Privacy Policy

1. Purpose of the policy

Pinnacle Advisors (referred to as “we”, “us”, or “our”) is committed to protecting the privacy of personal information obtained through its operations as a professional services firm. Pinnacle Advisors is bound by applicable privacy laws, including the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and any relevant privacy code registered under the Privacy Act.

The purpose of this policy is to generally inform people of:

how and when we collect personal information and personal data;
how we use and disclose personal information and personal data;
how we keep personal information and personal data secure, accurate and up-to-date;
how an individual can access and correct their personal information and personal data; and
how we will facilitate or resolve a privacy complaint.

This policy sets out how Pinnacle Advisors handles personal information. This privacy policy does not apply to personal information collected by Pinnacle Advisors that is exempted under the Privacy Act, for example, employee records.

Our privacy policy will be reviewed regularly to take account of changes in legislation, technology, and our operations and practices. We aim to ensure the policy is appropriate to the changing environment. We will inform you of any changes we make to this privacy policy as necessary.

Our privacy policy is based on openness about how we use and protect your information.

2. Requesting a copy of Pinnacle Advisors Privacy Policy:

Our privacy policy is available by following links to the policy on our website footer. However, on request, we may provide you with a copy of the policy in an alternate format. If you have any enquiries or would like to request a copy of the policy, please contact our Privacy Officer (refer to contact details below).

3. Purposes for which Pinnacle Advisors collects, holds, uses and discloses personal information:

We only collect, hold, use, and disclose personal information which is reasonably necessary to ensure that we can provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use, and disclose your personal information.

4. Kinds of personal information Pinnacle Advisors collects:

Due to the nature of the products and services we provide and the requirements of legislation and regulations, we ask for a range of personal information from our customers.

The types of personal information we may collect can include details such as:

Names, employment titles, residency, contact details;
Date of birth and gender;
Information in identification documents (e.g., passport, driver’s licence);
Tax file numbers and other government-related identifiers;
Assets and liabilities;
CV, Educational qualifications and employment history;
Qualifications, memberships, and other accreditations;
Personal income and financial records;
Visa and work permit status;
Bank account details;
Shareholdings and details of investments;
Superannuation details;
Nature of Business, Tax and financial statements;
Information regarding insurance;
Personal information about your spouse and dependants.
advice received from the client or prospective client that may contain additional personal information, such as family relationships and other business-related connections;

It may be necessary in some circumstances for Pinnacle Advisors to collect sensitive information about you to provide specific services. The types of sensitive information we may collect include:

Health status;
Ethnic origin;
Details of any membership/s to professional associations;
Criminal record.

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information or request the use of anonymity or a pseudonym, we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.

5. Collection, holding, using and disclosing of personal information:

(a) Collection – General:

When we collect, hold, use, and disclose personal or sensitive information, it must be done through lawful and fair means. Consent must be obtained to collect, hold, use, and disclose personal information. We are not required to obtain your consent to collect, hold, use, or disclose your personal or sensitive information if the collection is required or authorized by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles. If you would like more information on these requirements, please contact our Privacy Officer.

(b) Methods of collection:

Pinnacle Advisors use a variety of formats for the collection of personal and sensitive information. These include:

Requiring clients to complete a Client Profile or other forms;
Receipt of emails, letters, and other correspondence;
Telephone calls;
Appointments in person;
Publicly available records;
Through a customer’s personal representative;
Through the use of our website, such as via contact mailboxes or online enquiry forms, or through the registration process (see more information about ‘web analytics’ in Clause 6).

In every circumstance, we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources in accordance with Clause 3(a) above.

(c) Collection of someone else’s personal information:

You should only provide us with someone else’s personal information where you have their express consent to do so, and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us. In providing such information, you agree that you have obtained the relevant consent and are authorized to do so.

Unsolicited personal information:

There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients.

In such situations, our Privacy Officer will determine whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained, it will be destroyed or de-identified. We will try to notify the relevant person, whose information has been mistakenly received if this situation arises.

6. Storage and Security of personal information

Pinnacle Advisors will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorized access, modification, or disclosure. We do this by employing a range of methods including:

secure server and network infrastructure;
encryption of data;
secure office premises; and
training staff on information security procedures and privacy policies.

Safeguarding the privacy of your information is important to us. We hold personal information in a combination of secure computer storage facilities and paper-based files and take steps to protect the personal information we hold from misuse, loss, interference, unauthorized access, modification, or disclosure.

Pinnacle Advisors trains its employees carefully on handling personal information and the confidentiality of such information.

When we no longer need your personal information for our purposes, we will take reasonable steps to securely destroy or de-identify your personal information.

7. Disclosure of personal information overseas and sharing personal information amongst and within the Pinnacle Advisors network

(a) Disclosure amongst and within the Pinnacle Advisors network:

Pinnacle Advisors has offices in various locations. To meet the purposes for which your personal information has been collected, we may disclose your information to others in the Pinnacle Advisors network.

(b) Disclosure overseas:

Pinnacle Advisors utilizes some service providers overseas to process data and help deliver services to you. We may disclose your personal information to these providers from time to time. Such overseas disclosure would typically be to countries such as India. When required, your personal information will only be disclosed to an overseas person or business in the following circumstances:

Where the overseas recipient has signed a contract with us which creates legal obligations to comply with Australian Privacy Law (i.e., the APPs);
If the recipient is subject to similar privacy laws as Australian privacy law, and you are able to personally access avenues to enforce the protection of those laws;
If you provide written consent for Pinnacle Advisors to disclose the information after we provide you with full information; or
If the disclosure is required or authorized by or under an Australian law or a court/tribunal order.

On collection of your personal information, we will inform you whether it is likely we will disclose the information to an overseas recipient and, if so, where those recipients are likely to be located.

(c) Disclosure to third-party service providers:

Pinnacle Advisors utilizes third-party providers (such as IT providers and market researchers) for its business and to deliver services to you. It may be necessary for us to disclose non-sensitive personal information to these providers from time to time. Such disclosure will be in accordance with this Privacy Policy and the APPs.

8. How we use your personal information

Pinnacle Advisors may at times use and disclose personal information about an individual for the “primary purpose” of collection (i.e., the dominant or fundamental purpose for which that information is collected).

The primary purpose includes facilitating our internal business processes, communicating with clients, prospective clients and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations, and dealing with enquiries and complaints.

In certain circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance, where a client would reasonably expect us to and the purpose is related to the purpose of collection).

For tax clients, tax file numbers:

can be collected by tax agents and accountants;
can be used only to conduct client’s affairs; and
can be disclosed only to the client and the Australian Tax Office.

9. Privacy on our websites

The Pinnacle Advisors website uses Google Analytics or other third-party software to analyze aggregate user behaviour. Google Analytics and such other software uses first-party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant Pinnacle Advisors access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased. For more information about Google Analytics, please follow the links provided on our website.

The information is collected using first-party cookies, meaning that only Pinnacle Advisors can access your information. Your information may be aggregated with information from other users for the purpose of improving our website and offerings. We will not associate any data gathered from our website with any personally identifiable information unless you explicitly submit that information (e.g., your email address) via our online information form.

Any links to third-party websites on Pinnacle Advisors’ website are not covered by our privacy policy.

10. Direct marketing

Pinnacle Advisors may engage in direct marketing to you from time to time.

When required, your personal information will only be used or disclosed for direct marketing where the information is not sensitive information, is collected directly from you, and there is an easy means to opt out of such marketing (and such an opt-out request has not been made) in the following circumstances:

Where you would expect Pinnacle Advisors to use or disclose the information for direct marketing purposes; or
You have consented to the use or disclosure of the information for direct marketing purposes.

If you do not wish to receive these materials, please contact our Privacy Officer.

11. Credit Information

Pinnacle Advisors may collect and hold various types of information about you, including credit information. We will hold and use such information in accordance with the Privacy Act and other relevant laws. For more detailed information about how we manage credit-related personal information, please refer to our separate Credit Reporting Policy.

12. Access to personal information

Pinnacle Advisors will take reasonable steps to ensure the personal information we collect, use, and disclose is accurate, complete, and up-to-date. If you believe that your personal information is inaccurate, incomplete, or out-of-date, you may contact us to request correction.

You have the right to access any personal information regarding you that Pinnacle Advisors holds. This is subject to some limited exceptions, which the Privacy Officer can explain to you. Such exceptions include:

Where providing access would have an unreasonable impact on the privacy of others;
Where the request for access is frivolous or vexatious;
Where the information relates to existing or anticipated legal proceedings between Pinnacle Advisors and you, and the information would not be accessible by the process of discovery in those proceedings;
Where providing access would reveal Pinnacle Advisors’ intentions in relation to negotiations with you in such a way as to prejudice those negotiations.

Requests for access to your personal information should be made in writing to our Privacy Officer.

For security reasons, you may be required to put your request in writing and provide proof of your identity before we provide you with access to your information.

In most circumstances, we will provide you with access to your personal information within 30 days of your request. If we cannot meet this time frame, we will inform you. If we refuse to give you access to any part of the information requested, we will tell you why in writing.

13. Correction of personal information

Pinnacle Advisors endeavours to ensure that the personal information we hold is accurate and up-to-date. We realize that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact Pinnacle Advisors as soon as possible to update any personal information we hold about you. Our contact details are below.

Where personal information held about you is inaccurate, out-of-date, incomplete, irrelevant, or misleading, you have the right to request us to correct it. If we refuse your request, we will tell you why in writing and how to complain about our refusal if you wish to do so.

14. Roles and Responsibilities

Our staff are trained to handle personal information in accordance with this policy and our information security procedures. We have designated roles within our organization to manage data protection and privacy compliance.

15. Modifications and Updates

Pinnacle Advisors reserves the right to modify this Privacy Policy at any time. Changes to the policy will be notified by updating the policy on our website and indicating the date of the update.

16. Complaints

If you believe that Pinnacle Advisors has breached the Australian Privacy Principles, you may make a complaint in writing to our Privacy Officer.

Our Privacy Officer will acknowledge receipt of your complaint within 7 days and will provide you with a written response within 30 days, outlining the outcome of the investigation and any steps taken to resolve the matter. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC).

17. How to contact us

For more information about our privacy practices, to make a complaint, to access or correct your personal information, please contact our Privacy Officer:

Privacy Officer

Pinnacle Advisors

Address: Poonam Apartments, Dr A.B.Road, Worli, Mumbai, Maharashtra, India 400 018

Phone: 9004597773

Email: accounts@pinnacleadvisorss.com

We will acknowledge your complaint within 14 days and provide a decision on your complaint within 30 days.

If you are not satisfied with the response from our Privacy Officer, you may contact the Office of the Australian Information Commissioner (OAIC).

This policy was last updated on May 14, 2024.