9 August 2023 – v2.0
We understand that your personal information is important to you, and we are committed to handling all personal information with care.
What is personal information?
Personal Information is any information or opinion about you that is reasonably capable of identifying you, regardless of whether the information or opinion is true or not and how it is recorded.
Kinds of personal information we collect and hold
The personal information we may collect, either from you or from third parties, and hold includes:
- name, residential or postal address, email address, date of birth, telephone numbers
- information contained on identification documents where we require to verify your identity such as passport, driver’s licence
- occupation, employment history and education history
- tax file numbers in Australia and overseas, tax residency status, and other government-issued identification numbers
bank account details, shareholdings and details of investments
- other financial information you provide to us or authorise us to access from third parties
- Internet Protocol (IP) address when you use our website and via electronic signing platforms (for example, DocuSign)
- details of your interactions with us, and any other information you give to us as a result of our dealings with you.
How we collect personal information
We may collect personal information directly from you when you:
- apply for a product or service
- submit electronic or hard copy forms with us
- participate in a phone or video conference call with us
- email or otherwise correspond with us, and
- visit our website.
We may collect information about you from others such as:
- your investment adviser
- our service providers
- regulator databases
- public sources such as public domain websites.
Collection of Sensitive Information
Sensitive information is personal information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information, or health information.
We will not collect, use, or disclose sensitive information about you unless we need the information for one of our functions or activities and we have your consent (or we are legally required to do so).
Other matters regarding our collection of personal information
Purposes for which we collect personal information
We collect personal information for the purpose of providing our products and services and undertaking our obligations and for any of the following purposes:
- to comply with our legal and regulatory obligations when we provide our services to you, such as:
- identify you as required under the Anti-Money Laundering and Counter-Terrorism Financing Act
- determine whether you are subject to withholding tax on any distribution payments you receive and to share information about distribution payments to the Australian Taxation Office
- establish your tax residency status under tax information sharing agreements the Australian Government has with other countries (the Foreign Account Tax Compliance Act and the Common Reporting Standard)
- to carry out or facilitate client instructions or responding to client queries or requests
- to manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, staff training and market or customer satisfaction research)
- to consider any concerns or complaints you raise against us and/or to manage any legal action between you and us
- to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct.
Who we disclose personal information to
We may disclose your personal information for any of the purposes described in this policy to the following parties:
- our service providers however, we do not authorise them to use or disclose such information other than to perform certain services on our behalf or to comply with legal requirements
- your investment adviser
- our representatives and advisors, including lawyers and accountants
- auditors we appoint to ensure the integrity of our operations
- other financial institutions, for example for AML/CTF customer identification purposes when providing custodial services
- any person acting on your behalf, including your solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney
- government agencies, regulatory bodies and law enforcement agencies, or as required by law
- other organisations who in conjunction with us provide products and services (so that they may provide their products and services to you).
We may use your personal details to provide you with newsletters and information about products, services or other events that may be of interest to you.
If at any time you do not wish to receive such information, you can ask us not to send you any further such material by contacting our Privacy Officer using the contact details provided in this policy.
Disclosing your personal information overseas
Some of our service providers which perform technology, operational and customer service functions on our behalf, may have hosting and cloud service providers in locations outside of Australia.
We will not use service providers who transfer personal information outside Australia unless we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract providing the same standards of protection of personal information as provided for under the Australian Privacy Principles.
Quality of information
We will take reasonable steps to ensure that your personal information is accurate, complete and current.
We will take reasonable steps to destroy or permanently de-identify your personal information, if it is no longer needed for any purpose for which the information may be used or disclosed under the Use and Disclosure section of this policy.
How we keep your personal information secure
We may store your personal information in hardcopy documents or electronically.
We are committed to keeping your personal information secure and take all reasonable precautions to protect it from misuse and loss and from unauthorised access, modification or disclosure. Our security measures include:
- training our staff about their obligations
- having passwords to control and restrict access to authorised staff
- having firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised access
- using dedicated secure networks or encryption when we transmit electronic data for outsourcing purposes
- having building security measures in place, and
- destroying and de-identifying personal information when it is no longer required.
Accessing and correcting your information
If you wish to verify what information (if any) we hold about you and/ or whether that information held is correct, you may contact our Privacy Officer by email at firstname.lastname@example.org
We will take reasonable steps to confirm the identity of the person making the request.
In some instances, we may not be able to provide access to all of your personal information, and if this applies, we will tell you why. We will take reasonable steps to ensure your information is corrected.
We will respond within 30 days, or any longer period as agreed by you.
There is no fee payable for requesting access to your personal information, but we reserve the right to charge a reasonable fee to cover the costs of providing access.
Making a privacy complaint
If you have a concern about the way we handle your personal information, please contact our Privacy Officer in the first instance at email@example.com
To help us complete a quick and effective investigation, please include your name, email address, and/or telephone number and describe your complaint in as much detail as you can.
Complaints received by the Privacy Officer will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated, and a response provided within 30 days. If the matter is more complex and we need more time to complete our investigation, we will advise you of this.
If you believe we have not adequately dealt with your complaint, you may contact the Privacy Commissioner, details of which can be found at www.oaic.gov.au
Privacy Officer Contact
Our Privacy Officer’s contact details are:
- Email: firstname.lastname@example.org
- Mail: Boutique Capital, Suite 211, 3 Eden St, North Sydney NSW 2060
- Phone: 1800 541 155