Privacy Policy
PRIVACY POLICY
Small Business Reboot
GS-APAC Pty Ltd (ABN 68 606 128 741) trading as Small Business Reboot
1. Introduction
GS-APAC Pty Ltd (ABN 68 606 128 741), trading as Small Business Reboot (“we”, “us” or “our”), is committed to protecting your privacy and handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
We provide commercial debt negotiation and restructuring support services for Australian small businesses. This Privacy Policy explains how we collect, use, disclose, and protect personal information.
2. What is Personal Information?
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether recorded in a material form or not.
Sensitive information is a subset of personal information and includes information about racial or ethnic origin, political opinions, religious beliefs, health information, sexual orientation, criminal record, and membership of professional or trade associations.
Note: information about a business (such as ABN, company financials, or trading details) is not usually “personal information” unless it identifies an individual (for example, a sole trader, a director, or a guarantor).
3. Types of Information We Collect
To provide our services, we may collect the following:
3.1 Identity and Contact Information
Full name, date of birth (where needed for identification), residential and postal address, email address, telephone number, and identification documents (such as driver’s licence or passport details) where required for verification.
3.2 Business and Commercial Information
Business name, trading name, ABN/ACN, business address, ownership/director details, and information about your business structure and operations where relevant to your matter.
3.3 Financial Information
Information relevant to negotiations and restructuring support, such as:
• creditor names and account references;
• debt balances and repayment status;
• invoices, contracts, and correspondence with creditors;
• business income/expenses, cashflow information, and financial statements (as relevant);
• asset and liability details; and
• bank account details (only where needed for payment processing or agreed arrangements).
3.4 Hardship or Vulnerability Information
Where relevant, we may collect information about circumstances affecting your ability to meet obligations (for example, illness, family circumstances, or business disruption). If this includes sensitive information (such as health information), we will only collect it with your consent or where required or authorised by law.
3.5 Technical Information
When you visit our website, we may collect technical information such as IP address, browser type, device information, pages visited, and cookies to help operate and improve the website.
4. How We Collect Your Information
We collect personal information directly from you when you:
• enquire about or use our services;
• complete forms or questionnaires;
• communicate with us by phone, email, or in writing;
• use any client portal or systems we provide; or
• visit our website.
We may also collect information from third parties where relevant and lawful, including:
• creditors, debt purchasers, and their agents;
• your accountant, bookkeeper, lawyer, or other authorised representative;
• restructuring practitioners or insolvency professionals you engage (where applicable);
• financial institutions involved in payments or transactions; and
• public sources and government agencies where authorised by law.
If you provide information about other individuals (for example, business partners, directors, employees, or guarantors), you confirm you are authorised to provide that information to us.
5. Why We Collect and Use Your Information
We collect and use personal information to:
• assess whether our services are suitable for your situation;
• provide commercial debt negotiation and restructuring support services;
• communicate with creditors and other relevant parties on your behalf;
• prepare negotiation proposals, supporting documents, and communications;
• administer our client relationship, including payments and record keeping;
• respond to enquiries and provide customer support;
• comply with legal and regulatory obligations; and
• improve our services and internal processes.
If you do not provide the information we request, we may be unable to provide services, or our ability to assist may be limited.
6. Who We Disclose Your Information To
We may disclose personal information to:
• creditors, debt purchasers, and their agents (to negotiate or communicate on your behalf);
• professional advisers you engage or we engage to support service delivery (e.g., lawyers, accountants), where relevant;
• restructuring practitioners or insolvency professionals you engage (where applicable);
• payment processors and financial institutions (for payments you authorise);
• IT and service providers (such as CRM, secure storage, communications platforms);
• government agencies, regulators, courts, or tribunals where required or authorised by law; and
• any other party you authorise us to deal with on your behalf.
7. Overseas Disclosure
Important: Some of our staff and service providers may be located overseas. This may include:
• Philippines: assistance with client communications, marketing, and administration.
• India: assistance with document preparation, review, and case administration.
Where we disclose personal information overseas, we take reasonable steps to ensure overseas recipients handle personal information in a manner consistent with the APPs. In some cases, we may seek your express consent to an overseas disclosure after informing you that, if you consent, we may not be accountable under the Privacy Act for the overseas recipient’s handling of that information.
If you do not consent to overseas disclosure, please tell us before engaging our services. This may limit the services we can provide.
8. Data Quality and Security
We take reasonable steps to ensure personal information we hold is accurate, up-to-date, complete, and relevant, and we rely on you to tell us if your details change.
We protect personal information using measures such as access controls, password protection, encryption in transit where appropriate, staff training, secure storage, and secure destruction/de-identification when information is no longer required.
No method of transmission or storage is completely secure. We cannot guarantee absolute security.
9. Accessing and Correcting Your Information
You may request access to the personal information we hold about you by contacting us (see Section 12). We will respond within 30 days.
We may charge a reasonable fee to cover the cost of locating and providing access and will tell you about any fee before proceeding.
We may refuse access in limited circumstances permitted by law. If we do, we will provide written reasons and information on how to complain.
If you believe personal information we hold is inaccurate, out-of-date, incomplete, irrelevant, or misleading, you may request correction. We will respond within 30 days. If we refuse, we will provide reasons and complaint options.
10. Privacy Complaints
If you believe we have breached the APPs or mishandled personal information, you can lodge a complaint with us.
10.1 How to Complain
Submit your complaint in writing to our Privacy Officer using the contact details in Section 12. Include your name, contact details, what happened, and the outcome you want.
10.2 Our Response
We will acknowledge your complaint within 7 days and aim to resolve it within 30 days. If more time is needed, we will explain why and provide an expected timeframe.
10.3 External Complaints
If you are not satisfied with our response, you may lodge a complaint with the Australian Financial Complaints Authority (AFCA):
Website: www.afca.org.au
Phone: 1800 931 678 (free call)
Email: info@afca.org.au
Post: GPO Box 3, Melbourne VIC 3001
11. Cookies and Website Analytics
Our website may use cookies and similar technologies to operate the site and understand usage. You can usually disable cookies via your browser settings, but some features may not function properly.
12. Contact Us
For questions, access/correction requests, or privacy complaints, contact:
GS-APAC Pty Ltd trading as Small Business Reboot
Address: 117/530 Little Collins Street, Melbourne VIC 3000, Australia
Phone: (02) 7255 5799
Email: contact@smallbusinessreboot.com.au
Website: www.smallbusinessreboot.com.au
13. Changes to This Policy
We may update this Privacy Policy from time to time. The current version will be available on our website. Where changes are significant, we will take reasonable steps to notify you (for example, via email or a notice on our website).
Effective Date: 11/11/2025
Last Updated: 11/11/2025
Version: 1.0
