Introduction

This Privacy Statement is made on behalf of Finlancer Holding Pty Ltd (ACN 603 824 835) trading as WealthO2 of Suite 7.02 157 Walker Street North Sydney NSW 2060, trading as WealthO2 and its related bodies corporate.

Related bodies corporate includes the following entities:

MDA Operator Pty Ltd (ACN 43 609 025 130) trading as MA Operator;
uXchange Pty Ltd (ACN 610 852 536);
Finlancer Shared Services Pty Ltd (ACN 09 120 103); and
WealthO2 Services Pty Ltd (ACN 610 852 456).

The MDA Operator and uXchange are Corporate Authorised Representatives (CAR) of WealthO2 Services Pty Ltd (ABN 20 610 852 456) which holds an Australian Financial Services Licence (AFSL) AFSL Number 500023.

WealthO2 recognises an individual's right to privacy and understands the protection and confidentiality of your personal information is important to you. WealthO2 is bound by the Privacy Act 1988 (Cth).

This Privacy Statement outlines the type of personal information we collect, how that information is collected, used, stored and protected, and to whom we may disclose your personal information. We may also provide you with additional information about how WealthO2 will use your personal information at the time that it is collected.

Personal Information we Collect

Any information that identifies you is deemed to be "personal information" and we primarily collect this information through our standard forms, information you provide through our website, and when you phone or contact our staff.

The type of personal information WealthO2 collects from you includes – your name, contact details (such as your address and telephone number), date of birth, investment details, bank account information and tax file number. The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. The Government's anti-money laundering laws may also require us to collect additional personal information from you.

Phone calls to WealthO2 staff may be recorded or monitored for quality control, training, regulatory or other compliance reasons.

When browsing our website WealthO2's webservers automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information. From time to time, WealthO2 may use 'cookies' in its website and may collect 'clickstream' data. Cookies and clickstream data collects information about your use of our website and potentially other websites.

How we Use Personal Information

WealthO2 uses your personal information to administer your investment, comply with relevant laws and communicate with you on an ongoing basis about your investment. We may also send you educational and marketing material about our other products and services we offer – you may contact us at any time to ask us not to send this information.

WealthO2 may use information that you provide through our website or over the phone for analysis to improve our products and services.

Staff may also use personal information to verify your identity over the phone.

In some circumstances WealthO2 may disclose your personal information to persons/entities outside of WealthO2.

For example:

WealthO2 uses agents and external service providers to help us provide our services to you.
WealthO2 will facilitate the opening of your Broker, CMA and other third-party accounts required for the service provided to you.
From time to time we may be required to provide your details to a governmental or regulatory body (such as ASIC, ATO, AUSTRAC, or a law enforcement agency).
A court order may require us to disclose certain information.
WealthO2 takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and WealthO2, are authorised.
You may also authorise us to disclose information we hold about you to your financial adviser, accountant or other person nominated by you. Your express consent is required.

Exemptions Note – WealthO2 intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relating to employee records (we have, however, adopted a number of measures designed to protect the privacy of our employees).

* If you nominate an individual contact within an Advisory firm or Administrative firm, you will be taken to have given authority to the firm and as well as the individual contact.

Personal Information Security

WealthO2 regards the security of your personal information as a priority and has a number of physical and electronic protection measures in place.

You should be aware that the Internet is not a secure environment. Whilst WealthO2 takes reasonable steps, we cannot guarantee the security of information you provide to us via our website or that we make accessible to you via the secure Investor site. No personal data is stored on our public website. Personal data is stored on our secure Investor site.

Access to Your Personal Information

In many circumstances, you can request access to personal information we hold about you. Sometimes it is not possible for us to give you access in which case we will explain why.

You may also ask us to correct information which we hold about you which is inaccurate, incomplete or out of date.

Need to Contact Us?

If you have any questions about this Privacy Policy or how we handle your personal information, please send us an email to enquiries@wealtho2.com.au.

What if I have a Complaint or Concern?

If you wish to make a complaint about how WealthO2 has handled your personal information, or wish to access or correct your personal information held by us, please contact our Company Secretary and Privacy Officer, Mr. Colin Bernasconi, on 1300 726 008 or write to us at Suite 7.02 157 Walker Street, North Sydney, NSW, 2060.

As an Australian Financial Services Licensee, WealthO2 is a member of an external disputes resolution scheme, Australian Financial Complaints Authority (AFCA), AFCA may be able to assist with any complaints about privacy where it arises from one of our financial services, and we have not been able to resolve your complaint. You can contact AFCA on the details below:

Australian Financial Complaints Authority Limited

GPO Box 3

Melbourne VIC 3001

Via phone on 1800 931 678

Or through its website: www.afca.org.au

Our AFCA membership number is 39990

You can also contact them by email to: enquiries@oaic.gov.au.

If you are unhappy with the outcome, you may then subsequently refer your privacy complaint to the Privacy Commissioner on 1300 363 992

GPO Box 5218

Sydney NSW 2001

Office of the Australian Information Commissioner (OAIC)