General information

The types of information that we collect and hold about you could include:

• ID information such as your name, postal or email address, telephone numbers, and date of birth;
• Your goals and aspirations;
• financial details such as your salary and assets you own; and
• other information we think is necessary ie, liabilities and loans.

When the law authorises or requires us to collect information

We may collect information about you because we are required or authorised by law to collect it. There are laws that which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.

What do we collect via your website activity?

If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.

We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum.

To improve our services and products, we sometimes collect
de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.

How do we collect your personal information?

How we collect and hold your information
Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.

There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.

How we collect your information from other sources

Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:

• we collect information from third parties about the loan or lease made available to you arising out of the services we provide you;
• we can’t get hold of you and we rely on public information to update your contact details; or
• we exchange information with your legal or financial advisers or other representatives.

What if you don’t want to provide us with your personal information?

If you don’t provide your information to us, it may not be possible:

• for us to give you the financial planning assistance you seek from us;
• verify your identity or protect against fraud; or
• to let you know about other products or services that might be suitable for your financial needs.

How we collect and hold your credit information

We will collect your credit information in the course of you answering the enquiries we make of you relating to the financial planning assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting information are:

• your employer, accountant, real estate agent or other referees;
• your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents; and
• bodies that issue identification documents to help
  us check your identity;

What do we do when we get information we didn’t ask for?

Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.

When will we notify you that we have received your information?

When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we take care of your personal information?

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

• document storage security policies;
• security measures for access to our systems; and
• only giving access to personal information to a person who is verified to be able to receive that information

We may store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

What happens when we no longer need your information?

We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

What are the main reasons we collect, hold and use your information?
Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:

• give you financial planning assistance;
• give you information about our services; and
• administer services we provide, for example, to answer requests or deal with complaints.

Can we use your information for marketing our products and services?

We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you.

We will always let you know that you can opt out from receiving marketing offers.

With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.

Yes, You Can Opt-Out

You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.

What are the other ways we use your information?

We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:

• identifying you;
• telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
• allowing us to run our business efficiently and perform general administrative tasks;
• preventing any fraud or crime or any suspected fraud or crime;
• as required by law, regulation or codes binding us; and
• any purpose to which you have consented.

Who do we share your personal information with

To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.

Sharing Your Information

We may use and share your information with other organisations for any purpose described above.

Sharing with your representatives and referees

We may share your information with:

• your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and
• your referees, like your employer, to confirm details about you.

Sharing with third parties

We may share your information with third parties in relation to services we provide to you. Those third parties may include:

• referrers that referred your business to us;
• organisations, like fraud reporting agencies, that may identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
• government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law. In some instances, these bodies may share the information with relevant foreign authorities;
• service providers, agents, contractors and advisers that assist us to conduct our business;
• any organisation that wishes to take an interest in our business or assets; and
• any third party to which you consent to us sharing your information.

Sharing outside of Australia

We are not likely to disclose your information to organisations overseas. However, we may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held.

How you can generally access your information
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone.

We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.

We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:

• we believe there is a threat to life or public safety;
• there is an unreasonable impact on other individuals;
• the request is frivolous;
• the information wouldn’t be ordinarily accessible because of legal proceedings;
• it would prejudice negotiations with you;
• it would be unlawful;
• it would jeopardise taking action against serious misconduct by you;
• it would be likely to harm the activities of an enforcement body (e.g. the police); or
• it would harm the confidentiality of our commercial information.

If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain.

How do you correct your personal information?

How we correct your information
Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:

• inaccurate;
• out‑of‑date;
• incomplete;
• irrelevant; or
• misleading.

If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can – if we can’t, then we’ll let you know in writing.

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.

You can contact us by using the details below:
PO Box 832
Sanctuary Cove QLD 4212
Ph: (07) 5530 8407

We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.

Need more help?

If you still feel your issue hasn’t been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:

Online: www.oaic.gov.au/privacy
Phone: 1300 363 992
Email: enquiries@oaic.gov.au
Fax: +61 2 9284 9666
Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601