Privacy Policy

01About this Privacy Policy

We are bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (APPs). This policy applies to personal information we collect through our financial services, our website and our dealings with you. By providing us with your personal information, you consent to it being collected, held, used and disclosed in accordance with this policy.

02The information we collect

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. The information we collect depends on the services we provide to you and may include:

• Your name, contact details, date of birth and identification documents;
• Financial information such as your income, assets, liabilities, expenses, superannuation, insurance and investment details;
• Tax-related information, including your Tax File Number;
• Employment and family details; and
• Your goals, objectives and attitude to risk.

Sensitive information. In providing certain advice (for example, personal and risk insurance), we may need to collect sensitive information, including health information. We collect sensitive information only with your consent and where it is reasonably necessary for our services, unless we are otherwise required or permitted by law.

03How we collect your information

We collect personal information in a number of ways, including:

• Directly from you — in person, by telephone, by email, through our website, or via forms and questionnaires;
• From third parties you authorise us to deal with, such as your accountant, solicitor, mortgage broker, employer, superannuation fund, product issuers and platform providers;
• From publicly available sources; and
• Automatically when you use our website (see “Cookies and our website”).

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym. In most cases, however, we will need to identify you in order to provide our services and to meet our legal obligations.

04Why we collect, hold, use and disclose your information

We collect, hold, use and disclose your personal information for purposes including:

• Providing financial advice and services to you;
• Assessing your needs and preparing recommendations;
• Implementing and administering products and services;
• Verifying your identity and meeting our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• Complying with our legal and regulatory obligations, including under the Corporations Act 2001 (Cth);
• Maintaining and improving our services; and
• Where permitted, providing you with information about products and services that may be of interest to you.

We use or disclose your information only for the purpose for which it was collected, a related purpose you would reasonably expect, or as otherwise required or permitted by law.

05Who we disclose your information to

We may disclose your personal information to:

• Product issuers, platform operators and other financial institutions necessary to give effect to our advice;
• Our representatives, employees and contractors;
• Service providers who assist us with paraplanning, administration, technology, data hosting and professional services;
• Related businesses and professional partners (including accounting and mortgage broking services) where relevant to your advice and permitted by law;
• The Australian Financial Complaints Authority (AFCA);
• Regulators and government agencies, including ASIC, the Australian Taxation Office and AUSTRAC; and
• Any other party where you have consented, or where we are required or permitted by law.

We require our service providers to handle personal information in a manner consistent with the Privacy Act.

06Direct marketing

From time to time we may use your personal information to provide you with information about products, services or offers we believe may be of interest to you. You can opt out of receiving marketing communications at any time by contacting our Privacy Officer or by using the unsubscribe facility in the relevant communication. We do not use sensitive information for direct marketing without your consent.

07Disclosure to overseas recipients

Some of our service providers — for example, cloud-based technology and data-hosting providers — may store or process information outside Australia. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure it is handled consistently with the APPs. The countries in which such recipients are located may change from time to time, but may include those in which our technology providers operate.

08How we hold and protect your information

We hold personal information in both electronic and physical form, and take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include access controls, secure systems, staff training and confidentiality obligations.

We retain personal information for as long as it is required to provide our services and to meet our legal and regulatory obligations — for financial advice records, generally a minimum of seven years. When information is no longer required, we take reasonable steps to destroy or de-identify it.

09Cookies and our website

Our website may use cookies and similar technologies to help it function and to understand how visitors use it. This information is generally aggregated and does not identify you. You can manage or disable cookies through your browser settings, although some features of the website may not function properly as a result.

10Tax File Numbers

Where you provide your Tax File Number (TFN), we handle it in accordance with the Privacy Act and the Taxation Administration Act 1953 (Cth). We use and disclose TFN information only for lawful purposes, such as administering superannuation and investment products, and we do not use it to identify you for any other purpose.

11Accessing and correcting your information

You may request access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. To make a request, contact our Privacy Officer using the details below.

We will verify your identity before providing access and will respond within a reasonable time. There is no fee to make a request, although we may charge a reasonable fee for the reasonable costs of providing access. If we decline a request, we will explain why and how you may complain.

12How to make a privacy complaint

If you have a concern about how we have handled your personal information, please contact our Privacy Officer. We will acknowledge your complaint, investigate it, and respond to you within a reasonable time.

If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC):

• Website: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

13Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or our legal obligations. The current version will be published on our website and applies from the date shown. We encourage you to review it periodically.

14Contact us

For any privacy question or request, please contact our Privacy Officer: