Purposes for which we collect, hold, use and disclose personal information
We collect, hold, use and disclose personal information for purposes relating to our accounting, financial and lending functions and activities. For example, we may collect, hold, use or disclose your personal information for one or more of the following purposes:
- providing you with our products or services;
- your attendance at our events;
- managing our client relationship with you;
- providing you with information about our products, services or events;
- carrying out our accounting, financial or lending functions and activities; and
- complying with our legal or regulatory obligations.
Types of personal information we collect
The types of personal information that we collect and hold about you depends on the type of product or service that we are providing to you.
The personal information that we may collect and hold about you includes:
- name, address and contact details, including email addresses;
- date of birth, age and your intended plans for retirement;
- marital status and information regarding any previous relationships;
- financial goals, needs, objectives and circumstances;
- details of your dependents and beneficiaries;
- financial information (for the purposes of preparing a tailored financial plan and/or statement of advice);
- your employment details (including your occupation, details of your employer, the nature of your employment and salary);
- details of any corporate structure which may be used by you to own and/or operate your business (and details of the relevant corporate entities);
- your Australian Tax File Number and Australian Business Number (where you have provided those to us);
- in some cases, insurance claim information;
- details of your assets, or assets in which you wish to invest;
- details of your health insurance provider (and relevant membership numbers);
- legal documents to which you are a party (including your will); and
- documentation which verifies your identify (which, in some cases, we are required to collect by the Commonwealth Anti-Money Laundering and Counter-Terrorism Financing Act 2006).
We do not generally collect sensitive information about you unless required by applicable law or rules, or you have consented to it. Sensitive information includes information relating to:
- political or religious beliefs;
- sexual preferences;
- criminal convictions; or
- membership of professional trade, associations or unions.
We collect health information with your consent where it is relevant for some types of insurance.
If we are not provided with the personal information about you which we request then we may not be able to provide you with our products or services and you may not be able to attend our events.
Manner of collection of personal information
We usually collect personal information directly from you in person or when you communicate with us by telephone, email, standard form, letter, facsimile or other means. For example, we may collect your personal information directly from you when:
- you request us to provide you with our products or services;
- you attend our events;
- you request us to provide you with information about our products, services or events;
- you complete a survey or provide feedback in respect of our products or services; or
- you subscribe to receive news or other information about our products or services.
We may also collect your personal information from a third party or publicly available source for the purpose of carrying out our accounting, financial or lending functions and activities.
We may use your personal information to send you publications that may be of interest to you (such as newsletters), invitations to events and product information alerts.
Disclosure of personal information
We may disclose your personal information to third parties for the purpose of carrying out our accounting, financial or lending functions and activities including implementing and administering your legal, taxation and investment matters, and providing you with our products or services. Third parties to whom we may disclose your personal information include:
- your authorised representatives in connection with providing you with our products or services
- other professional advisors such as accountants, auditors, lawyers and financial planners;
- our service providers that assist us to carry out our accounting, financial or lending functions and activities including information technology providers and marketing providers;
- contractors who assist us to process client work;
- insurance companies;
- financial institutions, including for the purpose of procuring finance for your investments where you have requested us to do so;
- organisations offering products and services you wish to invest in or obtain; and
- regulatory and government bodies in connection with carrying out our accounting, financial or lending functions and activities.
Some of these third parties to whom we may disclose your personal information may be located overseas. For instance, we may disclose your personal information to our contracted service provider in India, Carisma Solutions Private Limited, to assist us in providing accounting and other services to you.
We do not sell personal information to other organisations or allow third parties to whom we disclose personal information to do this.
Quality of personal information
It is in our interests to ensure that the personal information that we have about you is accurate, complete and up-to-date. To assist us with this, please advise us as soon as practicable if you believe that any of the information that we have about you is not accurate, complete or up to-date, and all reasonable effort will be made to correct your information.
Personal Information Security
We are committed to keeping your personal information secure. We will use all reasonable steps to protect the personal information which we hold from misuse and loss and from unauthorised access, modification and disclosure. We store your personal information in different ways, including in paper and electronic format. The measures we take to protect the security of your personal information include electronic and physical security measures, such as:
- securing our premises, by requiring security passes to enter our offices;
- placing passwords and varying access levels on databases to limit access and protect electronic information;
- the use of Firewalls, encryption, passwords and digital certificates;
- providing locked cabinets and rooms for the storage of physical records; and
- requiring our staff to undertake privacy and data protection training.
Where the information we collect is no longer required, we will delete the information or permanently de-identify it.
If you access our website, we may collect additional information about you in the form of your IP address or domain name.
Access to Personal Information
Under the Australian Privacy Principles and Health Privacy Principles you have rights to access personal information and health information respectively that we hold about you, except as set out below. If you wish to access the information, please contact our Privacy Officer at firstname.lastname@example.org
In some circumstances, we may refuse to give you access to your personal information or health information. Those circumstances are set out in the Australian Privacy Principles and Health Privacy Principles respectively and include situations when your request may unreasonably impact on another person’s right to privacy and frivolous or vexatious requests. If we are entitled, under the Australian Privacy Principles or Health Privacy Principles, to refuse to give you access to your personal information or health information respectively, we will tell you and provide reasons for our decision.
We reserve the right to charge a reasonable fee for fulfilling your request for access to your personal information or health information.
Contact us about Privacy
If you have a complaint, we will respond and advise whether we agree with your complaint. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider appropriate to take in response. If you are still not satisfied after having contacted us, then if your complaint relates to our handling of your personal information you may contact the Office of the Australian Information Commissioner or, alternatively, if your complaint relates to our handling of your health information, you may contact the Office of the Health Services Commissioner.
You may contact the Office of the Australian Information Commissioner by:
Phone: 1300 363 992
Post: GPO Box 5218, Sydney, NSW 2001
You may contact the Office of the Health Services Commissioner by:
Phone: 1300 582 113
Post: Level 26, 570 Bourke Street, Melbourne, VIC 3000