Asset Builder Financial Services Pty Ltd ACN 006 388 629 (“Asset Builder”) respects your privacy and is committed to complying with the Privacy Act (Cth) 1988 (the Act) and its Australian Privacy Principles (APPs).
Collection of Personal Information
The APPs apply to personal information (including sensitive information) as defined by the Act. Personal information is any information about you that identifies you or by which your identity can be reasonably determined. For example, your name or address. Sensitive information is a subcategory of personal information and includes, for example, health information, racial or ethnic origin, memberships and affiliations.
As a financial planning organisation, we are governed by various laws and regulatory requirements as well as business requirements which means that we must collect certain personal information about you, especially if you are or become a client. Such personal information would include, for example, your contact and identity details (and may include copies of passport, licence or birth certificate), occupation/employment details, financial/bank details, and tax file number.
We will only collect personal information about you that you have knowingly disclosed (where your consent is express or implied) or authorised a third party to disclose to us (for example, your accountant, lawyer, insurer or product issuer) or as required by law . Your consent may be accepted by us in writing, verbally or by your conduct.
We will always explain to you, as our client, why we need to collect your information and confirm that we have received the information if obtained from an authorised third party. If you fail to provide us with the necessary information, we may not be able to provide you with advice or services or continue to act for you.
We may collect your personal information a number of ways, such as when you contact us by telephone, email, post, face to face meetings or via access to our website.
We will only collect personal information necessary to provide you with the appropriate advice and services or in order to comply with the law.
You may have the option of not identifying yourself or using a pseudonym under the APPs. However, given the nature of our business and our legal obligations, this is generally impracticable. We can only offer limited anonymity or the use of a pseudonym to persons who are not clients.
If we receive personal information about you that is not solicited, we will determine whether the information is necessary to maintain for the purpose of providing you with advice and services or in order to comply with the law. If the information is not necessary, it will be either destroyed or deidentified. If the information is necessary to maintain, we will seek your consent, failing which the information will be destroyed.
Use and disclosure of Personal Information
Asset Builder will only use your personal information for the purpose for which it was collected or as allowed/required by law. For example, to provide financial advice, set up and manage ETFs/investments/ funds, ongoing review of your changing circumstances and needs, reports on the performance of your account, set up insurance cover.
We will only use and disclose your personal information for the primary purpose for which it was collected. We may also use or disclose for a secondary purpose if (a) you consent (b) you would reasonably expect us to use or disclose the information and the secondary purpose is related to the primary purpose or (c) as required or allowed by law. For example, we may disclose your information to third parties, such as superannuation fund trustees, your accountant, insurance providers and product issuers for the purpose of implementing our financial advice and providing services.
From time to time we may use your personal information to provide you with investment or product information, news updates or market developments. This information is likely to come via email or post. If you do not want to receive any such information, you may decline at any time by notifying us via phone, email or post letter using the contact details on our website.
Cross border (overseas) disclosure
As a matter of general practice, Asset Builder is not involved in the disclosure or sharing of information with any overseas entities. Asset Builder would only knowingly transfer your personal information to foreign countries with your consent or as required/allowed by law. For example, if you had previously lived and worked in a foreign country and requested Asset Builder to liaise on your behalf with an overseas third party.
Commonwealth Government identifiers
Commonwealth government identifiers are numbers assigned by the Commonwealth government or agency to uniquely identify you for its purposes, for example, your Tax File Number, Social Security Number or Medicare Number. Asset Builder will not adopt this information as its own identifier but may use or disclose it when authorised to act on your behalf in dealing with a government department/agency or as may be required/allowed by law.
Quality of personal information
Asset Builder takes all reasonable steps to ensure the personal information it collects is accurate, up to date and complete. Asset Builder also ensures that the personal information it uses or discloses is accurate, up to date, complete and relevant having regard to the purpose of the use or disclosure. We rely on you to notify us of any relevant updates or changes to your personal circumstances/information as and when they occur and will amend the information in our records accordingly. We will also request certain personal information from you from time to time. It is important that you cooperate in a complete and timely manner with all our requests for personal information or we cannot properly commit to our privacy obligations and may not be able to continue to provide you with services.
How we hold your personal information and its security
Your personal information is held securely and treated with utmost confidentiality. We hold your information in a number of ways including in a paper client file that is stored securely and in electronic records held on our computer data base/systems. The information we hold about you is protected by physical, electronic and procedural safeguards. For example, we have security measures for our software such as firewalls for our internet and user names and passwords to control access to our computer system.
We generally retain the paper client file for a minimum of 7 years after you cease to be a client or however longer as may be required by law after which time we will permanently destroy the paper client file. We retain all other records containing your personal information for varying lengths of time according to the circumstances. When personal information is no longer required by law and is no longer required for the purpose for which it was collected by us, we will take reasonable steps to destroy or delete it permanently in a secure and confidential manner.
Asset Builder takes reasonable steps to protect all personal information it holds about you from misuse, interference, loss, unauthorised access/modification or disclosure which include security systems, practices and procedures. If you suspect any misuse or unauthorised access etc, please contact us immediately.
Asset Builder’s website offers a dedicated Client Login link that allows you ready and secure access to only your personal information that links to a software platform. Your access to this information will require a verification of your identity via a client login password/code exclusive to you. You will be fully responsible for maintaining the secrecy and security of your password/code and must not share or allow disclosure to anyone else.
You should immediately contact Asset Builder in the event you become aware of any unauthorised disclosure or use of your Client Login password/code.
Access to and correction of personal information
As stated above, you may have ready direct electronic access to certain of your personal information via the Login link on the Asset Builder website. You may also contact us to request access to any personal information we hold about you.
Your request for personal information will be actioned as soon as practicable and will normally be acknowledged immediately on receipt. Depending on the nature of your request, we may provide the information immediately or within 24 hours and, in any event, normally within 7 -10 business days of receipt of the request subject to any delays or circumstances which are beyond our control, for example, delays in receipt of information from third parties.
Depending on the nature of your request, we may charge a fee to cover postal, courier or like costs incurred by us. You would be notified prior of any fee incurred.
We may refuse your requests for personal information in accordance with the Act and would give you the reason/s in that event.
You may request us to correct or amend any personal information about you that we hold if you believe it is inaccurate, incomplete, out of date, irrelevant or misleading. If appropriate, we will correct the information on the same day as receipt of the request. Otherwise we will generally provide an initial response to you within 7 business days and commence a review. We will then notify you as to the outcome of the request as soon as practicable and, in any event, within 30 days subject to exceptional circumstances. If we have not made the correction requested as an outcome, we will notify you of the reason/s.
Requests for access to personal information or requests for correction/amendment of personal information may be made by direct contact (via phone 9673 1300 or in person) to our office OR sent in writing to the Privacy Officer at :
- Postal address – Asset Builder Financial Services , Unit 1/ 345 Plummer Street, Port Melbourne, Vic. 3207; or
- Email address – email@example.com
You can obtain further information about how we handle your personal information by contacting us.
For any complaint about a possible breach of your privacy under the APPs, please contact our Privacy Officer on phone 9673 1300 or email firstname.lastname@example.org or by letter to our postal address above. We will acknowledge your complaint within 7 days and provide a decision within 30 days of receipt. If you are not satisfied with the outcome of your complaint to us, you may lodge a complaint with the Australian Information Commissioner whose office can be contacted on phone 1300 363 992 or see website www.oaic.gov.au.
This policy may be revised from time to time without notice in order to meet changes to the law or circumstances. You may request a paper copy of this policy by contacting our office.
Issued: 1 January 2018