Collection of personal information
We only collect and hold personal information, about you as a subscriber or your clients, that is reasonably necessary for one or more of our business functions or activities, which may include:
facilitating services to or by us, where you or your organisation is a client or service provider or potential client or service provider;
as required by law; and or
direct marketing of our services to you.
If you choose not to provide us with personal information, we may be unable to do such things.
Personal information is defined in the Privacy Act to mean information or an opinion about an identified individual or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Generally, the type of personal information we collect about you is the information included in your application for and/or registration regarding our investment offers and any personal information you upload through our website. For example, your name, mailing address, telephone number and e-mail address.
Whenever it is reasonable and practicable to do so, we only collect personal information directly. We may collect personal information by telephone, letter, e-mail or when using or visiting our website.
Use and disclosure of personal information
We may use and disclose personal information that we hold for the particular purposes for which it was collected. We will not use or disclose any personal information for any other purpose without consent, unless an exception applies under the APPs. We may disclose personal information to:
suppliers of services to us, including organisations to whom we outsource functions such as data storage;
our related entities;
a person authorised to act on your behalf;
administrators of your company’s account;
consultants who market or promote our offers and services;
otherwise if we have obtained consented; and or
otherwise as required by law.
We may use or disclose personal information for direct marketing of our offers or services, including by email. We will only use personal information for direct marketing where we have collected the information directly from you, have made you aware that the information may be used for such purpose, or you have consented to use of the information for such purpose. However, individuals may request not to receive direct marketing communications by contacting us.
Cross-border disclosure of personal information
In providing our services, Company, its service providers or clients may disclose personal information to a person outside of Australia (“overseas recipient”), including to overseas facilities or contractors to process or back up our information or to provide certain services to us. Company may disclose personal information to overseas recipients in New Zealand and the United States. Unless we obtain informed consent to the disclosure or another exception applies under the APPs, where personal information is disclosed to an overseas recipient, we will take such steps as are reasonable in the circumstances to ensure the overseas recipient does not breach the APPs in relation to that information. Where an exception applies, we may disclose personal information to an overseas recipient in accordance with the terms of the relevant exception.
Access to and keeping personal information up-to-date
We will take such steps as are reasonable to ensure that personal information we collect is accurate, up to date and complete and that personal information we use or disclose is accurate, up to date, complete and relevant. To assist us with this, you should contact us if any of your personal information changes or if you believe that the personal information we have is not accurate, up to date, complete or relevant, including your client’s personal information. We may also contact you from time-to-time to check the information is still correct.
You can gain access to the personal information we hold by contacting us or with respect to some personal information, by logging on using your user identification and password. You may update your personal information or your client’s personal information at any time by contacting us at firstname.lastname@example.org.
If we are satisfied that personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading (“faulty information”) or you request us to correct the information, we will, within a reasonable period after we identify the faulty information or the request is made, take such steps as are reasonable to correct the information.
Security of your personal information
Personal information may be stored in hardcopy or electronically. We will take reasonable steps to protect personal information we hold from misuse, interference and loss as well as unauthorised access, modification or disclosure. We use current techniques and processes to protect personal information. Where we no longer need personal information for any purpose for which the information may be used or disclosed we will take reasonable steps to destroy the information or ensure the information is de-identified in accordance with the requirements of the Privacy Act.
When you browse through the pages of our website, read or download information, we may collect or note details about your visit such as:
your server/Internet Protocol address;
your operating system, top level domain name and the type of web browser you use;
the date, time and duration of your visit to the website; and/or
whether you have visited the website previously and what content you viewed.
The information we may collect relates to your server or PC rather than you yourself (except where personal information is provided to Company). The information we may collect may be used within Company to help us improve the website by tailoring it to better suit your needs, and to provide quicker and more effective access to the various components of the website. We may disclose this information to other persons for these purposes or for related purposes, including to information technology companies who assist us in constructing, designing and maintaining the website.
We may also collect your personal details if you request information about Company that we may supply online, or if you request, email or telephone us with a comment or query. We may use your details:
to answer your comment or query;
to monitor our responses to you; and/or
for our internal sales and marketing analysis.
If necessary, we may also contact you to follow up on your request, or to provide you with further information which may be of interest to you.
You can contact us at email@example.com if you:
wish to access, update or correct your personal information or your client’s personal information;
wish to request not to receive direct marketing communications;
require further information about how we handle personal information;
have a complaint or concern in relation to privacy.
We will take any issue or concern relating to your privacy matter or complaint seriously and will take all reasonable steps to address your matter or complaint. If you are not satisfied with our handling of your privacy related matter or complaint, you may make a complaint to the Australian Information Commissioner.