Your privacy is important to us and we are committed to being open
and transparent about how we manage personal information. This
helps build community trust and confidence in our organisation.
Your Personal Information may be collected by us for the purposes
of providing you a service. If you have any concerns on how we
manage your Personal Information, please refer to the Complaints
section of this policy or speak to your Adviser.
The Privacy
Policy (the Policy) is divided into the following sections. You
can move to each section by clicking onto the hyperlinked text
below:
Who we are
In the Policy, references to ‘we’, ‘our’, ‘us’, ‘IAdvice’ and
‘iAdvice Technology’ (as applicable), are references to iAdvice
Technology Pty Ltd (AFSL Number 526700, ABN:
86-631-674-229) and to
its Authorised Representatives.
iAdvice is a financial services company that holds an Australian
Financial Services License (AFSL) providing age pension, life
insurance, wealth management and financial planning advice
solutions in Australia. We are bound by the provisions of the
Privacy Act 1988 and the Australian Privacy
Principles.
Authorised Representatives are those individuals licensed by
iAdvice (and registered with ASIC) as suitably qualified to
provide financial advice to individuals and small businesses.
Some may be employees of small practices, or principals of those
practices.
Definitions
Authorised Representative
means an Authorised Representative defined in the Corporations Act
2001 (Cth).
Adviser, Financial Planner or Financial Adviser
are given the same meaning in the Policy as Authorised
Representative.
Financial Service
means the provision of financial advice and/or dealing in
financial products such as life insurance, superannuation and
retirement income, managed investments and financial planning
services and financial product advice.
Personal Information means information or an opinion about an identified individual,
or an individual who is reasonably identifiable, whether true or
not, and whether recorded in a material form or not.
Sensitive Information
means information or an opinion about an individual's:
- racial or ethnic origin;
-
political opinions or membership of a political association;
- religious or philosophical beliefs or affiliations;
-
membership of a professional or trade association or trade
union;
- sexual orientation or practices;or
- criminal record
that is also Personal Information, or:
- health information about an individual;
- genetic information
-
about an individual that is not otherwise health information;
-
biometric information that is to be used for the purpose of
automated biometric verification or biometric identification;
or
- biometric templates.
The Policy
The Policy applies to iAdvice, our employees, and our Authorised
Representatives and their staff.
The Policy sets out how we manage your Personal Information. We
respect the privacy of any Personal Information we collect about
you and we are committed to ensuring that this is handled in
accordance with the provisions of the
Privacy Act 1988 , the Australian Privacy
Principles and any other applicable privacy related laws.
Where there is specific legislation, this will generally govern
how we use Personal Information despite the provisions of the
Privacy Act 1988 . For example, for certain
Financial Services, we are required to collect your tax file
number and provide that information to the Australian Taxation
Office.
Additionally, individuals located in the
European Union may also have rights under EU based rules known as
the General Data Protection Regulation (GDPR). The GDPR has
harmonised the data privacy laws of each individual EU country,
giving more rights to individuals located in the EU and more
obligations holding their personal information.
The Policy will be reviewed from time to time or whenever there
has been a change to the law or a change in our operations and
practices regarding the maintenance of privacy.
The Policy is specific to the services we provide under our
Australian Financial Services License. It has been written
specifically for clients of iAdvice because of the unique
relationship Advisers have with their clients.
Your Privacy
Collection of Personal Information
Advisers have a legal obligation to provide appropriate advice,
and act in the best interests of their clients. The extent of
information they require from you may vary, however it often
involves information required to establish your personal
circumstances. The information they collect is necessary not only
to provide appropriate advice, but also to complete any
transactions on your behalf with various product issuers, such as
superannuation funds and life insurers. These can be services
provided over the short term, however they are often part of a
long term relationship with an Adviser.
Collecting Personal Information also allows us to meet Australian
and international legal or regulatory obligations that we, or
product providers, might have to identify our customers. These may
include, but are not limited to, our obligation to identify and
verify clients under the
Anti-Money Laundering & Counter Terrorism Financing Act
2006
or provide information to the US government if a client is
considered a US resident for tax purposes under the
US Foreign Account Tax Compliance Act.
Collection of Personal Information from Others
In some instances, your information may also need to be collected
from third parties such as your employer if you are a member of a
corporate superannuation plan, or from your accountant, mortgage
broker or solicitor. It may also be provided to, or received from,
third parties to enable a secondary service, such as when you are
referred to a solicitor for estate planning purposes. If these
third parties approach us and request your Personal Information,
we will ask for your consent before it is provided.
Relatives, Dependants and Other Individuals
To enable us to provide financial planning advice and services,
often we will record information regarding your relevant personal
circumstances, which may include information regarding your family
situation, your partner, dependants, beneficiaries and children.
This information will only be gathered where it is necessary to
provide you services, such as financial planning advice, for
example, where members of your family may become beneficiaries to
your life insurance policy or superannuation fund. You are not
obligated to provide this information, however it may affect the
quality of, or restrict the services provided to you.
Where this information is reasonably required from you, and you
willingly provide it, we expect and assume that you have their
consent to provide this information to us.
In these
circumstances, you need to ensure that they are aware:
- That you have provided their personal information to us
-
That they understand who we are and how they can contact us
-
That they may access the Personal Information that we hold
about them
-
Of the purposes for which you provided their Personal
Information to us
-
That their Personal Information will be handled in accordance
with this Policy, and
-
That they can refer to this Policy for further information.
Use and Disclosure of Personal Information
How do we use your Personal Information?
The Personal Information we hold is used for the primary purpose
of providing you financial planning advice services as well as
reviewing your ongoing needs. We may also use your Personal
Information for related secondary purposes such as: enhancing our
customer service and product options; communicating with you
regarding the products and services you have with us; handling
your complaints; providing you with ongoing educational
information including newsletters; and providing you with
marketing material that we believe may be relevant to your
financial needs and circumstances. Where the secondary purpose is
unrelated to the primary purpose for which you have sought our
services, we will ask for your consent. You may provide your
consent in writing, or via telephone.
Depending on the
product or service concerned, your Personal Information may be
disclosed to:
-
Other areas within the iAdvice Group, who provide financial
and other related services.
-
Advisers, brokers and those who are authorised by us to review
your needs and circumstances from time to time.
-
Service providers and specialist Advisers to us who have been
contracted to provide iAdvice with administrative, financial,
insurance, accounting, legal, information technology, research
or other services.
-
Other insurers, credit providers, courts, tribunals and
regulatory authorities as agreed or authorised by law.
-
Credit reporting or reference agencies or insurance
investigators.
-
AUSTRAC, the government agency who oversees Anti-Money
Laundering and Counter Terrorism Financing. Before we arrange
the provision of products or services for you, we are required
to validate your identity. We will request and copy some
personal documents for that purpose. We are also required to
report details of entities and certain transactions where we
hold reasonable suspicion of reportable suspect matters.
-
Product or service providers who have an obligation to
disclose information to the Australian Tax Office (ATO) where
the ATO has agreements to share information with overseas tax
authorities.
-
External dispute resolution bodies such as the Australian
Financial Complaints Authority who would handle your dispute.
Generally, we require that organisations outside iAdvice who
handle or obtain Personal Information as service providers
acknowledge the confidentiality of this information, undertake to
respect any individual’s right to privacy, and comply with the
privacy laws.
Independent service providers
The Advisers authorised by us may individually engage (or via us)
independent service providers to assist them in providing services
to you. These services may range from contracting staff for
providing back office duties and administering client relationship
management systems, to more complex tasks such as accessing direct
share advice (on your behalf) from specialist share brokerage
firms.
We expect these independent service providers to comply with the
Policy and the privacy laws and regulations applicable to their
jurisdiction.
Sensitive Information is subject to greater restrictions
Some Personal Information we hold is classed as Sensitive
Information. Sensitive Information may have further restrictions
on its disclosure.
Sensitive Information is usually
required for personal insurance applications, to manage claims on
those products and may also be relevant to credit and other
applications. Sensitive Information will only be used and
disclosed for the purposes for which it was provided, unless you
specifically agree otherwise, or the use or disclosure of this
information is allowed by law.
We will only collect
Sensitive Information from you where it is reasonably necessary
for us to require this information in order to provide the service
to you. It will only be collected with your consent, or in limited
other circumstances specified under privacy laws.
Unless we have your consent, we cannot use or disclose Sensitive
Information about you for any purpose other than the primary
purpose of the collection or a directly related secondary purpose
(unless we are permitted to disclose this information under the
law); nor can it be shared by related bodies corporate in the same
way that they may share other Personal Information. Documents
asking for Sensitive Information will explain this.
Marketing Material
From time to time, iAdvice (and its related entities) may promote
opportunities or products that we believe may be relevant to your
financial needs and circumstances. You can inform us if you do not
wish to receive marketing material from us.
The ability to ‘opt-out’ does not include important disclosure
documents and letters your Adviser may send to you that include
portfolio updates on your current investments, an offer of review,
or other communications required to be provided as part of an
Adviser’s general obligations. Please allow up to 60 days for us
to fully implement your “opt-out” request.
Access and Correction
Can I access my Personal Information?
You have the right to access any Personal Information that we hold
about you. You can ask us for access to Personal Information that
we hold about you at any time. To do so, please call iAdvice on 03
8658 8875 or email the Privacy Officer at
theo@iadvicetechnology.com.au
We will respond to your request within 30 days (unless unusual
circumstances apply). We may charge a fee to cover the cost of
verifying the application and locating, retrieving, reviewing and
copying any material requested. We will always check this with you
first. If the information sought is extensive, we will advise you
of the likely cost in advance and can help to refine your request
if required.
We will provide you with access to Personal Information held about
you except to the extent that we are permitted to refuse access in
accordance with the Privacy Act 1988 and the Australian
Privacy Principles. If we refuse to provide you with access to
some information, we will provide you with our reasons in writing
for doing so. If you have concerns, you may lodge a complaint.
Correction of Personal Information We will correct any Personal
Information that we hold about you if we become aware that it is
inaccurate, incomplete, out of date, irrelevant or misleading.
If you believe that the Personal Information we hold about you is
inaccurate, incomplete, out of date, irrelevant or misleading, you
can ask us to correct it and we will take reasonable steps to do
so. If there are any instances where we cannot do this, we will
let you know in writing.
If we disagree that the information is inaccurate, incomplete or
out of date, we will take reasonable steps to include a note on
your record that you believe that such information is inaccurate,
incomplete or out of date.
Enquiries and Complaints
If you consider that any action by us breaches the Policy, the
Australian Privacy Principles or otherwise fails to respect your
privacy, you can make a complaint.
Upon the lodgement
of a complaint with us, you will receive an acknowledgement letter
and an indication of the timeframe in which we will respond to
your complaint. We will try to resolve your complaint within 30
days. When this is not possible, we will inform you of the reasons
for the delay and how long we believe it will take.
To make a complaint, please forward it in writing to:
Complaints Manager
iAdvice
Level 31
120 Collins St
Melbourne Victoria 3000
Email:
theo@iadvicetechnology.com.au
Phone:
03 8658 8875
If you are not satisfied with our response to your
complaint, you can escalate the matter to the Office of the
Australian Information Commissioner (OAIC) to complain about the
way we have handled your personal information.
The
OAIC can be contacted at: Office of the Australian Information
Commissioner
GPO Box 5218, Sydney NSW 2001
Email:
enquiries@oaic.gov.au
Phone:
1300 363 992