1.          Definitions and

ROIC Business Group Privacy & Contact Consent Policy

Protecting your privacy

Protecting your privacy and the confidentiality of your personal information is crucial to The ROIC Business Group and

our related entities. This Privacy & Contact Consent Policy covers all ROIC Business Group entities. We value your

trust and strictly abide by the National Privacy Principles established under the Privacy Amendment (Private

Sector) Act 2001 to protect your privacy, and take very seriously our obligations under the Privacy Act

(1988) to protect your personal information.

Under the Privacy Act, we are bound by the National Privacy Principles and in this Privacy Policy we

describe how we intend to meet our privacy obligations concerning the collection, use and disclosure of

your personal information.

This Privacy & Contact Consent Policy details:

• how we collect, manage, and protect your personal information
• how you can access the information we hold about you
• how you can request that we correct your information; and
• how you can make a complaint if you have concerns about how your information is managed
• how we can contact you via email

Personal information

The Privacy Act sets out the information that it protects.

Personal information generally means information or an opinion about a person, where the person's identity

can be derived from the information or opinion. It is irrelevant if the information or option is true or not, or

whether the information or opinion is recorded in a materials form or not.

Some personal information is sensitive. Sensitive information is information or an opinion that

clearly implies an individual’s:

• Racial or ethnic origin
• Political opinions or membership in a political association
• Religious beliefs or affiliations
• Philosophical beliefs
• Membership in a professional or trade association
• Membership of a trade union
• Sexual orientation or practices
• Criminal record
• Health information
• Genetic information or
• Biometric information.
• We will not collect, use or disclose sensitive information about you unless it is necessary to provide our
  service to you and we have your consent, or we are required to do so by law.
  What personal information is collected?
  
  We only collect personal information that is relevant to assist us in conducting our business activities and
  to provide you with the range of services we offer. If we do not collect your personal information we may
  not be able to provide you with a service.
  The kind of information we are likely to collect includes your name, address and contact details, your date
  of birth and details about your financial circumstances, goals, and strategies. We generally collect this
  information directly from you. This information may be collected when you fill out a form with us when we
  speak on the phone, when you use one of our websites or when you meet with one of our representatives.
  We may also collect publicly available information or may collect information from third parties such as:
• 
  
  • Credit reporting bodies, with your consent, if we require information about your credit history.
  • Our related entities so that we can provide a comprehensive service to you.
• Consequences of not providing your personal information
  
  You are not obliged to give us your personal information. However, if you decide not to give us information,
  we may not be able to provide our services to you.
  How is your personal information collected?
  
  We usually only collect your personal information directly from you.
  It may be necessary to collect personal details from third parties, for example, issuers or operators of
  financial products or financial services.
  If we collect sensitive information, we will not do so without your consent (subject to some exceptions, for
  example where collection is required by law). However, we will endeavour to collect such information directly
  from you wherever possible.
  When we collect personal information about you, we will tell you why it is being collected, the organisations,
  or the types of organisations, to whom we usually disclose that kind of information, any law that requires
  the information to be collected, and the main consequences for you if the information (or part of the
  information) is not provided. We will also give you our contact details and tell you about how you can access
  the information.
• 
  We store all personal information collected in Australia and the USA.
• 
  How is your personal information used?
• 
  Personal information is collected so that we can provide you with the services you request. This is known
  as the primary purpose for the collection of personal information.
  The types of secondary purposes for which we would ordinarily use or disclose your personal information
  include contacting you regarding other services that we believe may be of interest to you. We will also use
  or disclose information where such use or disclosure is required by law or is necessary concerning dealing
  with unlawful activity or threats to life, health, or safety.
  Some of the uses described above will require disclosure of your personal information to third parties. We
  will require that any third party to whom we disclose personal information will only use that information for
  the purposes for which we disclosed it to them and on the basis that they will comply with their privacy
  obligations.
• 
  How is your personal information disclosed?
  
  We may use your personal information to identify a product or service that may be of interest to you. We
  may contact you to let you know about new or existing products or services. We may disclose your personal
  information to associated entities or businesses, as well as the seller of a business, or another client. This
  includes but is not limited to the following PTY LTD companies:
• 
  
  • ROIC Business Group
  • ROIC Business Sales
  • Geelong Business Sales
• We may at times need to disclose your information to overseas locations because we use service providers
  to perform some functions on our behalf. We only disclose your information to these service providers
  when it is necessary.
• 
  Data quality and protection
  
  We will also take reasonable steps to protect your personal information from misuse and loss, and from
  unauthorized access, modification, and disclosure. We have processes in place to ensure that your
  personal information is only accessible by those who are authorized to access this information.
  We may store your personal information in hardcopy documents, or via electronic means. We maintain
  physical and electronic security systems to ensure your personal information is protected at all times.
  Once your personal information is no longer required by us, we will take reasonable steps to destroy or
  permanently de-identify that personal information.
• 
  Data access and correction
  
  We strive to maintain current records, to facilitate this please let us know as soon as possible if any of your
  details change or if there is any change to your circumstances.
  If you think the personal information, we hold is not accurate, incomplete, or out of date, you should contact us.
  We will need to verify your identity before providing you with any personal information. We will usually
  provide access to you at our International Head Office which is located in Geelong Victoria.
• 
  If you require access to the personal information we hold about you, please send us an email. We will
  generally, allow access, unless certain exceptions apply - for example, if providing access would pose a
  serious and imminent threat to the life or health of any person, providing access would prejudice action.
  being taken by an enforcement body or providing access would be unlawful.
  Your request should specify the information to which you require access. We will keep a record of your
  request for access and how it was dealt with.
• 
  We will not charge you for requesting access to your personal information. We may, however, charge you
  the costs associated with meeting your request, for example, processing fee, photocopying and postage
  costs.
• 
  We will aim to respond to your request within 5 business days of receipt of your request.
  If we cannot meet your request for access or correction, we will provide reasons by email.
• 
  Use of this website
• 
  This website contains links to other websites whose operator may or may not adhere to a privacy policy or
  be governed by the National Privacy Principles.
  The information collected about you by this website depends on the options accessed by you on the
  website. Anonymous data is collected from our website to evaluate its performance. Our website may use
  ‘cookies’ that allow us to identify your browser while you are using our site. Cookies do not identify you;
  they simply allow us to track usage patterns so that we can measure the level of interest in various areas
  of our site. All browsers allow you to be notified when you receive a cookie and elect to either accept it or
  not.
• 
  Your Internet service provider should be able to assist you in setting your preferences.
  We will retain any emails submitted by you to us and may use your email address to send information
  that may be of interest to you. You can at any time request us to remove your email address from our
  mailing list.
• 
  Your personal information that is recorded on our server is protected by encryption technology and a system
  of secure passwords, logons and/or other security procedures.
• 
  If you are concerned
• 
  If you believe your privacy has been compromised or that we have breached the Privacy Legislation you
  are entitled to complain. If you have a privacy complaint, please contact the Finn representative you have
  been dealing with.
  Alternatively, you can write to us using the details below.
• 
  
  • Email: support@roicbusinessgroup.com.au
  • Address: level 4, 90 William Street Melbourne Vic. 3000
• How this policy changes
  This policy may change over time. All changes will be published on this website.