The NOT so Silent Business Partner

Doolan Consortium Pty Ltd ABN 16 100 864 266 trading as "The NOT so Silent Business Partner" · BAS agent 28785005

Earlier versions:www.thenssbp.com.au/terms-and-conditions/archive

Version 2.0 - 01 November 2026

Doolan Consortium Pty Ltd ABN 16 100 864 266, trading as "The NOT so Silent Business Partner" ("we", "us", "our"), provides general business, bookkeeping, payroll and BAS agent services. As a referral partner, we can also introduce you to providers of finance products and solutions. We do not hold an Australian Financial Services Licence or an Australian Credit Licence.

These Terms apply together with your Letter of Engagement. If the two differ, these Terms apply, except for the items specific to you in your Letter of Engagement (the entities covered, your services, your fees, your start date, and any consents and authorities you give in it), where your Letter of Engagement applies. If anything in these Terms conflicts with our obligations under the Tax Agent Services Act 2009 (Cth) or the Code of Professional Conduct, those obligations apply.

Information we give you, on www.thenssbp.com.au or otherwise, is general information only. It is not financial product or investment advice and does not take into account your objectives, financial situation or needs. Before acting on it, you should seek independent advice that does.

1. Confidentiality

1.1 Our promise. Information about your business, its performance, its clients and its people is confidential ("Confidential Information"). We keep it confidential and use it only to provide our services, as clause 10.3 allows, and to meet our legal and professional obligations. We never use it for our own benefit or sell it.

1.2 When we may share it. We may disclose Confidential Information only as reasonably needed:

• to our team, on a "need to know" basis (including for technical advice and quality control reviews);

• to employees and subcontractors, in Australia and overseas (including our outsourcing partner Echo Global Pty Ltd in the Philippines), who help complete the agreed work;

• to Valont group companies that help us deliver our services;

• to our cloud, software and AI providers, on the basis in clause 10;

• to your tax agent or accountant, and other advisers you nominate;

• to the ATO, the Tax Practitioners Board and other agencies when we act for you or the law requires, and to our insurers and professional advisers on a confidential basis; and

• to a buyer of our business under a written confidentiality agreement.

Everyone we share it with is bound by confidentiality obligations at least as strict as ours, and we remain responsible for them.

1.3 Not confidential. This clause does not apply to information that is, or becomes, public other than through a breach of confidentiality.

1.4 Your materials. Your records, concepts, proposals and materials, and any copies we make of them, remain your property. We use them only for your engagement.

2. Who you are engaging

2.1 Our business. You are engaging Doolan Consortium Pty Ltd ABN 16 100 864 266, trading as "The NOT so Silent Business Partner". We are a registered BAS agent, number 28785005. You can confirm our registration on the Tax Practitioners Board (TPB) register at www.tpb.gov.au/public-register, by searching our name or BAS agent number.

2.2 Part of the Valont group. Since [August 2026], we have been part of the Valont group of companies. Your engagement remains with us, and our team continues to look after you.

2.3 Insurance. As required by the Tax Agent Services Act 2009 (Cth), we hold professional indemnity insurance to the level specified by the TPB.

2.4 Professional memberships. Our firm, or people within our firm, are members of:

• the Australian Bookkeepers Network (www.austbook.net); and

• [Australian Bookkeepers Association / Institute of Certified Bookkeepers – confirm memberships]

As members, we are bound by their codes of conduct, ethics and professional standards, including continuing professional education.

2.5 Your contact. Blake Doolan · 0401 029 293 · blaketd@thenssbp.com.au · PO Box 124, Berowra Heights NSW 2082.

3. Our obligations under this agreement

3.1 The Code. Our conduct as a BAS agent is regulated by the TPB and by the Code of Professional Conduct in the Tax Agent Services Act 2009 (Cth) and the Tax Agent Services (Code of Professional Conduct) Determination 2024. The Code sets out the professional and ethical standards required of tax and BAS agents, including:

• honesty and integrity;

• independence, and managing conflicts of interest;

• confidentiality;

• competence, and taking reasonable care to ascertain your state of affairs and to apply the taxation laws correctly; and

• other responsibilities, including upholding the proper administration of the taxation laws, not making false or misleading statements to the ATO or the TPB, maintaining professional indemnity insurance, and responding to requests and directions from the TPB.

3.2 More information. You can find out more about the TPB and the Code, and view our registration details, at www.tpb.gov.au. The TPB has published an Information for clients fact sheet, which explains your rights and our obligations. Please read it, and ask us if you have any questions.

3.3 Matters you should know. Under section 45 of the Tax Agent Services (Code of Professional Conduct) Determination 2024, we confirm that, having made reasonable enquiries, we have nothing to declare. [Other matter: we joined the Valont group in [August 2026] and share some systems and staff with it.] We will update this information when it changes and at least once a year.

3.4 Safe harbour. One of the benefits of using a BAS agent is the "safe harbour" from some ATO penalties. Broadly, penalties will not apply where:

• a false or misleading statement is made carelessly, provided you took reasonable care by giving us the information needed to make the statement; or

• a document (such as an activity statement) is not lodged on time in the approved form because of our carelessness, provided you gave us the information we needed in time.

3.5 False statements. If we believe you have made a false or misleading statement to the ATO, we will tell you the consequences and how to correct it. If it is not corrected, we may have to stop acting for you.

4. Complaints

4.1 Talk to us first. If you have a complaint about our services, please contact Blake Doolan on 0401 029 293 or at blaketd@thenssbp.com.au. We will acknowledge your complaint within 1 business day and aim to resolve it within 30 days.

4.2 Escalating to the TPB. If we cannot resolve the issue, or you are not satisfied with how your complaint was handled or with the outcome, you can complain to the Tax Practitioners Board. Complaints to the TPB must be made in writing using its online form at https://myprofile.tpb.gov.au/complaints/.

4.3 Other avenues. You may also refer concerns about our ethical or business practices to the Australian Bookkeepers Network, and privacy complaints to the Office of the Australian Information Commissioner at www.oaic.gov.au.

5. Client / business owner responsibilities

5.1 Records and information. You will give us access to the business records we need for the period, on time and in a properly arranged manner. If records are not provided this way, extra charges may apply. This may include, but is not limited to:

• ongoing access to your business software;

• bank and credit card statements;

• receipts, invoices and other source documents;

• deposit and bank transfer information; and

• answers to our queries, when we ask.

5.2 Maintaining records. Unless we agree otherwise in writing, you are responsible for maintaining your business records, keeping them accurate and secure, protecting against fraud, and making them available to us and to the authorities when required. You must keep all records the ATO requires, generally for 5 years. You are personally responsible for the information in any statutory return.

5.3 Our reliance on you. We may ask for source documents for some items and process other transactions based on the information you give us, which may not include all source documents. If you tell us in writing that you hold a valid tax invoice and GST applies, we will process on that basis. We do not audit your records.

5.4 Invoices we prepare for you. When we create invoices for your customers, you must review all information before they are sent. You confirm that everything, including your bank account details, is correct before the invoice goes to your customers.

5.5 Payment batches. When we create payment batches, you must review all information, including each payee's bank account details, before you approve the payments in your banking gateway. You release payments; we do not.

5.6 Bank details. You must give us accurate and complete bank account details, and tell us promptly in writing of any change. We will check any new or changed payee bank details through a separate channel before use. We are not liable for any loss or delay caused by incorrect or incomplete bank details provided by you or your suppliers where we have followed that process.

5.7 Supplier ABNs. The ATO requires supplier ABNs to be checked at least once a year to make sure they are valid.

5.8 Timing. You must provide the documents and information we need by the dates we agree. We are not liable for penalties if they are not provided as agreed.

5.9 Your tax agent. You authorise us to contact your tax agent by email and phone as required.

5.10 Your decisions. You remain responsible for your business decisions and your legal obligations as a business owner and employer. Engaging us does not transfer them to us.

6. Payroll matters

6.1 Our role. We are engaged to assist your business with managing and administering payments to all employees. We will pay your employees in accordance with the Fair Work Act 2009 (Cth), the National Employment Standards and the modern award or enterprise agreement that applies to each employee, and we will liaise with the Fair Work Ombudsman for interpretation where needed. We do not simply process the rates you tell us to pay.

6.2 What we need from you. Award classification depends on each employee's actual duties, hours and type of employment. You must give us accurate and complete information about these, approved timesheets and leave, and any change before the relevant pay run. You approve each pay run before it is paid, and you fund wages and superannuation on time, including super on each payday under Payday Super.

6.3 If something is wrong. If we identify that an employee is being, or has been, paid less than their legal minimum entitlement, we will notify you immediately in writing, explain what needs to change, and work with you to correct it, including any back-payment. Since 1 January 2025, intentionally underpaying wages or superannuation can be a criminal offence, and people involved in an underpayment, including payroll providers, can also be liable.

6.4 If it is not fixed. We will not process pay that we know is below the legal minimum. If the underpayment is not corrected within [14] days of our written advice, we will stop providing payroll services and will end our engagement with you. [You authorise us to notify the Fair Work Ombudsman of an underpayment that remains uncorrected after our written advice.]

6.5 Limits. We apply awards; we do not provide legal advice on employment contracts, disputes, dismissals or workplace investigations. We will refer complex matters to an employment lawyer or HR specialist. You remain legally responsible as the employer, and we are not liable for underpayments that result from inaccurate or incomplete information you give us.

7. Lodgement of information with the ATO

7.1 Authorisation first. The law requires your authorisation for each lodgement, including activity statements, STP finalisation and payment summaries, and TPAR reports (if applicable). We will provide an authority form before each lodgement and lodge only after we receive it. Email authorisation is acceptable.

7.2 Late lodgement. Failure to lodge on time can incur penalties. If we have not received your authorisation in time, those penalties are your responsibility.

7.3 Authority to act. You authorise us to act for you with the ATO on BAS matters, including adding you to our client list and accessing your activity statement information. Where the ATO requires it, you must nominate us in Online services for business.

8. Communication

8.1 Keep us informed. You must keep us informed of your current business details, including address, phone and email. We are engaged and authorised to work with your business by the people named in your Letter of Engagement. Please tell us of any change to your personnel, or to their authority, that affects our work.

8.2 Electronic communication. We communicate and send documents electronically. Email carries risks that cannot be fully removed, and we will never change our own bank details by email alone. If you receive a request to pay us to new bank details, call us on a number you already have before paying.

9. Review of documentation

9.1 Your review. You are responsible for reviewing final reports and work before relying on them.

9.2 Corrections. We will not charge you to correct errors that are clearly our fault. Revisions you ask for may be charged for the time involved, and we will discuss this with you first.

10. Technology, automation and AI

10.1 We use AI. We use cloud software, automation and artificial intelligence (AI) tools, including large language models, to help deliver our services faster, more accurately and more consistently. Some are part of the Valont group's systems and some are built into software you or we use, such as Xero, MYOB or Dext.

10.2 We stay responsible. Our use of AI does not change our obligations under these Terms, the Tax Agent Services Act 2009 (Cth) or the Code of Professional Conduct. AI-assisted work is reviewed under our quality management system. A qualified person approves anything lodged with the ATO and any professional advice from our team, and our team reviews pay runs and payment files before they are sent for your approval. AI tools do not lodge, approve payments or make decisions that significantly affect you without a person. Insights, forecasts and alerts produced by our systems are general information, not advice.

10.3 Your data. You permit us to disclose your information to our AI and technology providers to deliver our services. AI providers we engage are bound by confidentiality, may not train their own general models on your data, and keep it only as long as needed to provide their service and for security monitoring. AI features built into third-party software you or we use (such as accounting, payroll or receipt-capture software) are governed by those providers' terms. The Valont group may use your data once it has been de-identified, so that neither you nor any individual can reasonably be identified, to improve, develop, train and test its products, services and AI tools, and to produce benchmarks. We never use tax file numbers or sensitive information for this. You can opt out at any time by emailing blaketd@thenssbp.com.au, and your opt-out applies from the date we receive it.

10.4 Overseas. Some providers process or store data outside Australia, including in the United States, and some of our team members work from [the Philippines and Indonesia] (see clause 11). We take reasonable steps to ensure your information is protected to Australian standards.

10.5 Your choices. Our Privacy Policy explains how we use AI and automated processing. You can ask us how AI is used on your work, or ask a person to review any AI-assisted work or decision, at any time.

10.6 Your own AI use. If you use AI to prepare information or instructions you give us, you are responsible for checking them.

11. Information relating to your affairs and third-party suppliers

11.1 Our team and contractors. Employees, contractors and outsource providers may help complete the agreed work. All are bound by our Operations Manual and confidentiality obligations consistent with clause 1.

11.2 Outsourcing. We have an outsourcing arrangement with Echo Global Pty Ltd in the Philippines, which supports our bookkeepers and provides administrative services. [Valont group team members in Indonesia may also assist.] They work under our supervision, through our systems and with individual secure logins. You authorise us to disclose information about your affairs to them as needed for this work.

11.3 IT and cloud providers. We and our contractors use external IT and cloud providers, such as Google, Microsoft, Xero, MYOB and Dext, to deliver our services. This may mean information about you and your entities is stored overseas. You authorise us and our contractors to disclose information to these providers as needed.

11.4 Still our responsibility. Where we use third parties, we remain responsible for their conduct, supervision and activities, and for delivering the services we are engaged to perform.

12. Billing information

12.1 Packages. A fixed package fee can be set only after 3 months of work, so that the quote is accurate. Until then, we charge as set out in your Letter of Engagement.

12.2 Invoices. We send an invoice on completion of work for each calendar month, week or visit, as set out in your Letter of Engagement. A minimum charge of 2 hours applies to each onsite visit.

12.3 Payment terms. Payment is due within 7 days of the invoice date, unless we have agreed different terms in writing.

12.4 Fee reviews. We review our fees annually, generally in line with CPI. We will give you at least 30 days' written notice of any increase, and you may end the engagement before it applies without any exit fee.

12.5 Late payment. If payment is not made by the due date without a prior arrangement, we may charge interest of [2% per month, calculated simply,] on the overdue amount. If payment is still outstanding after a reminder, we may stop work, other than telling you about upcoming lodgement deadlines, until it is paid. Debts outstanding beyond 30 days (unless a payment arrangement is in place) may be referred to a debt collection agency, and reasonable recovery costs will be passed on to you.

12.6 Software and third-party costs. Where we hold software subscriptions or pay third-party costs for you, you pay the amount on your invoice, which may include an administration fee. Providers may change their prices, and we will pass those changes on.

12.7 Phone support. A charge applies for extended phone support that is not part of a quoted telephone support package.

12.8 Cancellation. We may charge a fee if an appointment is cancelled on the day.

12.9 Commissions. As a normal part of our business, we or the Valont group may receive commissions, rebates or referral fees from software providers and other third parties, and you agree we may keep them. If we refer you to a finance broker, lender, insurer or other adviser who pays us for the referral, we will tell you at the time.

13. Ownership of the accounting software file and your records

13.1 Your data. The data in your accounting software file, your source documents and the reports we prepare for you belong to you.

13.2 Software licences we hold. If our licence for accounting software is used for your business, a licence removal fee may be charged when our services end. If you wish to take over or transfer the licence, we will transfer it to you or your new provider.

13.3 Our materials. Our working papers, methods, templates, checklists, software and systems belong to us or the Valont group, as do de-identified data and the models, prompts and tools the Valont group develops from it. We will give you copies of working papers you reasonably need.

13.4 No lien. We will not withhold your records, software file or data because fees are unpaid. [Replaces the previous right of lien – confirm.]

13.5 Backups. We keep backups of our bookkeeping work for our own records, but you should make sure all your business electronic data is backed up securely.

13.6 Collection and destruction of documents. When we ask, during or after our engagement, you must collect any of your physical property we hold. If it remains with us after our request, we will hold it for three months and then securely destroy it. We keep our own records for as long as the law and our professional obligations require.

14. Working standards

14.1 Onsite work. When working onsite, we expect a safe and reasonable working environment, including a suitable chair, office space and a non-smoking area.

14.2 Respect. We expect our team to be treated with courtesy, and we will treat you and your team the same way.

15. Liability and indemnity

15.1 Consumer law. Nothing in these Terms excludes any right you have under the Australian Consumer Law that cannot lawfully be excluded. Where the law allows, our liability for failing to meet a consumer guarantee is limited to supplying the services again or paying the cost of doing so.

15.2 Limit. Subject to clause 15.1, our total liability arising out of or in connection with our services is limited to the fees paid or payable in the 12 months before the event giving rise to the claim. Neither party is liable for indirect or consequential loss, or loss of profit, revenue or opportunity.

15.3 Shared responsibility. Our liability is reduced to the extent you contributed to the loss, including by giving us incomplete, inaccurate or late information or approvals.

15.4 Indemnity. You agree to indemnify us against third-party claims to the extent they arise from information or instructions you gave us that you knew, or should reasonably have known, were false or incomplete.

15.5 Exceptions. Clauses 15.2 to 15.4 do not limit liability for fraud, wilful misconduct, death or personal injury, any liability that cannot lawfully be limited, or your obligation to pay fees.

16. Ending the engagement

16.1 On notice. Either of us may end the engagement by giving at least 30 days' written notice (email is fine), unless your Letter of Engagement says otherwise.

16.2 Immediately. We may end the engagement immediately by written notice if fees remain unpaid after a reminder, if continuing would breach the law, the Tax Agent Services Act 2009 (Cth) or the Code (including under clauses 3.5 and 6.4), or if you or your representatives are abusive towards our team.

16.3 Handover. When the engagement ends, you pay for services provided up to the end date. We will tell you of any lodgements due or overdue, hand over your records and software access, and remove you from our ATO client list. You should also remove our nomination in Online services for business.

17. Transfer and subcontracting

17.1 Valont group. We may transfer this engagement to another Valont group company, or to a buyer of our business, that is a registered BAS agent with professional indemnity insurance meeting the TPB's requirements. We will give you at least 30 days' written notice, and you may end the engagement before the transfer, or within 30 days after it, without any exit fee.

17.2 Records on transfer. You consent to us giving the new provider your records, software access and the authorisations we hold for you, and to the ATO being asked to move those authorisations.

18. Privacy

18.1 Our Privacy Policy. We handle personal information under the Privacy Act 1988 (Cth), the Australian Privacy Principles and our Privacy Policy at [www.thenssbp.com.au/privacy-policy]. It explains what we collect, how we use and disclose it (including overseas and with AI), how long we keep it, and how to access, correct or complain about it.

18.2 Your employees. When you give us personal information about your employees, contractors, customers or others, you confirm you are entitled to do so and have told them, as the law requires, that it is shared with service providers like us.

18.3 Data breaches. If we become aware of a data breach involving your information, we will tell you promptly, assess it under the Notifiable Data Breaches scheme, and work with you on any notifications.

19. Changes to these Terms

19.1 Updates. We may update these Terms from time to time, for example to reflect changes in law, regulator guidance, technology or how we deliver our services. You do not need to sign again.

19.2 Changes that don't disadvantage you. Changes required by law, or that do not disadvantage you, take effect when published on our website. We will tell you about them in our next email or invoice.

19.3 Changes that could disadvantage you. For any other change, we will email you at least 30 days before it takes effect, with a plain summary. If you do not accept it, you may end the engagement before it takes effect, without any exit fee.

19.4 What an update cannot do. An update to these Terms cannot increase your fees, reduce your services, add a minimum term or exit fee, increase your liability, or widen any consent you give in your Letter of Engagement. Those changes need your agreement in writing (email is fine).

19.5 Versions. Each version is numbered and dated, and earlier versions are kept on our website.

20. General

20.1 Notices. Notices may be given by email to the address in your Letter of Engagement, as updated by notice.

20.2 Electronic signing. Your Letter of Engagement and these Terms may be accepted electronically.

20.3 Whole agreement. Your Letter of Engagement and these Terms are the entire agreement about our services and replace any earlier terms. Any part that is void or unfair is severed and the rest continues.

20.4 Governing law. These Terms are governed by the law of New South Wales.

Privacy Policy

The NOT so Silent Business Partner

This policy explains how Doolan Consortium Pty Ltd (ABN 16 100 864 266), trading as "The NOT so Silent Business Partner", of PO Box 124, Berowra Heights NSW 2082 ("we", "us", "our") collects, uses, stores and discloses personal information. We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

We are part of the Valont group of companies. Some of our services are delivered using the Valont platform and with help from Valont team members, who handle personal information in line with this policy and the Valont group Privacy Policy.

This policy applies to our website (www.thenssbp.com.au), our bookkeeping, payroll, BAS agent and general business services, and our finance referral services.

1. Who this policy covers

• Owners, directors and contacts of our clients

• Employees and workers of our clients, whose information we handle to run payroll and related services

• Customers and suppliers of our clients, whose details appear in the records we process

• People who visit our website, contact us or ask about our services

• People we introduce to finance partners, with their consent

• Contractors and advisers who work with us

2. What we collect

• Contact and business details: name, email address, phone number, postal address, business name, role and ABN.

• Business and financial records: bank and credit card statements, invoices, receipts, ledgers, ATO correspondence, activity statements and other records of your business.

• Payroll and employee information: name, date of birth, address, tax file number, bank and superannuation details, pay rates, hours, leave, employment type and terms, and timesheets.

• Connected systems data: information we retrieve from the accounting, payroll, banking and other systems you authorise us to access (for example Xero, MYOB, Dext and Deputy), limited to what you approve.

• Communications: emails, messages, call notes and the instructions and approvals you give us.

• Billing information: fees, invoices and payment details. We do not store full card numbers.

• Website usage data: browser type, operating system, pages visited and the site you came from, collected through cookies and similar technologies (see section 8).

Sensitive information and tax file numbers

We do not ask for sensitive information (such as health information) unless a service needs it and you have consented, or the law allows it. Payroll records can contain sensitive information, and we handle it only for the purpose it was provided for. We collect and use tax file numbers only as permitted by tax law and the Privacy (Tax File Number) Rule 2015.

3. How we collect it

• Directly from you, when you engage us, give us records or contact us

• From your business, when it gives us information about its owners, employees, customers and suppliers

• From connected systems, only with your authorisation

• From the ATO and other agencies, when we act for you as your BAS agent

• From your previous bookkeeper or accountant, with your permission

• Automatically, through our website and systems

If we receive personal information we did not ask for and could not have collected under the APPs, we destroy or de-identify it where it is lawful and reasonable to do so.

4. Why we collect and use it

• To provide our bookkeeping, payroll, BAS agent and business services, including preparing and lodging activity statements and dealing with the ATO for you

• To run payroll in line with the Fair Work Act 2009 (Cth), awards and superannuation laws

• To generate AI-assisted insights, forecasts, alerts, recommendations and documents, including ones we raise without being asked

• With your consent, to introduce you to finance brokers, lenders or other partners

• To bill you, provide support and keep the records the law requires

• To keep our systems secure and to detect and prevent fraud

• To improve, develop, train and test the Valont group's products, services and AI tools, and to produce industry benchmarks, using data de-identified so that no business or individual can reasonably be identified. We never use tax file numbers or sensitive information for this

• To send marketing communications, only where you have opted in

• To comply with the law, including our obligations as a registered BAS agent

5. AI processing and automated decisions

We use AI tools, including large language models, to help deliver our services. When we do, relevant data is processed by our AI providers to produce output for us. AI providers we engage may not train their own general models on your data, and keep it only as long as needed to provide the service and for security monitoring. AI features built into third-party software, such as accounting, payroll and receipt-capture software, are governed by those providers' terms.

We use computer programs, including AI, to help with tasks and decisions such as:

• suggested transaction coding and bank matching

• flagging unusual items, such as duplicate bills, missing documents or payroll changes, for review by our team

• checking pay runs against award rates and entitlements

• producing insights, forecasts and alerts about your business

These programs use the business, financial and payroll information described in section 2 that is relevant to the task. Routine steps are checked under our quality management system, and you can ask a person to review any of them. Programs do not make decisions that significantly affect you without a person: a qualified person approves anything we lodge with the ATO and any professional advice from our team. Decisions about your business are yours.

6. Who we share it with

We never sell your personal information. We disclose it only as described in this section, and only as reasonably needed.

6.1 Service providers

We use service providers to deliver our services and run our business, including providers of:

• Accounting, payroll and receipt-capture software (such as Xero, MYOB and Dext)

• Cloud hosting, file storage and email (such as Google and Microsoft)

• AI models

• Payments and billing

• Our website

Each is engaged on terms that include confidentiality and security obligations, and receives only the information it needs. We remain responsible for how our service providers handle your personal information.

6.2 Offshore team members

We have an outsourcing arrangement with Echo Global Pty Ltd in the Philippines, which supports our bookkeepers and provides administrative services. [Valont group team members in Indonesia may also assist.] Where they need personal information to do this work:

• they are bound by written agreements to keep it confidential and handle it in line with the APPs

• they access it only through our managed systems, using individual logins and multi-factor authentication

• their access is limited to the clients and information their work requires, and is removed when the work ends

6.3 Other disclosures

• Valont group: companies in the Valont group that help us deliver our services.

• Your advisers: your tax agent, accountant and other advisers, where you ask us to work with them.

• Government agencies: the ATO and other agencies, when we act for you as your BAS agent or tax law requires.

• Referral partners: finance brokers, lenders or other partners, only with your consent for that referral.

• A buyer of our business: a buyer of our business, under a written confidentiality agreement.

• Regulators: regulators, courts and law enforcement, where required or authorised by law.

7. Where your information is stored and accessed

Your information is primarily stored in Australia. Some personal information is disclosed to, processed in, stored in or accessed from other countries:

• AI providers: requests are processed in the United States, on the basis set out in section 5.

• Software and cloud providers: providers such as Xero, MYOB, Dext, Google and Microsoft may store and process data outside Australia under their own terms.

• Offshore team members: our offshore team members access information from [the Philippines and Indonesia] (see section 6.2).

Before disclosing personal information outside Australia, we take reasonable steps to ensure the recipient handles it consistently with the APPs, and we remain accountable for it.

8. Our website and cookies

When you visit www.thenssbp.com.au, we may collect information such as your browser type, operating system and the site you visited before ours. We use this in aggregate to understand how people use our site and to improve it.

Our website may use cookies to analyse traffic and improve your experience, and [to show relevant advertising through third-party services such as Google Ads]. You can reject cookies in your browser settings, although parts of the site may not work as well. Links to other websites are for convenience only; we are not responsible for their privacy practices.

9. How we protect it

We maintain administrative, technical and physical safeguards to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. These include encryption, role-based access controls and multi-factor authentication for our team and contractors.

10. How long we keep it

We keep client records for as long as the law and our professional obligations require, generally at least 7 years. When a retention period ends, we securely destroy or de-identify the information.

11. Your choices and rights

• Access and correction: you can ask for access to, or correction of, the personal information we hold about you. We do not charge for making a request.

• De-identified use: you can opt out of our use of your de-identified data to improve, develop, train and test our products, services and AI tools and produce benchmarks, by emailing blaketd@thenssbp.com.au. Your opt-out applies from the date we receive it.

• Marketing: you can unsubscribe from marketing at any time. Service communications, such as invoices and lodgement reminders, continue.

• Anonymity: you can browse our website without telling us who you are, but we cannot provide our services anonymously.

We respond to requests within 30 days and verify your identity before acting. We may refuse access in the limited circumstances the Privacy Act allows, and will tell you why.

12. Data breaches

If a data breach is likely to result in serious harm, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as required by the Notifiable Data Breaches scheme, and we will notify affected clients promptly.

13. Complaints

If you have a privacy concern, please contact Blake Doolan on 0401 029 293 or at blaketd@thenssbp.com.au, or write to PO Box 124, Berowra Heights NSW 2082. We will acknowledge your complaint within 1 business day and aim to resolve it within 30 days.

If you are not satisfied with our response, you can complain to the OAIC at www.oaic.gov.au or on 1300 363 992. If your complaint is about our BAS agent services, you can also complain to the Tax Practitioners Board at https://myprofile.tpb.gov.au/complaints/.

14. Changes to this policy

Each version of this policy carries a version number and effective date. If we make a material change, we will update this page and let our clients know. Earlier versions are available on request.

Contact

The NOT so Silent Business Partner (Doolan Consortium Pty Ltd ABN 16 100 864 266) · PO Box 124, Berowra Heights NSW 2082 · Blake Doolan · 0401 029 293 · blaketd@thenssbp.com.au

Approval

Approved by Signature

Full name: Blake Doolan

01 November 2026