1. Introduction

References to “PivotPB” in this Privacy Policy includes TwoFold Solutions Pty Limited ACN 634 689 142 trading as Pivot Property Buyers ABN 14 634 689 142, and any related entities (as defined pursuant to the Corporations Act 2001 (Cth)). PivotPB provides buyer agency services to prospective property buyers including, but not limited to, buyer consultation, research, evaluation, advisory, negotiation and other buyer advocacy or related services (Services).

This privacy policy applies to use of the Services, our website and dealings with us in any other manner, including by actual or prospective buyers, authorised representatives, prospective employees, persons engaged in a business related to PivotPB’s Services or other third parties.

PivotPB (also referred to as “we”, “our” and “us”) is committed to protecting your privacy and personal information when you use our Services, our website or interact with us.

The purpose of this Privacy Policy is to explain how and why we collect, hold, use and disclose your personal information to assist us in carrying on our business. By providing us with your personal information, you consent to us holding, using and disclosing it as set out in this Privacy Policy. We will comply with obligations under the Privacy Act 1988 (Cth) (Privacy Act) (including the Australian Privacy Principles (APPs) and the Privacy (Credit Reporting) Code 2014 (CR Code)).

We may update this Privacy Policy from time to time and changes will take effect when published on our website. You should periodically view our website to stay up to date with the current terms of this Privacy Policy.

This version of the Privacy Policy was last updated on 21 September 2022.


2. Collection and Use of Personal Information

2.1 What is “Personal Information”

The Privacy Act currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.

If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.

2.2 Information We Collect

We collect information that personally identifies you, which may include your name, address, phone number, mobile number, email address, payment information (including credit card details), financial information (including assets, liabilities, income, spending patterns and credit-related personal information), property ownership details, property preferences and device information. We may collect additional personal information from time to time.

Depending on your requests in relation to the provision of Services we may also collect sensitive information. We will usually only collect sensitive information where consent has been obtained, and when the information is reasonably necessary for provision of our Services. It is usually optional for you to supply sensitive information.

You don’t have to give us the information requested. However, if you do not provide us with some or all of the personal information requested, we may not be able to provide you with our Services or satisfy your request, to the requested standard or at all, and you may also miss out on receiving valuable information about PivotPB or our Services.

2.3 Consent to Collection and Use

By using the PivotPB website and Services, providing information to us via any medium (including engaging with us through any social media channel such as Facebook or Instagram), or entering into an agreement or other arrangement with us, you are consenting to the collection and use of your personal information in accordance with this Privacy Policy.

You consent to us collecting sensitive information which you provide to us voluntarily.

2.4 Why We May Collect, Hold, Use and Disclose Personal Information

PivotPB may collect, hold, use and disclose personal information about you to provide and improve the quality of the PivotPB Services. Our collection, holding, use and disclosure of your personal information will depend on our relationship with you, the circumstances of collection and the type of Services you request, but may include the following:

(a) to perform and manage our business functions or activities, including providing our Services to you and facilitating your purchase of a property;
(b) to provide you with communications and resources;
(c) to obtain the services of third party service providers as part of providing our Services;
(d) to manage invoicing and payment systems and services;
(e) to manage and improve our Services and relationships including for data analysis to predict moving trends, market insights and identify products and services of value to buyers;
(f) to inform and conduct marketing activities including to promote any other products or services, unless you tell us not to; and
(g) to maintain our records and comply with our legal obligations.

We may also collect, hold, use and disclose your personal information for other reasons where the law allows or requires us to do so.

2.5 How We Collect Personal Information

The main ways we collect personal information are:

(a) if you access our website or engage with us via social networking services such as Facebook or Instagram, including by the use of cookies, which may track what you view on our website and also other websites that you visit;
(b) if you subscribe to our mailing list;
(c) in connection with the supply of Services;
(d) if you request us to provide you with information regarding PivotPB Services. This may include online, email and telephone enquiries;
(e) via databases in the public domain or referrals and recommendations from existing clients or associates of PivotPB; and
(f) via third parties we may engage to assist us in provision of services, marketing and advertising. These third parties may use cookies and other technologies to obtain information about your preferences when you access online platforms or websites other than our website. Your preferences collected in this manner may be disclosed to us. These third parties may include service providers that may provide market leads or marketing services to us and online platforms.

We may also obtain your personal information from our affiliates or advertising partners, members and other third parties, marketing websites, any other websites accessible via our website that we consider help us to deliver or advertise our Services, understand online activity and collect information that we consider important to managing the quality or content of the Services that we deliver.


3. Disclosure of personal information

3.1 Disclosure of personal information to third parties

We may disclose your personal information to third parties as a part of providing the PivotPB Services, including:

(a) to owners of properties and/or their representatives;
(b) to personnel of PivotPB for the purposes of operating our business, fulfilling requests and providing the PivotPB Services;
(c) to any contractors or third parties we engage to assist with the provision of the PivotPB Services including to nominated legal advisors, mortgage brokers, Council or for the purpose of obtaining building, pest or strata reports (where requested);
(d) to marketing, advertising and promotions services providers and event organisers in connection with our marketing, advertising or events;
(e) to service providers of other administrative or operational services to PivotPB, such as market research companies, IT service providers, payment processors and debt collectors;
(f) to law enforcement or government agencies or other third parties, if permitted or required by law; and/or
(g) otherwise with your consent.

PivotPB may impose contractual restrictions equivalent to those imposed on PivotPB under the Privacy Act in respect of collection and use of personal information by third parties. In some cases, PivotPB’s ability to impose contractual restrictions is limited. In those circumstances, PivotPB will carefully consider the risks to the protection of personal information when entering into arrangements with third parties.

In the event of a data breach likely to cause serious harm involving your personal information, we will notify you in accordance with our Notifiable Data Breaches scheme obligations under Part IIIC of the Privacy Act.

3.2 Cross-border disclosure of personal information

Some of PivotPB’s third party contractors may be located overseas or perform services overseas and as a result your personal information may be disclosed to a third party in a foreign country.

Under the Privacy Act, we must take reasonable steps, before personal information is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach Australian privacy laws in relation to that information (the Obligation).

The Obligation does not apply if you consent to disclosure of your personal information to an overseas recipient.

By supplying personal information to us you consent to the disclosure of your personal information to an overseas recipient and agree that the Obligation does not apply.


4. Accessing your personal information

3.1 Disclosure of personal information to third parties

You have the right to request access to personal information that is held by PivotPB about you.

You also have the right to request the correction of any of your personal information that PivotPB holds. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date.

To seek access to, or correction of, your personal information please contact PivotPB as follows:

By email to our Privacy Officer:
[email protected]
By phone:
1300 402 424

PivotPB also welcomes any comments on its Privacy Policy to assist with the evaluation of its effectiveness. Comments will be handled confidentially.


5. Use of your personal information to contact you

We will never knowingly send you unsolicited commercial electronic messages. More information on the Spam Act 2003 (Cth) is available from the regulator’s website:

We may use information that we know about your requests or interests to tell you about PivotPB Services. We may know about your requests or interests because you have provided that information.


6. Opting out

If you decide that you do not want to be contacted by PivotPB please contact us (details at clause 4 above). You may also opt out of receiving communications by following the unsubscribe function on PivotPB communications.

We will use reasonable endeavours to remove your name from the mailing lists within a reasonable period of receiving your request.


7. Storage and protection of your personal information

PivotPB stores personal information electronically on servers hosted by our service providers. PivotPB has implemented appropriate physical, electronic and managerial security procedures in order to protect personal information from loss, misuse, alteration or destruction. PivotPB regularly reviews security and encryption technologies and will strive to protect information to the fullest extent possible.

Due to the nature of the internet, PivotPB cannot give any warranties as to the security of any personal information transmitted by you to PivotPB over the internet, or that personal information will not be accessed by unauthorised persons.

We encourage you to be vigilant about the protection of your own personal information when using any digital services.


8. Linked Sites

Our website may contain links to other sites. We are not responsible for the privacy practices or the content of such web sites. We encourage you to read the privacy statements of any linked sites as their privacy policy may differ from ours.


9. Personal Information About Other People

If you give us personal information about any other person in relation to or in connection with the provision of our Services:
(a) we are entitled to assume that you have sought their consent to the disclosure of such personal information to us; and
(b) we will collect, hold, use and disclose their personal information in accordance with this Privacy Policy.


10. Complaints

If you wish to make a complaint about PivotPB’s handling of your personal information, you should first make a complaint in writing to PivotPB. PivotPB will handle your complaint seriously and confidentially and will provide you with a response in a reasonable time period (usually 30 days). If PivotPB is unable to resolve your complaint, or you are not satisfied with the response, you may seek to have the matter resolved through mediation.


11. National Privacy Commissioner

If you are not satisfied with the way in which we handle your enquiry or complaint, or you wish to make a complaint about any perceived breach by PivotPB of the APPs you can contact the Office of the Australian Information Commissioner on:

Tel: 1300 402 424 or email: [email protected].