This Privacy Policy sets out the personal information handling practices of Wilson Pateras Accounting Pty Ltd ABN 40 184 483 623, Wilson Pateras Financial Planning ABN 85 301 035 961 and Wilson Pateras Lending and Finance Pty Ltd ABN 76 155 724 600 (“we“, “us” or “our“) current as at 01/01/2018.

We recognise the importance of privacy and we are committed to ensuring the privacy of your personal information. We are bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act 1988 and the Health Privacy Principles contained in the Victorian Health Records Act 2001 in respect of our handling of personal information and health information respectively.  In this Privacy Policy, “personal information” includes any information about an identified or reasonably identifiable individual and “health information” includes any information about the health of an individual that is also personal information.

By providing us with your personal information you consent to us handling it in accordance with this Privacy Policy. If you provide us with any personal information about another individual then we rely upon you to inform that individual of the details contained in this Privacy Policy.

We may amend this Privacy Policy from time to time. If we do so, we will publish the amended Privacy Policy on our website.

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:

• health;
• race;
• 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.

Direct marketing

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.

If you do not want to receive marketing communications from us, you can contact us as detailed at the end of this Privacy Policy (see ‘Contact us about Privacy’). In each direct marketing communication we send you, we will give you the opportunity to ‘opt out’ or unsubscribe from receiving marketing communications in the future.

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.  Like most major businesses, we use cloud storage and accounting programs such as Box and Xero to store and process your accounting affairs and personal information. If you would like further information, please do not hesitate to contact us.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, virtual private networks, 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.

Our website

If you access our website, we may collect additional information about you in the form of your IP address or domain name.

Our website uses ‘Cookies’. Cookies are small text files placed on your computer when you first visit the site and are used on some parts of our website. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer, your company’s IT help desk or your Internet service provider. We sometimes use cookies to analyse statistical data such as the date and time that you accessed the site and the internet address of the site that linked you to our site. We do not and are not able to use cookies to gain personal information.

Wilson Pateras uses remarketing to advertise online. Third-party vendors, including Google, show our ads on sites across the internet. Third-party vendors, including Google, use cookies to serve ads based on your past visits to this website. Visitors can opt out of Google’s use of cookies by visiting the Ads Preference Manager or visitors can opt out of a third-party vendor’s use of cookies by visiting Network Advertising Initiative opt-out page.

Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and any linked websites are not subject to our privacy policies and procedures. These third party websites are not under our control and we do not accept any responsibility for the conduct or operation of third party websites. Before disclosing information on any other website you should examine the terms and conditions and privacy policy of that website.

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 advice@wilsonpateras.com.au.

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 any questions about this Privacy Policy or would like to contact us for any reason about privacy, then we ask that you contact our Privacy Officer in writing by emailing advice@wilsonpateras.com.au

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
Email: enquiries@oaic.gov.au

You may contact the Office of the Health Services Commissioner by:

Phone: 1300 582 113
Post: Level 26, 570 Bourke Street, Melbourne, VIC 3000
Email: hsc@health.vic.gov.au