Privacy Policy

Your privacy is important to us.

Positive Collection Services is committed to providing you with the highest levels of service. This includes protecting your privacy. From 1 January 2002, Positive Collection Services is bound by amendments to the Commonwealth Privacy Act 1988, which sets out a number of principles concerning the protection of your personal information. This is outlined in our Privacy Policy below.

Positive Collection Services Privacy Policy sets out important information about privacy protections which we extend to your personal information. It relates to personal information that you provide to us.

Positive Collection Services will update this Privacy Statement as required. For example, as we update and improve our services, modifications may be required. Any changes will be published as that you are always aware of the sort of information we collect, how the information may be used, and under what circumstances it may be disclosed by Positive Collection Services.

Please note, that if at any time Positive Collection Services is required by law to release information about you or your organisation, Positive Collection Services must co-operate fully. This Privacy Policy does not apply to acts or practices of Positive Collection Services that are directly related to employee records of current or former employees.

What personal information does Positive Collection Services collect?

Personal information is any information or opinion from which an individual's identity may be ascertained. Positive Collection Services only collects information that is necessary to assist us in providing our services. We do not collect personal information unless we ask you for it, you provide it to us, or the information is publicly available.

Examples of the types of information we collect include, but are not limited to:

• Your individual or your entity's identity and contact details
• Financial information
• Share portfolio information
• Creditor information, and
• Information as required by Taxation Law

How does Positive Collection Services collect information?

Positive Collection Services collects information about you (individuals and entities) in a number of different ways including:

Positive Collection Services collects information from you when you engage our firm so that we may provide you with financial planning, tax consulting, training, business services, audit, information technology, business recovery and insolvency, human resources or corporate secretarial services.

Positive Collection Services collects information from external sources with prior consent from you.

Our external sources include - Australian Security and Investments Commission (ASIC), Fund Managers, The Australian Taxation Office (ATO). Positive Collection Services ensures that external sources are permitted under the National Privacy Principles to disclose the information to Positive Collection Services, or has received the prior consent from the individual to release the information to Pivotal Advisory.

Our appointment is confirmed in writing with you.

Positive Collection Services collects information when you make contact with us to enquire about our services. When you email us:

• We will use your email address for the purpose for which you provided it and to raise awareness about recent developments that may be of relevance or interest
• Your email address will not be added to a commercially available mailing list, and We will not disclose it without your consent

Other personal information collected by us:

• Will be collected by lawful and fair means
• Will be used for a lawful purpose
• Will be collected with your consent
• The purpose for collection should be clear and explicit, and
• We ensure that any information collected is collected in accordance with the National Privacy Principles

What may happen if you do not provide Positive Collection Services with information?

If you do not provide Positive Collection Services with the information we request, our ability to provide our high standard of service may be compromised. This may result in:

• Positive Collection Services's advice may be inaccurate or incomplete
• Positive Collection Services may be unable to provide certain services to the individual concerned
• The provision of (some of) Positive Collection Services's services to the individual may be delayed, and/or
• In certain circumstances, failure to provide some information may result in documents being submitted to the Australian Taxation Office, the Australian Securities and Investments Commission or other statutory bodies late and possibly incurring penalties

Why does Positive Collection Services collect the information and how is your information used by Positive Collection Services?

Positive Collection Services collects information to provide you with a specific service. We may use the information you provide to us for a number of purposes, such as:

• Australian Taxation Office reporting requirements
• Managing your financial portfolio
• Australian Securities and Investments Commission requirements
• Provide other services you require
• Administer and manage those services, including charging, billing and collecting debts
• Inform you of ways the services provided to you could be improved
• Advising clients of events, business opportunities and service provisions available to them
• Providing you with news and information relevant to you
• Research and develop our services, and
• Maintain and develop our business systems and infrastructure

Your personal information is also collected to promote and market other services which we consider may be of interest to you. You may notify us at any time that you do not wish to receive marketing or promotional material by contacting our Business Development Manager.

Positive Collection Services does not collect sensitive information such as an individual's religious beliefs or affiliations, sexual preferences or practices, criminal records or health information. There may be exemptions to this rule, such as where collection is required by law.

Disclosure of Personal Information

Positive Collection Services will not sell, exchange, trade or otherwise supply to third parties any personal information obtained from you without your prior consent.

Positive Collection Services, with prior consent, discloses information about you to various organisations and/or parties in order to fulfil our client services. These organisations include, for example

• Australian Taxation Office (ATO)
• Australian Securities and Investments Commission (ASIC)
• Institute of Chartered Accountants in Australia (ICAA) Quality Control
• CPA Australia Quality Control
• Banking and financial institutions
• Superannuation authorities
• Fund managers
• Government and statutory bodies
• Auditors

When your personal information is no longer used by Positive Collection Services as set out above, we will destroy or permanently de-identify personal information. Our ability to destroy information is limited by legislative requirements to retain records for a period of time.

How will Positive Collection Services keep your personal information secure?

Positive Collection Services intends to protect the quality and integrity of personal information kept about you. Positive Collection Services has implemented appropriate industry standard techniques, technological and organisational measures to protect against loss, misuse and/or alteration of the information under our control.

These measures include:

• Server encryption and site monitoring
• Computer firewalls and intrusion detection
• Computer password authentication
• Offsite data backup
• Audit trail of access to client data
• Confidentiality clauses in Employment Agreements
• Bound by the Rules of Ethical Conduct of the ICAA and CPA
• Computer, internet and email policy
• Building security
• Restricted access to firm premises
• Unique client identifiers

Positive Collection Services will review security arrangements from time to time as we deem appropriate.

We take reasonable steps to ensure that any personal information transmitted via our website is stored securely. Transmissions sent to or from our website are routinely monitored for quality control and systems administration. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your personal information from misuse, loss and unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from our online products or services. Once we receive your transmission, we make our best efforts to ensure its security.

Other web sites that may be accessed through our site may collect personally identifiable information about you. The information practices of those third party web sites linked to Positive Collection Services are not covered by this Privacy Statement.

Cookies are pieces of information that a web site can transfer to an individual's computer hard drive for record keeping. Cookies can make web sites easier to use by storing information about your preferences on a particular website. The information remains on your computer after the internet session finishes. Parts of Positive Collection Services's website may use cookies to store basic statistical data. The information collected may be used by Positive Collection Services to help us improve the service by understanding how it is used. There is no attempt made to identify individual users in any way. On each use, a session cookie may be temporarily placed on your computer, which is used to maintain navigation information during your site visit. These session cookies are automatically deleted from your computer at the end of each internet session. Most internet browsers are pre-set to accept cookies. If you prefer not to receive cookies, you can adjust your internet browser settings to refuse cookies, or to warn you when cookies are being used.

Advice about the internet and personal information can be found on the Privacy Commissioner's website at http://www.privacy.com.au

Help us to ensure we hold accurate information

Positive Collection Services takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of the information we hold depends to a large extent on the information you provide.

You have the right to access your personal information (subject to the Act), subject to some exceptions allowed by law. If you would like to do so, please let us know by contacting your adviser or our Business Development Manager. You may be required to put your request in writing for security reasons. We will not charge you for responding to such a request, unless we incur costs in providing the information.

How to contact us

For any complaints regarding a possible breach of privacy, or if you have any questions or feedback in relation to privacy, contact Royden Mauger.

For more detail on Positive Collection Services's approach to privacy, please contact Royden Mauger.