Privacy Policy
Last updated: 4 June 2026 | Groom Advisory (Vital Verde Pty Ltd)
Vital Verde Pty Ltd (ABN 15 670 579 058) trading as Groom Advisory (we, us or our) is committed to protecting your privacy. This Privacy Policy explains how we collect, hold, use, disclose and protect personal information when you interact with us, use our website, enquire about our services, engage us, supply services to us, apply to work with us, or otherwise communicate with us.
This policy applies to personal information we handle through our website, email, telephone, meetings, client onboarding processes, documents, online forms, professional software platforms, third-party service providers and other business channels.
2. Quick Overview
We collect personal information that you provide to us, information we generate while providing services, and information that we receive from authorised representatives, service providers, public sources and other third parties. We use this information to provide professional advisory, consulting and related services, manage our business, communicate with you, comply with legal and regulatory obligations, and improve our services.
| Topic | Groom Advisory’s Approach |
|---|---|
| Main information collected | Identity, contact, business, employment, financial, commercial, engagement, billing, website and communication information. |
| Main purposes | Providing advisory services, managing client relationships, administration, compliance, security, marketing and service improvement. |
| Key disclosures | Service providers, professional advisers, authorised representatives, regulators, government bodies and parties involved in business transactions. |
| Overseas access | Some cloud, software, analytics or support providers may access information from outside Australia. |
| Your rights | You may request access, correction, marketing opt-out assistance, or complain about privacy handling. |
3. Information We Collect
The types of personal information we collect depend on how you interact with us and the services we provide to you.
3.1 Identity and contact details
We may collect your name, business name, position title, postal address, email address, phone number, date of birth, signature, and information contained in identification documents where identity verification is required or appropriate.
Where relevant to our services or legal obligations, we may collect government-related identifiers, such as an Australian Business Number, Australian Company Number, director identification number, tax file number or other identifier. We only collect and use these identifiers where reasonably necessary and where permitted or required by law.
3.2 Client, business and advisory information
We may collect information about you, your business, your role, your professional circumstances, your commercial objectives, business structure, financial position, assets, liabilities, revenue, expenses, employees, contractors, suppliers, customers, projects, transactions, contracts, insurance arrangements, governance arrangements, risk profile, succession plans and other matters relevant to the services you ask us to provide.
We may also collect documents and information supplied by you or on your behalf, including business records, correspondence, meeting notes, questionnaires, due diligence materials, financial statements, management accounts, tax or accounting information, corporate documents, asset records and other information relevant to an engagement.
3.3 Billing, payment and administration information
We may collect billing details, payment records, invoice history, transaction details, account status, service preferences, engagement terms, client onboarding information, conflict-check information and records of communications between you and us.
3.4 Sensitive information
In some circumstances, information you provide to us may include sensitive information, such as information about health, professional memberships, associations, criminal history, racial or ethnic origin, political opinions, religious beliefs or other matters treated as sensitive under privacy law. We will only collect sensitive information where it is reasonably necessary for our functions or activities and where you have consented, or where collection is otherwise permitted or required by law.
3.5 Digital and website information
When you visit our website or interact with our online content, we may collect information such as your IP address, approximate location derived from your IP address, device and browser details, website usage patterns, pages visited, referring websites, search and browsing behaviour, enquiry form submissions, cookie preferences, marketing engagement and analytics information.
4. How We Collect Personal Information
We collect personal information in several ways, outlined below:
| Source | Examples |
|---|---|
| Directly from you | When you enquire, complete forms, book a meeting, provide instructions, sign an engagement letter, send documents, communicate with us, participate in a survey or attend an event. |
| From authorised representatives | From your directors, employees, contractors, accountants, lawyers, financial advisers, brokers, consultants, family members or other representatives you authorise to deal with us. |
| From third parties | From professional advisers, service providers, software platforms, payment processors, referral partners, government agencies, regulators, financial institutions and business partners. |
| Automatically | Through cookies, analytics tools, website hosting logs, email tracking technologies and other online technologies when you use our website or digital services. |
| From public sources | From ASIC, ABN Lookup, professional registers, court or tribunal records, public databases, websites, social media platforms, LinkedIn and other publicly available sources. |
5. Why We Collect, Hold, Use and Disclose
We collect, hold, use and disclose personal information to operate Groom Advisory and provide our services. The specific purposes include:
- Providing services: Assessing fit, providing proposals, onboarding clients, performing conflict checks, preparing engagement terms, and delivering fractional CFO and AI implementation services.
- Business operations: Managing billing, payments, internal reporting, record keeping, supplier relationships, quality assurance, and general administration.
- Communication: Responding to enquiries, scheduling meetings, sending service updates, and requesting feedback.
- Legal & Risk: Complying with applicable laws, regulations, tax obligations, identity verification checks, and establishing or defending legal rights.
- Marketing: Sending newsletters, industry insights, and event invitations (with a clear opt-out path available at any time).
- Service Improvement: Understanding website usage, troubleshooting issues, and optimizing our operational and digital workflows.
6. When We Disclose Personal Information
We may disclose personal information where reasonably necessary for the purposes described in this policy, where you have authorised us to do so, or where required or permitted by law.
| Recipient Category | Examples of Possible Disclosures |
|---|---|
| Service providers | IT support, cloud hosting, cybersecurity, CRM, practice management, email, document management, data storage, payment processing, accounting, bookkeeping, electronic signing, website hosting, marketing automation and analytics providers. |
| Professional advisers | Lawyers, accountants, auditors, tax advisers, bankers, insurers, insurance brokers, consultants and other professional advisers. |
| Authorised representatives | Your directors, officers, employees, contractors, accountants, lawyers, advisers, brokers, family members or other representatives you ask us to deal with. |
| Government & regulatory bodies | ASIC, the ATO, ABR, AUSTRAC, courts, tribunals, law enforcement agencies, regulators, professional bodies and external dispute resolution bodies, where relevant. |
| Corporate transaction parties | Purchasers, investors, financiers, advisers or other parties involved in a proposed or actual sale, merger, restructure, financing, acquisition or transfer of all or part of our business or assets. |
Note: We do not sell personal information under any circumstances.
7. Overseas Disclosure and Offshore Access
We are based in Australia and store personal information using reputable cloud-based providers. Some of our software, analytics, support, or marketing platforms may process or access information from locations outside Australia. We take reasonable steps to ensure overseas recipients handle your data securely and in accordance with Australian Privacy Principles.
8. Your Privacy Rights and Choices
You have clear rights regarding how your personal information is managed:
- Right to withhold information: You can choose not to provide information, though this may prevent us from delivering our advisory services or completing onboarding checks.
- Right to Access: You may request access to the personal information we hold about you at any time.
- Right to Correction: You can ask us to update or correct inaccurate, outdated, or incomplete records.
- Marketing Opt-Out: You can unsubscribe from marketing emails instantly using the provided footer links or by contacting us.
9. Contact Us & Complaints
If you have a privacy question, want to request access or correction, or wish to make a complaint, please contact us using the details below:
Post
PO Box 24, Wavell Heights North, QLD, 4012
Website
groomadvisory.com.auIf you are not satisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au or on 1300 363 992.
10. Protecting & Retaining Information
We use robust technical, operational, and physical safeguards (such as password controls, multi-factor authentication, secure cloud databases, and staff access permissions) to protect your data. We retain personal information only for as long as necessary to provide services, comply with legal, tax, or professional record-keeping obligations, and resolve disputes.
11. Cookies and Analytics
We may use cookies, tracking pixels, and analytics tags (such as Google Analytics or Meta Pixel) to understand website traffic, optimize browser performance, and deliver relevant marketing campaigns. You can manage or block cookies through your browser settings, though doing so may impact certain site features.
12. Changes to this Policy
We may update this Privacy Policy from time to time by posting the revised version on our website. The updated policy will apply from the date of publication.
© 2026 Groom Advisory. All rights reserved.
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