When we collect personal information directly from you, we take reasonable steps at, or before the time of collection to ensure that the individual is aware of certain key matters, such as:

• the details of the entity collecting the personal information or on whose behalf we are collecting the personal information;

• the purposes for which we are collecting the information (including for example where required by law);

• the organisations (or types of organisations) to which we would normally disclose information of that kind;

• the main consequences if all or some of the personal information is not collected;

• the fact that you are able to access the information and how to contact us to either access or correct their personal information; 

• the fact that your may complain about the handling of their personal information if they believe it is has not been done in accordance with the Privacy Act, and how the we - or an entity on whose behalf we collect the information - will deal with the complaint.

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We will not collect any personal or sensitive information about you except where you have knowingly provided that information to us or we believe you have authorised a third party to provide that information to us.

We will collect personal information directly from an individual where it is reasonable and practicable to do so. Where we collect information from a third party such as financial advisers, fund manager, or another Australian Financial Services Licensee, we will still take reasonable steps to ensure that an individual is made aware of same key matters as set out above.

You are not required to give us the information that we request, however if you choose not to provide the information we ask for, or the information you give us is not complete or accurate, this may for example, prevent or delay the processing of your application or any other request or it may prevent us from contacting you. It may also (in certain circumstances) impact on the taxation treatment of any financial products you acquire that are issued by an entity on whose behalf we collect your information.

We - or an entity on whose behalf we collect your information - will take reasonable steps to ensure that the personal information that we collect, use and disclose is accurate, complete and up to date, by reviewing personal information provided as part of any application process against certified documentation to make sure it meets requirements before processing. We and our clients advise you to keep your information up to date and provide mechanisms for you to do so.

We take reasonable steps to protect the personal information and sensitive information that we hold from misuse and loss and from unauthorised access, modification or disclosure by using security procedures and the latest technology. Account information is hosted on our Platform and is password and security token protected (multi-factor authentication) and instructions are verified before they are processed.

Your personal information is stored on secured third party servers in Australia and can only be accessed in accordance with our Data Security Policy. Data on servers are backed up to separate secured servers. We have implemented a range of physical and electronic security measures to protect your personal information from misuse, unauthorised access and improper disclosure. We also monitor and maintain our security system to ensure that our online services are secure and your personal information is protected appropriately. All personal information is encrypted in transit and at rest.

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We may disclose personal information to the following:

• internally to our staff and related bodies corporate - but only to the extent that this is necessary to provide you with services or products for which you have applied to acquire;

• professional advisers nominated by you to receive that personal information;

• promoters of financial products issued by our clients for which you have applied to acquire;

• any financial institution which holds an account for you;

• any organisations or professional advisers involved in providing, managing or administering our products or services such as auditors, accountants, lawyers, custodians, external dispute resolution services, insurers, investment managers or mail houses, within normal business practices;

• your personal representative, or any other person who may be entitled to receive your estate on death, or any person contacted to assist us to process the transmission of your estate;

• support services; and

• where otherwise required or authorised by law

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We will also disclose your personal information if you give us your written or explicit consent - which may include electronic means of instruction from you through a secure medium on which you have been previously enrolled.

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If other organisations provide support services to us, they are required to appropriately safeguard the privacy of the personal information provided to them.
 

Where personal information collected is no longer needed for any purpose that is permitted by the Privacy Act, we will delete, securely destroy or permanently de-identify the personal information.
 

Use of government identifiers
We do not use government identifiers (Identifiers) issued by the Commonwealth of Australia (or any other government) as our own identifier of individuals. We will only use or disclose Identifiers in the circumstances permitted by the Privacy Act.