Effective 31 October 2020
Personal information which an individual or that can reasonably enable their identity to be determined. For example, this may include your name, date of birth and contact details.
Personal information includes “sensitive information”. Sensitive information is any information, or an opinion concerning about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record. It also includes health or genetic information, biometric information and biometric templates.
We will only collect “sensitive information” if you have consented to the collection of the information and the information is reasonably necessary for one or more of our functions or activities or if the collection of sensitive information is authorised or required by a court/tribunal order or an Australian law, including the following Australian laws:
What personal information do we collect?
We may collect the following types of personal information:
We may collect these types of personal information either directly from you, or from third parties (for example, identity verification service providers, publicly or commercially available sources or third parties you have authorised us to contact). We may collect this information when you:
If it is lawful and practicable, we offer you the opportunity to deal with us anonymously or by using a pseudonym. For example, we can provide general information to you about our products or services, or general guidance on how to fill out our forms without collecting any personal information.
However, if we are unable to collect and/or verify some or all of your personal information, we may not be able to enter into a business relationship with you or provide certain services to you. In order for us to provide our services to you it is normally impracticable for us to deal with you anonymously or by using a pseudonym. For example if you do not provide your personal information to us, we will be unable to properly administer your investment, contact you about your investment or adequately provide our services.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
If you cease your relationship with us, we will only retain your personal information on file to the extent necessary to meet our regulatory obligations and we will only contact you with your consent.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, provided in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
To whom do we disclose your personal information?
We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.
If you do not consent to us collecting, using and/or disclosing your personal information for such other purposes, this may affect our ability to deliver and improve our products and services, or to engage or do business with you.
Disclosure of personal information outside Australia
We will only disclose your personal information to a recipient overseas in accordance with the Privacy Act.
We may disclose personal information outside of Australia to third party suppliers such as cloud providers located in the United States.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian privacy laws. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles under the Privacy Act.
Using our website and cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we use third party cloud based providers that utilise multi-layered encryption to electronically store and restrict access to our files. We regularly review, monitor and update our security policies and systems. However, we cannot guarantee the security of your personal information.
You are responsible for keeping any account details, username and password confidential and secure at all times.
We take reasonable steps to destroy or permanently de-identify personal information that we are not required by law to retain.
Third part website and services
Please note that:
Accessing or correcting your personal information
You can seek to access the personal information we hold about you by contacting us at firstname.lastname@example.org. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you contact us about your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected (and, if we are unable to do so, we will tell you why).
To ensure that the information we hold about you remains accurate, complete and up-to-date, we may ask you to check and correct your personal details from time to time. We may do this as part of our regular communications with you, when you make a telephone enquiry, or through other means.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us at email@example.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.
If you are not satisfied with the manner in which we deal with your complaint you may refer it to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC:
Online: by visiting www.oaic.gov.au
Phone: 1300 363 992
Mail: GPO Box 5218
Sydney NSW 2001