Privacy Policy
Introduction
This is the Privacy Policy for Affluence Funds Management Limited ABN 68 604 406 297 (Affluence, we, us or our), an Australian financial services licensee (no. 475940). It applies to us in our capacity as trustee for managed investment schemes operated by us as well as in our personal capacity.
Affluence – is committed to its customers, we seek to both respect and protect the privacy of those with whom we deal. The way we manage your personal information is governed by the Privacy Act 1988 (Act) and the Australian Privacy Principles (APPs) established under the Act as amended from time to time.
Our Privacy Policy tells you how we manage personal information we may collect about you. This Privacy Policy is to be read subject to any overriding provisions of law or contract. In this Privacy Policy:
- Affluence, we, us and our refers to Affluence Funds Management Limited and our related entities;
- You or your refers to you as a current or prospective Affluence customer, individual user of our website or any of our services; and
- the singular includes the plural and vice versa.
If you apply for or accept any of our products or services or otherwise provide us with your personal information, then you agree to your information being collected, held, used and disclosed as set out in this Privacy Policy.
What is personal information?
For the purposes of this Privacy Policy, “personal information” is any information or opinion, in any form and whether true or not, which identifies an individual or from which an individual’s identity is apparent or can be reasonably ascertained.
Collecting personal information
What kind of personal information do we collect?
The information we collect will depend on the nature of your dealings with us. The types of personal information we may collect include:
- your contact and identification details such as your full name, residential address, date of birth, telephone number, email address, and other identity information from any documents you offer as proof of your identity (for example, driver’s licence details or passport);
- copies of any relevant trust deeds, partnership agreements or constitutions;
- transactional information you provide when dealing with us (for example, your tax file number (as authorised under the Act) and bank account details) for the purpose of administering your investment accounts and tax reporting and withholding;
- personal information you provide when you commence a customer relationship with us;
- your investment contribution details and investment choice;
- any correspondence between you and us; and
- any personal information you provide when you make an enquiry, request information or otherwise correspond with us.
Reasons for collecting your personal information
Affluence collects your personal information to enable us to provide you with appropriate products and services. In particular, Affluence may collect personal information in order to:
- determine your requirements and so provide you with appropriate information about our products and services;
- process any communication you send us (which includes answering any queries and dealing with any complaints or feedback you have);
- conduct internal research to improve the way we interact and communicate with you;
- meet any legal obligations we have to identify our customers before dealing with them (for example, under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006);
- get in contact with you should we need to;
- do anything which you authorise or consent to us doing; or
- take any action we are required or authorised by law to take.
If you do not provide us with your personal information, it may not be possible for us to provide you with the products or services you have requested or to take any of the above steps. Where it is lawful and practical to do so, we may allow you to deal with us anonymously.
It may, on occasion also be necessary for us to obtain other details, including information relating to powers of attorney or for probate and estate administration.
How do we collect personal information?
Where possible, we try to collect personal information directly from you when you deal with us including:
- from you filling out application forms, such as an application form completed by you to acquire a financial product or receive other financial services from us
- through your use of our website
- from communications between you and our officers, employees and representatives (including communications conducted in person, over the phone, by email or otherwise), and
- from promotional and marketing activities undertaken by us, in which we request or otherwise receive personal information from you (such as from competitions organised by us).
We may also obtain your personal information from third parties we deal with (for example, your financial adviser, our service providers or any other organisation acting on behalf of Affluence).
We may also collect personal information from third parties you refer to us. If we do so, we will assume that you have made that third party aware of the referral and the purpose(s) of the collection, use and disclosure of the relevant personal information.
How we use and disclose personal information
Use of personal information
We use your personal information to assist us in conducting our business and providing you with investment products and services. This includes to:
- assess your application and establish and administer your investment;
- keep in contact with you (where you have requested us to do so) and provide you with any information you have requested;
- process any communications you send us (including answering any queries and dealing with any complaints or feedback you have);
- inform you of investment opportunities or to provide information about investment products and services which we think might be of interest to you;
- properly identify you;
- maintain any business relationship we have with you;
- help us develop, manage and improve services to our customers;
- do anything you authorise or consent us to do; and
- take any action we are required or authorised by law to take.
Disclosure of personal information
We may disclose your personal information to others if we are required to, such as where we are required to by:
- Australian Government regulators and entities such as the Australian Securities and Investments Commission, the Australian Tax Office, and the Australian Transaction Reports and Analysis Centre;
- the Financial Ombudsman Service (FOS);
- court order (including in Family Law matters); or
- other regulatory or governmental entities outside of Australia.
It may be necessary to release information or provide access to external service providers, such as:
- our business associates, referral partners, agents and other entities for purposes which are related to our purposes for collecting your personal information;
- other organisations with whom we have alliances or arrangements for the purposes of promoting our respective products or services;
- our professional advisers, contractors, or other service providers we engage to carry out, or advise on, our functions and activities (for example, the Affluence Investment Fund registry and organisations who conduct investor surveys on our behalf);
- your nominated financial adviser; and
- with your consent, express or implied, to others.
Direct marketing and disclosure to third parties
We or the above third parties may also use your personal information to provide you with information about our products and services. You may request not to receive marketing material from us at any time by contacting us in one of the ways outlined below. If you tell us you no longer wish to receive marketing or promotional material from us, we will not send you any such material. If you change your mind in the future and wish to receive marketing or promotional material from us, please contact us.
if we are currently providing you with services or products, we will still need to send you essential information about your account, the relevant services or products and other information required by law.
Stopping marketing and promotional material from third parties
As a general rule, if third parties have received your personal information, their handling of your personal information will be governed by their privacy policies. In some cases, it may also be necessary for you to contact the relevant organisations to whom we have provided your personal information to notify them of your decision.
Keeping information secure
We will take reasonable steps to protect your personal information from misuse, unauthorised access, modification or disclosure. We may send your personal information overseas, but only to companies which Affluence owns, partly or wholly, or our service providers. The only overseas country where data is currently held is the United States. When we disclose your information overseas, we are required to take measures to ensure your information is treated in accordance with the standards that apply in Australia except in rare cases (for example, where we are required by law to disclose your information overseas) or unless where we obtain your consent not to take these measures.
We will also take reasonable steps to securely destroy or de-identify personal information when it is no longer required. However, we are required by law to retain certain information (for example certain information about your investments with us) for a set period of time. After that time, we will destroy or delete this information in a secure manner.
We cannot provide any assurance regarding the security of information transmitted to us online, as the internet is inherently insecure. Nor can we guarantee the supply of information to us from you will not be intercepted. Information you transmit to us online is at your own risk.
How you can access, correct and update your information
To effectively provide you with products and services, it is important that the personal information we hold about you is complete, accurate and current. At any time we hold personal information, we may ask you to tell us of any changes to your personal information. Alternatively, if you are aware that the personal information we hold needs to be corrected or updated, please contact us at the contact details. You can also ask what personal information we hold by contacting us at the contact details. In normal circumstances we will seek, wherever possible, to provide you with access to your information. However, under certain circumstances in the APPs, we may not be required to provide you with access to or correct your personal information. If we decide not to provide you with access to or correct your personal information, we will give you reasons for our decision.
Identifiers
An “identifier” is a unique identification number assigned to you by the Commonwealth Government or a Commonwealth Government Agency. Examples of identifiers include your Tax File Number, Medicare Number or Passport Number. We will only use identifiers to identify you when we are required to do so by law or to properly identify you in order to protect your personal property or information.
Our Website
Online systems
We take reasonable steps to maintain the security of personal information you provide to us online. We seek to keep current with available security and encryption technology so as to maintain the effectiveness of our security systems. However, no transmission over the internet can be guaranteed as being totally secure. Accordingly, we cannot warrant or ensure the security of any information you provide to us over the internet and you transmit information at your own risk.
If you visit the Affluence website to browse, read or download information, our system will log these movements. These website logs are not personally identifiable and we do not link them with the individuals who browse the site, except where a website user has previously registered with the site and has logged in with their account details. Registered users (when logged in to the site) will additionally have usage information collected such as time and date of site access, documents downloaded and requests for password resetting that is matched to the account registration details provided by the user.
Cookies
Our website uses cookies to assist in your website navigation by customising site information tailored to your needs. Cookies are packets of information stored on your computer for this sole purpose. If you are concerned about cookies, you can set your browser to reject cookies or to alert you when cookies are being used (although rejection of cookies may affect your use of the website).
Links to other websites
Our website includes hyperlinks which enable access to a number of third party websites. These third party websites are not subject to this Privacy Policy. To determine how they deal with personal information, you should ensure you read their respective privacy policies.
Changes to this Policy
Affluence may amend this Privacy Policy from time to time. If we amend this Privacy Policy, we will make the amended Privacy Policy available on our website. Affluence encourages you to periodically review this Privacy Policy to be informed of how Affluence is handling your personal information.
Contact Details
If you have any questions regarding our Privacy Policy or handling of information, please contact us in one of the ways set out below.
Telephone: 1300 233 583 within Australia or +61 7 3532 4076 if calling from outside Australia
Post: The Privacy Officer, Affluence Funds Management Limited,
GPO Box 112, Brisbane QLD 4001
Fax: +61 7 3054 7082
Email: invest@affluencefunds.com.au
Website: affluencefunds.com.au
Complaints
If you wish to make a complaint about how we have managed your personal information, please contact our Privacy Officer in one of the ways outlined above.
If you are not satisfied with how we handled your complaint, you can lodge a complaint with the Federal Privacy Commissioner at:
Telephone: 1300 363 992 within Australia or +61 2 9284 9749 if calling from outside Australia
TTY: 1800 620 241 (this number for the hearing impaired only, no voice calls)
Post: Director of Complaints, Office of the Federal Privacy Commissioner,
GPO Box 5218, Sydney NSW 2001
Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au