information) to the primary purpose.

  • The use or disclosure is required or authorised by or under an Australian law or a court/tribunal order.

  • A "permitted general situation" exists (e.g., to prevent a serious threat to life, health or safety).

  • A "permitted health situation" exists (for sensitive information).

  • We reasonably believe that the use or disclosure is reasonably necessary for one or more enforcement-related activities conducted by, or on behalf of, an enforcement body.

6.1 Disclosure to Third Parties:

We may disclose your personal information to:

  • Our employees, contractors, and service providers who assist us in providing our services (e.g., IT support, administrative services, legal and accounting advisors).

  • Other professional advisors (e.g., accountants, lawyers, real estate agents) with your consent or as reasonably expected for the provision of our services.

  • Regulatory bodies or government agencies, where required by law.

  • Credit reporting bodies or financial institutions, if relevant to the services we provide, and with your consent.

6.2 Website Usage, Cookies, and Analytics:

Our website may use cookies and other tracking technologies to enhance your browsing experience and collect website usage data. This data may include your IP address, browser type, operating system, referring URLs, and pages visited. This information is generally used for analytical purposes (e.g., Google Analytics) to understand website traffic and improve our website, and it may not directly identify you.

We may also use aggregated and de-identified data for business intelligence and to improve our services. This data does not contain personal information.

6.3 Use of Artificial Intelligence (AI) and Machine Learning (ML):

Axiraa may leverage AI and ML tools to enhance our consulting services, improve efficiency, and generate insights. Our commitment to AI integrity means we adhere to the following principles:

  • Transparency: We will be transparent about using AI/ML in our processes where it directly impacts the handling or analysing your personal information.

  • Purpose Limitation: AI/ML systems will only process personal information for the purposes for which it was collected or for a related purpose that you would reasonably expect, in accordance with APP 6.

  • Data Minimisation: We strive to use only the necessary personal information for AI/ML processing, prioritising de-identified or aggregated data where possible.

  • Accuracy: We take reasonable steps to ensure that personal information used or generated by AI/ML systems is accurate, up-to-date, and complete (APP 10). We understand that AI models can sometimes produce inaccuracies, and we implement human oversight and verification processes to mitigate this risk, especially when the output impacts individuals.

  • Security: Personal information processed by AI/ML systems is subject to the same robust security measures as all other personal information we hold (APP 11).

  • Human Oversight: We ensure that AI/ML tools augment human decision-making, not replace it entirely, particularly in areas involving critical client advice or personal information. Human review and intervention mechanisms are in place.

  • Bias Mitigation: We are committed to identifying and mitigating potential biases in AI/ML systems and the data they process to ensure fair and equitable outcomes.

  • No Automated Decision-Making with Significant Impact: We will not use fully automated decision-making systems that significantly impact individuals without human oversight and the opportunity for individuals to challenge such decisions.

7. Direct Marketing (APP 7)

We may use your personal information (excluding sensitive information) for direct marketing purposes, such as sending you newsletters, updates on our services, or invitations to events, if:

  • We collected the information from you.

  • You would reasonably expect us to use or disclose the information for direct marketing.

  • We provide a simple means by which you can request not to receive direct marketing communications from us.

  • You have not made such a request.

If we collect sensitive information, we will only use or disclose it for direct marketing with your consent. You can opt out of receiving direct marketing communications from us at any time by contacting us using the details below or by using the unsubscribe link in our electronic communications.

8. Cross-Border Disclosure of Personal Information (APP 8)

Axiraa generally stores and processes personal information within Australia. However, in certain circumstances, and as part of our business operations (e.g., using cloud-based software or IT services with servers located overseas), your personal information may be disclosed to overseas recipients.

Where we disclose personal information to overseas recipients, we will take reasonable steps to ensure that the overseas recipient handles the personal information in accordance with the APPs, or that the disclosure is otherwise permitted under the Privacy Act. It is not practicable to list all countries where such recipients may be located, but they may include countries where our third-party service providers (e.g., cloud storage providers) operate.

9. Adoption, Use or Disclosure of Government-Related Identifiers (APP 9)

We will not adopt a government-related identifier (e.g., your Tax File Number) as our identifier for you. We will only use or disclose government-related identifiers in circumstances permitted by the Privacy Act.

10. Quality of Personal Information (APP 10)

We take reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, up-to-date, complete, and relevant, having regard to the purpose of the use or disclosure. This includes implementing internal procedures for data entry, regular data reviews, and encouraging you to notify us of any changes to your personal information.

11. Security of Personal Information (APP 11)

Axiraa takes reasonable steps to protect the personal information we hold from misuse, interference, and loss, and from unauthorised access, modification, or disclosure. Our security measures include:

  • Physical Security: Secure premises, restricted access to physical files.

  • Technological Security: Firewalls, encryption, secure networks, multi-factor authentication, regular security updates, and monitoring.

  • Access Controls: Restricting access to personal information to authorised personnel only, based on a "need-to-know" basis.

  • Staff Training: Educating our employees on privacy and data security obligations.

  • Data Breach Response Plan: Having a plan in place to respond to and manage any potential data breaches in accordance with the Notifiable Data Breaches scheme.

When personal information is no longer needed for the purpose it was collected, or when legally required, we will take reasonable steps to destroy or de-identify it securely.

12. Access to Personal Information (APP 12)

You have a right to request access to the personal information we hold about you. We will provide you with access within a reasonable time unless an exception under the Privacy Act applies (e.g., giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals).

To request access, please contact us using the details below. We may charge a reasonable fee to provide access to cover our administrative costs.

13. Correction of Personal Information (APP 13)

We take reasonable steps to ensure that the personal information we hold about you is accurate, up-to-date, complete, and relevant. If you believe that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading, please get in touch with us immediately. We will take reasonable steps to correct the information within a reasonable timeframe.

If we disagree with your request for correction, we will let you know of our reasons and give you information about how you can make a complaint. You may also request that we associate a statement with the information that you believe it is inaccurate, out-of-date, incomplete, irrelevant, or misleading.

How to Contact Us or Make a Complaint

If you have any questions about this Privacy Policy, wish to access or correct your personal information, or have a complaint about how Axiraa has handled your personal information, don't hesitate to get in touch with our office:

Email: admin@axiraa.com

We will acknowledge your complaint in writing and endeavour to resolve it within a reasonable timeframe. If dissatisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

Changes to this Privacy Policy

We may occasionally update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. We encourage you to review it periodically for any updates. The updated policy will be posted on our website, and the "Effective Date" at the top of the policy will be revised accordingly.