This document outlines Partners Private Pty Ltd’s policy on handling the personal information that we collect about individuals including customers, potential customers, business partners and shareholders.
In this policy ‘we’, ‘us’ or ‘our’ refers to Partners Private Pty Ltd (Partners Private). Partners Private is an Authorised Representative of Partners Wealth Group Advice Pty Ltd, the holder of Australian Financial Services Licence #483842. Partners Private Pty Ltd and Partners Wealth Group Advice Pty Ltd are subsidiaries of Partners Wealth Group Pty Ltd (PWG).
We are committed to respecting your right to privacy and protecting your personal information. We are bound by the National Privacy Principles in the Privacy Act 1988. Our staff and representatives are trained to respect your privacy in accordance with our standards, policies, and procedures.
Collecting your personal information
As a financial service provider, we are subject to certain legislative and regulatory requirements under the Corporations Act and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. These may require us to obtain personal information about you including:
- your name, address, contact details and date of birth,
- information regarding your dependents and family commitments.
- domicile and citizenship status
- your occupation, and employment history
- your financial needs and objectives
- details of your investment preferences and risk tolerance; and
- your assets, liabilities, income, expenses, insurances, tax and financial statements, and social security entitlements.
We may also collect this information if we need to make payments to you.
We will only ask you for information required to provide you with relevant financial products and services.
In certain circumstances, we may need to collect your tax file, Medicare or pension card number. We do not use or disclose this information other than for the purpose it was collected, authorised by law or if you have asked us to disclose this information to a third party.
We collect personal information directly from you or through application forms or other forms that you complete, as well as by recording information you provide us via phone calls and interviews. In some cases, we might collect your personal information from third parties where you have authorised us to do so.
It’s your choice whether to provide your personal information or authorise us to collect information from a third party. However, if you don’t, we might be unable to fulfil your request for a specific product or service or be unable to identify you to protect you against fraud. Where you are seeking financial advice, it may also affect our ability to properly analyse your personal circumstances.
We may need to collect sensitive information from you. Sensitive information includes such things as health information, racial information and genetic information.
We will only collect sensitive information that is reasonably necessary for us to provide the services you have requested from us.
Unsolicited personal information
We do not usually collect unsolicited personal information. Where we receive unsolicited personal information, we'll determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we'll destroy or de-identify that personal information as soon as practicable.
Using and disclosing your personal information
We collect, hold, use and disclose personal information so we can establish, manage and administer the products and services provided by us, and comply with legal and regulatory obligations.
We may also use the information for the purpose of:
- attending to any questions and queries you may have,
- attempting to identify other products and services that may be of interest to you;
- telling you about other service providers with whom we have arrangement , whose supply goods and services may be of interest to you, and
- disclosing your personal information to external associates and service providers who assist us to market our services.
If you do not wish to receive information relating to other products and services, please contact us at any time.
We may disclose your personal information to other entities where required to do so. The entities that we might share your personal information with vary according to the product or service involved, but could include:
- Organisations that assist us in operating a financial planning business such as those that provide administrative, financial, accounting, insurance, audit, research, legal, IT or other business services
- Product issuers or Investment Managers
- Government and regulatory authorities and other organisations, whom we, or our service providers are required or authorised by law to disclose such information to.
- A potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer of all or part of the assets of our business. Disclosure will be made in confidence, and it will be a condition that no personal information will be used or disclosed by them
- Your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker, mortgage broker, or bank, where you have given your consent for us to disclose your personal information (either expressly or impliedly).
- Courts, tribunals and other dispute resolution bodies in the course of a dispute or other financial services institutions in order to detect, investigate or prevent actual or potential fraud in connection with products or services we provide to you.
We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.
Where your personal information is disclosed, we will seek to ensure that the information is held, used, or disclosed consistently with the National Privacy Principles.
Sharing of information with related entities
Direct marketing and how to opt out
Unless you opt-out we may to the extent permitted by law:
- use or disclose your personal information to let you know about products and services that we believe may be of interest to you;
- market our services to you through third party channels (such as social networking sites), or via other companies who assist us to market our products and services;
- conduct these marketing activities via email, telephone, SMS, Instant Messaging, mail, or any other electronic or other means, including targeted advertising through our websites; and
- disclose your personal information to our related companies so they can tell you about their products and services.
You can let us know at any time if you wish to opt-out of receiving direct marketing offers from us or our related companies. We will process your request as soon as practicable.
You may also be able to opt-out by following the instructions in particular direct marketing communications.
Keeping your personal information accurate and up-to-date
We aim to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. We may update your personal information if we believe the personal information we hold is incomplete or out of date and may seek to correct or complete our records by gathering data from other sources such as public records and other organisations.
If you believe your personal information is not accurate, complete or up to date, please contact us.
Protecting your personal information
The security of your personal information is important to us. Whether your personal information is gathered through face-to-face meetings or by interacting with us via telephone, mail, internet or other methods, we take reasonable steps to store your information securely and protect it from misuse, loss, unauthorised access, modification or improper disclosure.
We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats. Some of the measures we have adopted for protecting your personal information include having facilities for the secure storage of personal information, having secure offices, and access controls for our computer systems.
It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off-site in a secure manner for 7 years. After this, the information will be destroyed.
Organisations outside Australia
From time to time, we may have staff located in the Philippines or other countries.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.
As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed. Overseas organisations may be required to disclose the information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
We will not send personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Privacy Act and the Australian Privacy Principles;
- the recipient is subject to an information privacy scheme similar to the Privacy Act; or
- the individual has consented to the disclosure.
Your privacy on the Internet
We take care to ensure that the personal information you give us on our websites is protected. For example, our websites may have electronic security systems in place, including the use of firewalls and data encryption. User identifiers, passwords or other access codes may also be used to control access to your personal information.
Website analytics measurement software may be used to assist in tracking traffic patterns to and from our websites, anonymously surveying users of the sites. The system is used to collect non-personal information such as the number of unique visitors, how long these visitors spend on the website when they do visit, and common entry and exit points into and from the website. We may collect this information to assist us analyse and improve our website.
Links to Other Sites
You may be able to access external websites by clicking on links we have provided. Those other websites may not be subject to our privacy standards, policies, and procedures. External websites should contain their own privacy statements, and we recommend you contact or review those websites directly to ascertain their privacy standards, policies, and procedures.
Your computer's web browser will allow you to configure your computer to refuse to accept cookies. You can also delete cookies from your computer's hard drive at any time. If you choose to delete cookies or disable the cookie acceptance in your browser, you may not be able to access some parts of our websites.
Notifying you of certain data breaches
In the unlikely event of a data breach, we have measures in place to manage and respond to data breaches, which include notifying impacted individuals and data protection authorities globally, where required to do so.
Notifications may be made by a telephone call, email, SMS, physical mail, social media post, or in-person conversation. If we are unable to contact you, (or your nominated intermediary) by any of the above methods we will publish a statement on the front page of our website and place a public notice on our reception desk.
We may use technology such as beacons, tags, scripts and tracking pixels to collect, store and use anonymous data about how you use our website / mobile technology. This includes your server address, the date and time of your visit, the pages and links accessed, the type of browser used and other information about your browsing activities. This data is used to increase functionality and can also enable us to display information and content that is tailored to our understanding of your interests. This information alone cannot be used to discover your identity.
Gaining access to your personal information
You can gain access to your personal information by providing your request for access in writing (for security reasons). This is subject to some exceptions allowed by law. Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.
We will do our best to respond to your request within 30 days if it is reasonable and practicable to do so, but in some circumstances, it may take longer (for example, if we need to contact other entities to properly investigate your request).
We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing access, such as staff costs of locating and collating information or copying costs. If charges are applicable in providing access to you, we will give you an estimate of these charges up front and confirm that you wish for us to proceed, prior to providing you with the information.
Resolving your privacy concerns
This policy is effective as of 1 September 2021 and applies to the operations of Partners Private Pty Ltd. We will update this policy when our information handling practices change, and any amendments will apply to the information we hold at the time of the update. When we update this policy, we will post the updated policy on our website. We encourage you to check our website from time to time to view our current policy.
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