Privacy Policy Statement

Effective Date: 15th Dec 2025

Opifer is a registered brand of ADMA Consulting Pty Ltd, ABN: 70 693 513 629 (referred to as "we", "us", or "our") is committed to protecting the privacy of your personal information. This Privacy Policy outlines how we manage and protect the personal information we collect, including commercial and financial data, in compliance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth), as amended.

Information We Collect (APP 3)

1.1 We collect personal information that is reasonably necessary for the primary purpose of providing our financial consulting services,

managing our relationship with you, and tracking key commercial and financial indicators for the purpose of our services.

1.2 The kinds of information we may collect include:

1.2.1 Identification and Contact Data: Name, address, email address, phone number, and job title.

1.2.2 Financial and Commercial Data: Financial statements, profitability reports, revenue figures, cost structures, banking and transaction details, and

other key commercial indicators related to your SME.

1.2.3 Technical Data: IP address, cookies, and website usage data for security and performance purposes.

1.3 We collect this information directly from you (e.g., via website forms, client data intake, or documents provided during consultation).

Why We Collect and Use Information (APP 6)

2.1 We use your personal and commercial information for the following primary purposes:

2.1.1 To provide the requested financial consulting services, including detailed analysis of your financial results and tracking of key performance

indicators.

2.1.2 To fulfil our administrative, billing, and contractual obligations to you.

2.1.3 For internal risk management, training, and operational purposes.

2.2 We will not use your personal information for a secondary purpose unless permitted by the APPs, such as where we have your consent or where the

use is related to the primary purpose and you would reasonably expect it.

2.3 We may use automated processes to analyze your financial and commercial data to identify patterns, trends, or risks relevant to our services. We do

not use automated decision-making alone to make decisions that have legal or similarly significant effects on you. If we do utilize automated

processes or profiling, we will provide you with information about this practice and our processes upon request.

Disclosure of Information (APP 6 & 8)

3.1 We may disclose your personal information to:

3.1.1 Our professional advisors (e.g., accountants, auditors, or legal counsel) on a confidential basis.

3.1.2 Third-party service providers (e.g., cloud data storage hosts, IT support, or payment processors) strictly for the purpose of carrying out our

services, which may include overseas entities. Data could be stored in multiple locations by third-party software contracted by us to carry out

our services, which could include overseas locations.

3.1.3 Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients comply with the APPs or

equivalent privacy protections. Where this cannot be assured, we will notify you and obtain your consent before disclosure.

3.1.4 Any entity where disclosure is required or authorised by Australian law (e.g., ASIC, ATO, or police investigations).

3.2 We will not sell your personal information to third parties.

Data Security and Storage (APP 11)

4.1 We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, or disclosure. Our protective measures include technical and organizational safeguards. We implement measures appropriate to the sensitivity of the information, the nature of our processing, and the risks involved.

4.2 When personal information is no longer needed for any purpose for which it was collected, we will take reasonable steps to destroy or permanently de-identify the information, in accordance with the law.

SMS

5.1 We respects your privacy. By opting into our SMS messaging service, you agree to the following terms regarding how we handle your data:

5.1.1 Data Collection: We collect your name and mobile phone number when you sign up for SMS updates.

5.1.2 Data Usage: We use your data solely for sending updates, promotions, and reminders related to our services.

5.1.3 Data Security: We protect your data through encryption and secure storage measures to prevent unauthorised access.

5.1.4 Data Retention: We retain your information as long as you are subscribed to our SMS service. You may request deletion at any time.

5.1.5 Opt-Out: Reply STOP to any message to unsubscribe from our SMS list. After unsubscribing, we will remove your number from our list within 24 hours.

5.2 Non-Sharing Clause: We do not share your data with third parties for marketing purposes. Your information is only shared with our SMS service provider to enable messaging.

Data Retention

6.1 We retain personal information for the period necessary to provide our consulting services and to fulfill our contractual, legal, tax, and administrative obligations.

6.2 Personal information relating to client relationships is generally retained for a minimum of seven (7) years after the conclusion of the engagement, in accordance with accounting records retention requirements.

6.3 Where information is no longer required, we will destroy or securely de-identify it unless longer retention is required by law.

Data Breach Notification (APP 1 & Notifiable Data Breaches Scheme)

7.1 We comply with the mandatory data breach notification scheme under the Privacy Act 1988. If we experience an eligible data breach (unauthorized access to, or disclosure of, personal information that is likely to result in serious harm to affected individuals), we will:

7.1.1 Assess the breach within thirty (30) calendar days to determine whether notification is required.

7.1.2 Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable.

7.1.3 Notify affected individuals as soon as practicable with details of the breach, our response, and recommended steps to mitigate risk.

7.1.4 Make a public statement on our website if notification of individuals is not practicable.

7.2 You have the right to lodge a complaint with the OAIC regarding any data breach.

Access and Correction (APP 12 & 13)

8.1 You have a right to request access to the personal information we hold about you and to request that we correct any inaccurate, incomplete, or out-of-date information.

8.2 To request access or correction, please contact our Privacy Officer using the details below. We will respond to your request within a reasonable time and will take reasonable steps to correct the information.

Complaints and Contact Details (APP 1)

9.1 If you have any questions about this Privacy Policy or believe we have breached the APPs, please contact our Privacy Officer in writing:

Email: [email protected]
Postal Address: Ground Floor 470 St Kilda Rd, Melbourne, Victoria, 3004

9.2 We will acknowledge your complaint and aim to investigate and resolve it within thirty (30) days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).