This policy applies to information collected by Flinders Investment Partners Pty Ltd (“Flinders” or “we” or “us”). It outlines how we collect and use personal information that we hold about you in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and the subsequent 2012 and 2016 amendments (Mandatory Data Breach Notification), Privacy Regulations 2013 and the General Data Protection Regulation (GDPR).
This policy has been developed in accordance with the Australian Privacy Principles (APP).
What personal information is collected?
We only collect personal information that is reasonably necessary for us to provide our products and/or services. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested. We may collect information such as your name, address, phone number, email address, tax ﬁle number, bank account details, other information that may be required for identiﬁcation purposes, information about your investments and transactions and other information related to the services we provide.
Sensitive information is not collected from you because it is not reasonable for us in providing our services to you. Sensitive information includes health information, racial information, genetic information, and information about religious beliefs.
Why we collect personal information
We collect personal information about you which is reasonably necessary to:
- Provide you with our products and services;
- Conduct marketing and social functions;
- Maintain your contact details; and
- Fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter terrorism financing.
How personal information is collected?
By using Flinders services you consent to Flinders collecting your information from you or from a person who is acting as your agent. We may collect information directly from you or your agent, such as when you or your agents provide information by phone, email or in an application form.
Use and disclosure of your personal information
Flinders may use your personal information for the primary purpose of providing ﬁnancial services to you, as well as for related purposes such as:
- to verify your identity or transactions which you may enter into with us;
- to administer and manage the provision of our products and services;
- to comply with laws and regulatory requirements including complying with any request made by a government authority or regulator, including in connection with legal proceedings or the prevention or detection of fraud and crime;
- to comply with risk management policies and procedures;
- those involved in providing, managing, or administering the products or services you have requested;
- conducting due diligence; or
- another purpose related to the primary purpose.
For the purposes we have described, we may disclose your personal information:
- to our suppliers (including service and content providers), contract and service providers, professional advisers, dealers and agents;
- to government agencies or individuals responsible for the investigation and resolution of disputes or complaints covering your use of our services and facilities including for example ASIC, AUSTRAC, ATO or the OAIC;
- other parties involved in the administration of your investments including securities exchanges, product issuers, share and investment registries or mailing houses;
- anyone to whom our assets or business (or any part of it) is transferred (or offered to be transferred, subject to conﬁdentiality provisions); and
- where you have otherwise consented or as otherwise required or authorised by law.
Do we disclose personal information for marketing?
We may use your personal information to offer products and services that we believe may interest you. We may also disclose your personal information to external service providers who assist us to market our products or services.
We are permitted to use personal information for marketing if the client would reasonably expect us to do so and when the client has been provided with a simple means of opting out of the marketing service.
If you do not wish to receive marketing offers from us please inform us by sending an email to firstname.lastname@example.org.
Government related identifiers
Although in certain circumstances we are required to collect government identiﬁers such as your tax ﬁle number, Medicare number or pension card number, we do not use or disclose this information other than when authorised by law or unless you have voluntarily consented to disclose this information to a third party.
Access and correction and updating personal information
Generally, we will provide you with access to your personal information that we hold within a reasonable time of a request unless an exception applies under the Privacy Act. Where we provide you with access to such information, we may charge you a reasonable fee to cover our costs.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, up to date, complete and relevant. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate or incomplete, you should contact us to correct the information.
If we disagree about the correction you have supplied, and refuse to correct the personal information, or if we believe that we are unable to comply with your request, we will give you a written notice to that effect. You have the right to make a complaint if you disagree with our decisions in relation to these matters.
Your Rights under the GDPR
If you are an individual residing in the European Union (EU), you have certain rights as to how your personal information is obtained and used. Flinders complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
Except as otherwise provided in the GDPR, you have the following rights:
- To be informed how your personal information is being used;
- Access to your personal information (we will provide with a free copy of it);
- To correct your personal information if it is inaccurate or incomplete;
- To delete your personal information (also known as ‘the right to be forgotten’);
- To restrict processing of your personal information;
- To retain and reuse your personal information for your own purposes;
- To object to your personal information being used; and
- To object against automated decision making and profiling.
We may ask you to verify your identity before we act on any of your requests.
Storage and security of information
Flinders Investment Partners Pty Ltd stores personal information in a combination of computer storage facilities, paper-based ﬁles and other records. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modiﬁcation or disclosure.
Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Australian Privacy Act and GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
We may also keep records of our interactions with you (including by telephone, e-mail and online) and of your transaction history.
Overseas disclosure of personal information
We do not currently disclose your personal information to overseas recipients. However, some third party providers that we may engage with from time to time may have overseas locations. In the event that we do disclose your personal information overseas, Flinders will make reasonable steps to ensure that the foreign recipient will not breach the APPs and to ensure that they are subject to similar privacy laws that will afford protection in the same manner as the APPs.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Contacting us and complaints
If you wish to contact us for any purpose regarding this policy including making a complaint about the way we have handled your personal information (including if you think we have breached the Privacy Act) you may do so to our client service team in writing, by mail to the address set out at the end of this policy. When you contact us, include your email address, name, address and telephone number and clearly describe your complaint. Any complaints will investigated and you will receive a response promptly. If you consider that we have failed to resolve the complaint satisfactorily, and you are an individual located in Australia, you can complain to the Office of the Australian Information Commissioner.
Flinders Investment Partners Pty Ltd
|140 William Street
|Melbourne VIC 3000