Policy Effective Date: 17 May 2023
No part of this documentation may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying or recording, for any purpose without express written permission of the Director of Hillpine Consulting Private Limited.
Why we have a Privacy Policy:
At HILLPINE CONSULTING PRIVATE LIMITED (“HILLPINE CONSULTING”), we recognise the importance of protecting and maintaining your personal information and that of the engaging ultimate client. We appreciate that you may have concerns about your privacy and about the security, accuracy and confidentiality of personal information.
HILLPINE CONSULTING strives to provide highest quality professional services whilst simultaneously preserving and protecting your privacy. In the event the legal form of end-client is formed and set-up outside India, HILLPINE CONSULTING will abide by the governing Privacy Principles of the relevant privacy laws applicable to the country of the client. (Hereinafter referred to as “Relevant Privacy Laws”)
This Privacy Policy sets out how HILLPINE CONSULTING collects, receives, processes and handles personal information. This policy may be modified from time to time to reflect our current privacy practices.
HILLPINE CONSULTING is a boutique consulting firm that collaborates and works alongside independent, standalone, and mid-sized international consulting firms and undertakes end-to-end execution of financial due diligence projects for their clients from an India based extended team.
In this Privacy Policy, ‘HILLPINE CONSULTING’, ‘we’, ‘us’ and ‘our’ refers to HILLPINE CONSULTING or any entity owned or controlled by a HILLPINE CONSULTING
Moreover, in this Privacy Policy, ‘you’ and ‘your’ includes the Client as well as the ultimate engaging client.
Upon using or accessing our services, You consent to bind Yourself to this Privacy Policy and agree to our use of Your information including personal information (including sensitive personal information) in accordance with this Privacy Policy. If You do not consent to any of the terms enumerated in this Policy, We request You to not proceed with availing our services.
What we are doing:
Open and transparent management of personal information:
HILLPINE CONSULTING manages personal information received during any consulting mandate from the Client in an open and transparent way by complying with the Relevant Privacy Act Principles. We will remain transparent about what type of personal information we collect, process, maintain and the ultimate purpose for which information is sought and analysed.
Please contact our Privacy Officer in writing either electronically or otherwise if you have reasons to believe that HILLPINE CONSULTING is in breach of Relevant Privacy Act Principles and/or privacy policy. We aim to provide an official response within 30 days.
Collection of solicited personal information:
Our ability to provide you with a comprehensive consulting service is dependent on us obtaining certain personal information. This might include information in whatever form (including, without limitation, in written, oral, visual or electronic form or on any magnetic or optical disk or memory and wherever located) relating to the business, customers (including the customers’ names, signature, address, phone number, date of birth, voice print and facial recognition biometric), products, projects, envisaged transactions, affairs and finances of the Clients or of the engaging ultimate client and trade secrets including, without limitation, technical data and know-how relating to the Business of the Client or any of its suppliers, customers, agents, distributors, shareholders, management or business contacts, and including (but not limited to) information that the Consultant Company or the Individual creates, develops, receives or obtains in connection with his Engagement, whether or not such information (if in anything other than oral form) is marked sensitive/confidential. You can choose to withhold such information, however, this may have a bearing on the services we offer.
Some personal information is considered to be ‘sensitive/confidential information’. It may be necessary in some instances for HILLPINE CONSULTING to collect sensitive/confidential information about the Client and/or the Ultimate engaging Client, for example, their Tax File Number, professional memberships etc.
HILLPINE CONSULTING will collect information that is reasonably necessary for the primary purpose of providing a professional service to the Client and/or the Ultimate Engaging Client and we may disclose such information with other entity(ies) solely for the purpose of providing our consultancy and professional services and also for complying with our legal obligations. If this information is considered sensitive/confidential, then unless the law provides otherwise, HILLPINE CONSULTING will also require your consent to the collection of this sensitive/confidential information. We will only collect sensitive/ confidential information if it is necessary to provide our services to you.
Dealing with unsolicited personal information:
If HILLPINE CONSULTING receives unsolicited personal information that otherwise would have been sought from you, we will observe the same privacy protection for such information as if we had solicited this personal information.
If the information is not reasonably necessary for one or more of HILLPINE CONSULTING’s scope of service or we know that we could not normally have collected the personal information, we will destroy or de-identify the information as soon as practicable, unless it is unlawful or unreasonable to do so.
Notification of the collection of personal information:
HILLPINE CONSULTING will endeavour to collect personal information directly from you, however, at times HILLPINE CONSULTING may need to collect personal information from a third party and when this occurs, we will inform you. We will also be clear about the purpose of the collection, who we might disclose this information to, whether the personal information is required under an Australian law or a court/tribunal order and the main consequences of not collecting this information.
In some circumstances, HILLPINE CONSULTING may use third party service providers to carry out part of the services and HILLPINE CONSULTING shall ensure that the third-party service providers agree to abide by the terms of this Policy.
Use or disclosure of personal information:
HILLPINE CONSULTING will not use or disclose personal information collected by us for any purpose other than for addressing and providing the services for which the information is collected (i.e. the primary purpose) unless you would reasonably expect us to use or disclose the information for a secondary purpose or your consent has been obtained to use the information for additional purposes.
Exceptions to this include where disclosure is:
Where HILLPINE CONSULTING has collected the information from you, we may use this information for the purpose of direct marketing, to conduct surveys, to notify of seminars and other events, to seek your feedback and for any other business-related purposes.
Direct marketing:
HILLPINE CONSULTING may use or disclose the received personal information we hold about you for the purpose of direct marketing, such as articles that may be of interest to you, if there is a reasonable expectation that your personal information will be used for this purpose and you have not opted out of receiving direct marketing communications from us, or where you have provided your consent.
HILLPINE CONSULTING will not directly market to you using information that is considered sensitive/confidential unless you have provided consent.
You may request not to receive direct marketing communications from us or request us not to use or disclose the information for the purpose direct marketing by making a request to the Privacy Officer in writing. We will give effect to the said request within a reasonable period following the receipt of request.
Cross-border disclosure of personal information:
HILLPINE CONSULTING may transfer or store your personal information outside Australia if we engage with, or are required to send personal information to, an overseas entity/person to fulfil the purpose for which the personal information was collected (or a related or ancillary purpose).
If we do disclose personal information to an overseas recipient without your consent, we will take reasonable steps to ensure that this recipient does not breach the Australian Privacy Principles or a similar applicable law in relation to that information.
Adoption, use or disclosure of government related identifiers:
HILLPINE CONSULTING will not adopt, use or disclose government agency identifiers, for example, tax file numbers, as our primary means of identifying you unless it is required or authorised by or under Applicable law or a court/tribunal order.
Quality of personal information:
Our goal is to ensure, that at all times, the personal information we collect, hold, use or disclose is up to date, accurate and complete. We will take reasonable steps to correct personal information. If you become aware, or believe, that any personal information we hold is inaccurate, incomplete or out of date, please contact your relationship manager or the Privacy Officer at the details provided below.
Security of personal information:
HILLPINE CONSULTING takes the security of your personal information very seriously. We have implemented significant measures and precautions to protect the personal information we hold (electronic and physical) from such risks as misuse, interference and loss, and from unauthorised access, modification or disclosure. We take reasonable steps to destroy or permanently de-identify any personal information no longer required.
Access to personal information:
You may at any time request access to personal information that HILLPINE CONSULTING holds about you. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held.
If HILLPINE CONSULTING were to refuse to give access to the personal information, or in the manner requested, we will provide written notice of the reasons (unless unreasonable to do so) and details should you wish to complain about the refusal. Generally, a refusal will only be in cases where denying such access is permitted under the Relevant Privacy Act Principles, Indian laws or is otherwise lawful.
All requests for access to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period (but not more than 30 days) after the request is made. HILLPINE CONSULTING may charge a fee for supplying personal information.
Correction of personal information:
If you request us to correct the information, we will take reasonable steps to do so. If a third party is relying on this information, at your request we will also notify them, unless it is impracticable or unlawful to do so. However, we shall not be responsible in any manner for corroborating the authenticity of the information furnished by you.
All requests for correction to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period after the request is made. We will not charge you for making the request for the correction of personal information.
Privacy on our website:
When you visit any part of our website, we collect statistical data about that visit (e.g. what you looked at, the way in which you moved around the site, etc). We use this information to make our sites more useful and easily navigable.
Cookies:
The HILLPINE CONSULTING website may uses cookies to track how users navigate within the site and to recognise returning visitors. A ‘cookie’ is a small text file that is saved onto your computer or other device to record this information. The information is used to improve the site’s performance and provide users with more relevant content. Most websites you visit will use cookies.
You may withdraw your consent to our use of certain cookies at any time by disabling the use of cookies on your web browser. Please note, however, that blocking certain types may impact your experience of our site and its functionality. See ‘Blocking cookies’ below for information on how you can manage your cookie preferences.
Types of cookies we use:
Essential cookies: These cookies are strictly necessary to operate core functions and features on our websites. Without these cookies our site may not work as you would expect and you may not be able to do such things as logging in or registering with us.
Personalisation/Functional cookies: We use these cookies to understand how you use our site and consume our information, so we can provide a more personalised experience.
Analytics cookies: We use Google and other Analytics cookies and tools to analyse how our websites are being used in aggregate, so that we can assess and improve the quality of experience we provide to our site users generally.
External Web Services:
We sometimes use external web services to display embedded content on our website, for example to display images, videos or feedback surveys. We cannot stop these services collecting information on your
use of this embedded content. See ‘Blocking cookies’ below for information on how you can manage your cookie preferences on your device.
Email communications:
On certain email communications, HILLPINE CONSULTING may use technology to determine whether the recipient has read, clicked on, or forwarded the email. This information is used to assess whether the content was relevant to the recipient. Where this technology is used, you will have the option to unsubscribe from the distribution list if you do not wish for HILLPINE CONSULTING to receive this information.
Blocking cookies:
Most web browsers give you the option to either allow or block cookies for selected sites or to delete the cookies that have already been recorded. Refer to the ‘Help’ section of your browser for instructions on how to do this. Please note, however, some site functionality may be affected if certain cookies are disabled.
How to contact us:
All requests for access or correction to personal information, privacy complaints, requests for access to personal information, queries in relation to this Privacy Policy, or any other privacy related matter, should be directed to the Privacy Officer at HILLPINE CONSULTING as follows:
The Privacy Officer
Your enquiry may be directed to the Privacy Officer of the relevant firm within the HILLPINE CONSULTING association that services your needs.
We will respond to your request within a reasonable time and in accordance with the requirements of the Privacy Act.
The Contact Details of the Privacy Officer as under:
If you have made a privacy complaint and believe that HILLPINE CONSULTING has not adequately handled your complaint, you may complain to the to the concerned authority under the Relevant Privacy Act.
