The objective of this Policy is to protect the privacy of individuals dealing with Us and to explain how We collect, use, disclose and store Personal Information in accordance with the APPs. This Policy also describes why We collect Personal Information and how You can access and correct Personal Information about You. This Policy does not cover information collected about employees.
We may collect Personal Information or opinions about You in the normal course of Our dealings with You. This Personal Information is collected in order to conduct business with You. The Personal Information may include Your name, contact details, family details, financial information such as your financial circumstances and investment details, goals and strategies or other information that is required by Us to conduct business with You. Sensitive Information about You, such as Your professional membership(s) and/or trade association membership(s), will not be collected without Your consent.
We collect Personal Information, directly from You by such means as email or when You access Our client engagement platform.
Personal Information provided to Us will always be handled by Us in accordance with this Policy and the APPs, regardless of who provides it.
If Personal Information about You is collected from someone other than You and if We are notified that You are not aware that We have collected the Personal Information then We will take reasonable steps to notify You that the Personal Information has been collected and will be dealt with in accordance with this Policy and the APPs.
We provide financial services to Our clients. In order to obtain these services, You will need to submit Personal Information to Us. However, Personal Information provided by You for the purpose of obtaining any services may be tracked, edited and/or disclosed to third parties including licensors (such as Astute Wealth Advice Pty Ltd ACN 150 511 194) whose services and products we utilise in order to:
We may also use Your email address to:
We also use the Personal Information that We collect for other purposes such as providing customer support, market research and obtaining references.
We will only disclose Your Personal Information to persons or bodies external to Us where permitted by the Act, including in the following circumstances:
Although We seek to deal with reputable third parties, We cannot control, and will not be liable for, any use of Your Personal Information by any third party to whom Your Personal Information is sent with Your consent.
We do not disclose any Personal Information to overseas recipients unless You consent to the disclosure or where required by law.
We maintain the security of digital records through password protection, firewalls, network security, and restricting and monitoring access to Personal Information. However, no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully secure. We also maintain security over physical records through storing the records in locked offices and restricting access only to authorised personnel.
We generally retain Personal Information for a period of 7 years from the time Our dealings with You become inactive. Ordinarily, We will destroy the Personal Information held at the end of 7 years or any reasonable time thereafter.
You can request Us for Personal Information about You if it is stored by Us. The Personal Information will be provided within a reasonable time after receiving Your request. Requests for Personal Information may be sent to Us using any of the contact details provided in this Policy.
We may refuse to give access to Personal Information under certain circumstances permitted by law, such as where the request for access is frivolous or vexatious, giving access to Personal Information is unlawful, or if We suspect unlawful activity or anticipate legal proceedings with You. If We refuse to provide Personal Information, We will provide written notice to You within a reasonable time and that sets out the reasons for refusal unless it is unreasonable to do so.
We are committed to ensure that the Personal Information collected or used or disclosed is reasonably accurate, up-to-date and complete.
If You become aware that the Personal Information stored by Us is wrong, You have the right to have such Personal Information rectified. This facility is provided free of charge to You. You may rectify the Personal Information by providing any necessary documentation. Such details may be supplied by using any of the contact details provided in this Policy. The Personal Information will be corrected within a reasonable time after receiving all necessary documents.
If We correct Personal Information about You that We previously disclosed to another organisation and if You request Us to notify that other organisation of the correction, We will take reasonable steps to give that notification unless it is impracticable or unlawful for Us to do so.
The APPs allow for You to deal with Us without the need to identify Yourself or by using a pseudonym. However, considering the nature of Our business, it is impracticable for Us to deal with You if You have not identified Yourself. If We are not able to collect Your Personal Information, We may not be able to provide appropriate services or do business with You or any organisation with which You are connected.
We welcome feedback about privacy issues and will endeavour to attend to all questions and complaints promptly. You can contact Us about any privacy issues. If You are not satisfied with Our response, a complaint can be lodged with the Australian Information Commissioner at http://www.oaic.gov.au/privacy/making-a-privacy-complaint or You can call the OAIC enquiries line on 1300 363 992.
In this Policy:
19 June 2017