Our Privacy Policy

Your privacy is important to Opinion2 Financial Services Pty ltd trading as P16 (‘We’). We are committed to ensuring the confidentiality and security of your personal information.

This Privacy Policy outlines how we collect, use, disclose and protect your personal information, as required by the Privacy Act 1988 (Cth) (Privacy Act). It also outlines how you can access and change your information, ask a question or make a complaint.

In this Privacy Policy, unless the context requires otherwise, a reference to ‘we’, ‘us’ or ‘our’ is a reference to P16.

This Privacy Policy does not apply to our handling of personal information relating to employees. Please contact us if you would like further details in relation to how we handle information of that nature.

1.  Collecting personal information

We only collect personal information that is reasonably necessary for our business functions and activities.

1.1 What is personal information?

Personal information is information that identifies you as an individual or from which your identity can be reasonably identified.

The types of personal information we may collect include:

• your name;
• your address;
• your email address;
• your telephone or fax number;
• your date of birth;
• your driver’s license number;
• your passport number;
• your bank account details;
• your credit card details;
• your financial information (including records of your assets and liabilities);
• your employment details (including via pay slips and other income documents); and
• other information of a personal nature that you disclose during communications with us or our staff, whether in person, over the telephone, via email or in writing.

1.2. What is the purpose for collecting personal information?

In respect of clients, we collect your personal information for the purpose of providing you with personalized property investment strategy or other services directly or indirectly offered through us or our Business Partners. Our partnered licensed service provider may use your personal information to assist you in designing your financial strategy, providing financial planning services, mortgage broking services, personal tax services and financial advice.  In respect of other persons, we collect personal information from, including contractors and job applicants, we collect that information for the purpose of operating and managing our day-to-day business, particularly in respect of our contractual or business relationship with you.If we do not collect your personal information, we may not be able to do these things. For example, in respect of clients, we may not be able to introduce you to service providers, communicate with you or deal with your enquiries.In respect of other persons, we collect information from, including contractors and job applicants, we may not be able to communicate with and manage our relationships with you.

1.3. How do we collect personal information?

We can only collect personal information about you by a lawful and fair means. There are several ways that we may collect your personal information, which are set out below:

(a) Directly from you

If it is reasonable and practical to do so, we will collect your personal information directly from you. We may do this when we meet you in person, such as when you complete a form or contract. But we may also collect your personal information directly from you in other ways, including when:

1. we have a conversation with you over the telephone;
2. you send an email or letter to us;
3. you complete on online form or application form; or
4. you enter a competition with us.

(b) Indirectly

If it is unreasonable or impracticable to collect your personal information directly from you, we may collect it from third parties. This may include collecting your personal information from third parties such as our service providers (for example, client managers), referrers, financial institutions, the Australian Taxation Office or our related companies.

If we receive personal information about you from someone else without having asked for it, we will only continue to hold it if it is personal information that we could have collected from you ourselves, in accordance with this Privacy Policy. If it is personal information which is not reasonably necessary for our business functions and activities, we will destroy or de-identify it.

(c) From our website

If you are using one of our websites, you will browse anonymously unless you have completed an online application form or as set out in this section.

For all visitors browsing our website, we use cookies to collect information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), the time of visit, time spent online, downloaded information, pages visited and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address. We also use cookies to manage online advertising.

Information collected in this way is not capable of personally identifying you.

If you have provided us with personal information by completing an application form online and we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our websites, irrespective of how you access our sites (e.g., by clicking a link in an advertisement or from a third-party website). In addition, we may combine that information about your use of our website with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information.

If you would prefer not to be identified in this way or would prefer us not to collect anonymous cookie information about you at all, you can delete the cookies and reconfigure the cookie preferences on your internet browser.

2. How we use and disclose your personal information
2.1 Using and disclosing personal information

We only hold, use and disclose personal information about you for the purposes outlined in section 1.2, or for related purposes which might be reasonably expected, unless we otherwise obtain your consent.

To do this, we may disclose your personal information to related companies or third parties who:

(a) provide services which are necessary for us to conduct our business.
(b) are regulatory bodies, government agencies, law enforcement bodies, courts and dispute resolution schemes; or
(c) are your authorised agents, executors, administrators or legal representatives.

We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity, and as part of acquisitions or potential acquisitions of our business.

On some occasions, we may be obliged to disclose your personal information by law, e.g., court order or statutory notices pursuant to any legislation and to government authorities.

2.2  Direct marketing

With respect to clients, from time to time, we may use the personal information collected from you for direct marketing purposes, such as targeted advertising, promotions, special offers and other information which we think you may find interesting.

We may contact you by telephone, electronic messages (e.g. email), online (including websites and mobile apps) and other means for these purposes.

If we do contact you in this way, it will only be in relation to matters that clients would reasonably expect us to contact them directly about. And we will ensure that our marketing activities comply with applicable law.

If we have disclosed your personal information to other related companies, we may tailor this marketing to you, by combining information about you which is held by the other related companies with the information we hold.

If you no longer wish to receive any direct marketing communication from us, please follow the instructions for unsubscribing in our direct marketing communications. If there are no instructions, please contact us as set out in section 5 below.

We do not sell personal information to other third-party organizations to allow them to contact you for direct marketing purposes.

3. Keeping personal information secure

We use security procedures and technology to protect the personal information we hold.

Before disclosing personal information to a client, job applicant or contractor, we confirm the identity of that client, job applicant or contractor to prevent misuse or unlawful disclosure of the information.

We also take reasonable measures to ensure the physical security of personal information.

When records containing personal information are no longer required, we delete the information or permanently de-identify it.

If you are considering sending us any personal information electronically, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g., email, standard http).

4. Access and correction of personal information

4.1 . Access

You are entitled under the Privacy Act to access the personal information we hold about you and (provided that it is reasonable and practicable) to do so in a manner that you request. You can make a request in a letter or by telephone if you prefer. To make such a request, please see our contact details in section 5 below.

We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.

We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.

Your rights to access your personal information are subject to some limitations. For example, we do not have to provide you with access to the extent it would be illegal to do so, if it would have an unreasonable effect on the privacy of others or the request is frivolous or vexatious.

If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.

We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs.

4.2 Correction

If you feel that the personal details, we hold for you are incorrect, you are able to contact us at any time to request that we correct that information.

If you would like to do so, please contact our Privacy Officer using the contact details in section 5 below.

We will normally try to resolve correction requests within 30 days of you making a request. If we need more time to resolve your request, we will notify you in writing as to the delay and seek your agreement to a longer period.

There will be no cost to you if we correct your personal information held by us.

5. Complaints

If you believe that we have not complied with our obligations relating to your personal information, please contact our Privacy Officer as follows:

By phone: Call P16 between 9am and 5pm Monday to Friday. By mail: Mail your written complaint to:

Privacy Officer 106 Bagot Road, Subiaco, 6008, WA By email: Send an email at any time to info@P16investing.com.auYou will receive acknowledgement of the receipt of your complaint as soon as practicable and in any case within 5 business days after we receive it.If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or on 1300 363 992.6. UpdatesWe may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our current operations and practices.You can obtain a copy of the current version on request or at www. myincomemychoice.com.au