Privacy Policy
The Freedom Group (“Freedom Group”) (“we”, “us”, “Freedom” or the “Company”) is committed to privacy protection. At Freedom we understand the importance of keeping personal information private and secure. This Privacy Policy (“Privacy Policy”) describes generally how we manage personal information and safeguard privacy. If you would like more information, please don’t hesitate to contact us.
This Privacy Policy applies to the Freedom Group companies including the following:
• Freedom Wealth Creation Pty Ltd (ABN 17 602 514 670)
• Freedom Property Finance Pty Ltd (ABN 70641818608)
• Freedom Investment Lending Pty Ltd (ABN 70648396267)
of Level 12, 201 Kent Street, Sydney NSW 2000 and Level 15, 28 Freshwater Place, Southbank VIC 3006.
The Australian Privacy Principles
We will treat all personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and this policy. This includes the collection, use, storage, and disclosure of personal information.
The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles”.
What is “personal information”?
Personal information held by the Company may include your:
• name and date of birth;
• residential and business postal addresses, telephone/mobile/fax numbers and email addresses;
• bank account and/or credit card details for agreed billing purposes;
• your computer and connection information;
• your personal financial information;
• your ownership and other interest in real estate;
• any other information that you otherwise share with us, or that we reasonably need to collect from time to time in connection with our products and services.
• identity verification information, including copies of government-issued identification documents, your date of birth, and biometric information (including a facial image and liveness-detection data) collected via our identity verification service provider (currently VerifiMe);
• information about your status as a politically exposed person, and any sanctions-list or adverse media information reasonably relevant to assessing that status.
How we may collect your personal information
We only collect personal information that is necessary for us to conduct our business and provide services to you.
Sensitive Information and Biometric Verification
Some of the personal information we collect, including biometric information collected as part of our identity verification process, is ‘sensitive information’ under the Privacy Act. We will only collect sensitive information, including biometric information, with your consent, except where the law otherwise permits or requires us to do so.
When you apply for Freedom Membership (“Freedom Membership”), meaning your enrolment in Freedom Group’s client services program
SMS communications
Where you provide your mobile number and consent to receiving SMS communications, we may use it to send you SMS text messages relating to your enquiry, including follow-ups, appointment reminders, and marketing communications about our products, services and events. Message and data rates may apply and message frequency varies. You can opt out of marketing SMS at any time by replying "STOP" to any message, or by contacting us using the details below.
Information that you provide to us
We may collect personal information that you provide to us about yourself when you:
• use our websites, including (without limitation) when you:
– purchase any services through our websites;
– register for access to premium content or request certain premium features; or
– complete an online form to contact us or any third party supplier;
• provide information to us by telephone or through marketing or competition application forms;
• send us an email or other communication; and
• provide information to us as during our events.
IP addresses
Our websites may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management and for security purposes. The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.
Cookies
This site uses “cookies” to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used on our websites: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the “Cookies” folder on your computer and remains in that folder after you close your browser, and may be used by your browser on subsequent visits to our websites. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. In some cases, cookies may collect and store personal information about you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.
You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our websites.
Why we use cookies
Our websites uses cookies in order to:
• remember your preferences for using our websites;
• facilitate e-commerce transactions, to ensure that your order is remembered between pages during the checkout process;
• show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, subscribed to newsletters or email or other subscription services); and
• remember details of data that you choose to submit to us (e.g., through online contact forms).
Many of these cookies are removed or cleared when you log out but some may remain so that your preferences are remembered for future sessions.
Third party cookies
In some cases, third parties may place cookies through our websites. For example:
• Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies to collect de-identified data about how long users spend on our websites and the pages that they visit;
• Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and
• third party social media applications (e.g., Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc.) may use cookies in order to facilitate various social media buttons and/or plugins with our websites.
How we may use your personal information
Your personal information may be used in order to:
• verify your identity and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), including customer due diligence, screening against sanctions and politically exposed persons lists, ongoing monitoring, and reporting to AUSTRAC;
• assist you to place orders or applications through our websites;
• process any purchases of services that you may make through this site, including charging, billing and collecting debts;
• respond to any queries or feedback that you may have;
• conduct appropriate checks for credit-worthiness and for fraud;
• contact you with information that might be of interest to you, including information about products, services and events of ours and of others;
• ask for your opinion or preference about our products or the products of others;
• prevent and detect any misuse of, or fraudulent activities involving, this site;
• conduct research and development in respect of our services;
• gain an understanding of your information and communication needs or obtain your feedback or views about our services in order for us to improve them; and/or
• maintain and develop our business systems and infrastructure, including testing and upgrading of these systems,
and for any other purpose reasonably necessary in connection with the products and services we provide to you, or as otherwise permitted or required by law.
From time to time we may email our clients with news, information and offers relating to our own services or those of selected partners. Your personal information may also be collected so that the Company can promote and market products and services to you. This is to keep you informed of products, services, and special offers we believe you will find valuable and may continue after you cease acquiring products and services from us. If you would prefer not to receive promotional or other material from us, please let us know using the contact details set out in this Privacy Policy and we will respect your request. You can unsubscribe from such communications at any time by following the unsubscribe link in our emails, or by contacting us using the details below.
When we may disclose your personal information
In order to deliver the services you require, we provide, or for the purposes set out in this Privacy Policy, we may share your personal information within the Freedom Group companies (listed above), as well as organisations outside the Freedom Group. Some of our trusted service providers may be located outside of Australia including, but not limited to, India, the Philippines, and other countries or jurisdictions depending on the nature of the services. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may be hired by us to deliver the services you require from us or may carry out or provide:
• client enquiries;
• mailing systems;
• billing and debt-recovery functions;
• information technology services;
• marketing, telemarketing and sales services;
• market research; and
• website usage analysis.
Identity verification and biometric information collected for AML/CTF purposes is not transferred outside Australia in the course of that verification. If this changes, or if our identity verification service provider processes or stores that information overseas, we will update this Privacy Policy accordingly and, where required by Australian Privacy Principle 8, take reasonable steps to obtain your consent before doing so.
In addition, we may disclose your personal information to:
• our identity verification service provider (currently VerifiMe) and its screening and verification partners, for the purpose of verifying your identity and conducting AML/CTF screening, including biometric verification, sanctions and PEP screening, and adverse media screening;
• your authorised representatives or legal advisers (when requested by you to do so);
• credit-reporting and fraud-checking agencies;
• credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
• our professional advisers, including our accountants, auditors and lawyers;
• government and regulatory authorities and other organisations, as required or authorised by law, including AUSTRAC (the Australian Transaction Reports and Analysis Centre) under the AML/CTF Act;
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.
Contacting us about privacy
If you would like more information about the way we manage your personal information, or are concerned that we may have breached your privacy, please contact us by email to contactus@freedompropertyinvestors.com.au or by post.
OR by post addressed to:
Freedom Property Investors,
Level 12, 201 Kent Street, Sydney NSW 2000.
We will acknowledge your complaint promptly and aim to respond within 30 days. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/.
Access to your personal information
In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to us, in writing, via the email address or by writing to us at the postal address stated above.
We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred to us, to retrieve your information. In no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:
• be unlawful (e.g., where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties);
• have an unreasonable impact on another person’s privacy; or
• prejudice an investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. If we refuse to give you access, we will provide you with reasons for our refusal.
AML/CTF Confidentiality (“Tipping-Off”)
The AML/CTF Act prohibits us from disclosing that we have made, or are considering making, a report to AUSTRAC about you or your dealings with us, or from disclosing certain other information about our AML/CTF compliance activities. If we are unable to explain a decision affecting your Freedom Membership, or do not respond to a request for information, this may be because we are subject to these confidentiality obligations. This does not affect your other rights under this Privacy Policy or under the Privacy Act.
Correcting your personal information
We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.
Storage and security of your personal information
We are committed to maintaining the confidentiality of the information that you provide us. We take all reasonable precautions to protect your personal information from unauthorised use or alteration. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. Firewalls, anti-virus software and email filters, as well as passwords, protect all our electronic information. Likewise, we take all reasonable measures to ensure the security of hard-copy information.
We retain personal information collected for AML/CTF customer due diligence purposes (including identity verification records and related transaction records) for at least 7 years from the date your Freedom Membership ends, or such other period as required by the AML/CTF Act, even if you cease to be a Freedom Member during that time. Biometric information (such as facial images and liveness-detection data) collected for identity verification is destroyed or de-identified once the verification process is complete, and only the verification outcome is retained as part of our AML/CTF records. Other personal information is retained only for as long as reasonably necessary for the purposes for which it was collected, or as otherwise required by law.
Third party websites
You may click-through to third party websites from our websites, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to our websites only and the Company assumes no responsibility for the content of any third party websites.
Re-marketing
We may use the Google AdWords and/or Facebook re-marketing services to advertise on third party websites to previous visitors to our websites based upon their activity on our websites. This allows us to tailor our marketing to better suit your needs and to only display advertisements that are relevant to you. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of your personal Google and/or Facebook information is reported to us.
You can set preferences for how Google advertises to you using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables you to opt out of targeted advertising.
Changes to this Privacy Policy
From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We will notify you about changes to this Privacy Policy by posting an updated version on our websites.
If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Australian Information Commissioner’s website (see https://www.oaic.gov.au/).