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1. Purpose of this Policy
The purpose of this policy is to outline LIFE Financial Planners’ policy in relation to the collection, storage, use, disclosure and other management of personal information.
3.1 Rights to Privacy
LIFE Financial Planners, understands the importance of protecting individuals’ rights to privacy. We have prepared this statement to help you understand how we manage personal information and how we aim to protect the privacy of your personal information. In handling personal information, LIFE Financial Planners is subject to the Privacy Act and complies with the Australian Privacy Principles in the Privacy Act. This policy describes the way LIFE Financial Planners collects, uses, discloses and otherwise manages your personal information and your rights in relation to our management of your personal information. This policy may be updated from time to time.
3.2 What kinds of Personal Information does LIFE Financial Planners collect?
For the purposes of the Privacy Act, personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
Generally, LIFE Financial Planners will collect personal information, such as your name and contact details including home address and e-mail address and any other information, necessary to provide our funds management and other services to you or to provide you with information about LIFE Financial Planners and/or our products and services.
The specific kinds of personal information we collect will depend on our dealings with you. For example, where you invest in a fund or other product of LIFE Financial Planners, we may collect information such as your name, residential and business address, date of birth, contact details (such as email and phone numbers), income details, asset and liabilities information, tax details (whether in Australia or overseas) and financial statements, employment details and details regarding your financial or accounting advisors, as well as information regarding your investment in the fund or product and other dealings with LIFE Financial Planners.
Where you attend seminars, briefings or other events conducted by LIFE Financial Planners or sign up for newsletters or other similar information services of LIFE Financial Planners, we may collect information such as your name, contact details (such as email and phone numbers) and details regarding any funds, products or services you have expressed an interest in.
LIFE Financial Planners will not generally collect or hold sensitive information about you, unless LIFE Financial Planners is required to do so by law. Sensitive information includes information about your race, political or religious beliefs, sexual preferences, criminal convictions, membership of professional or trade associations or unions or health information.
3.3 Collection of Personal Information
LIFE Financial Planners collects personal information in a range of circumstances including where you apply to invest in a fund or other product of LIFE Financial Planners, request information regarding LIFE Financial Planners or its products or services, attend seminars or other events conducted by LIFE Financial Planners, sign up for newsletters or other similar information services of LIFE Financial Planners or otherwise engage with LIFE Financial Planners. Where you are an investor in a fund or other product of LIFE Financial Planners, LIFE Financial Planners will collect personal information from you to process and establish that investment and also in the course of administering that investment.
Generally, LIFE Financial Planners collects your personal information directly from you, for example by requesting that you complete an application form.
There may be occasions when LIFE Financial Planners will collect your personal information from a third party. For example LIFE Financial Planners may collect your personal information from a publicly maintained record, a third party broker, a person authorised by you (such as your accountant or financial advisor) or our agents or service providers (such as registry service providers).
In the event that LIFE Financial Planners collects your personal information from a third party, we will take reasonable steps to inform you of certain matters, such as LIFE Financial Planners’ identity and contact details.
3.4 Why does LIFE Financial Planners need Personal Information?
LIFE Financial Planners collects, holds, uses and discloses personal information for the purposes of operating its funds management business and providing its funds management and related services, including to:
- provide you with information regarding the funds and other products or services of LIFE Financial Planners;
- process your application for investments in the funds or other products or services of LIFE Financial Planners;
- establish your investment in a fund or other product or service of LIFE Financial Planners; and
- administer your investment in a fund or other product or service of LIFE Financial Planners.
Where you invest in a listed fund or other listed product of LIFE Financial Planners, LIFE Financial Planners will collect, hold, use and disclose your personal information to comply with its legal obligations under the listing rules or other relevant laws applying to that listed fund or other listed product.
LIFE Financial Planners may also collect, hold, use and disclose personal information to undertake identification and verification processes in accordance with the Anti-Money Laundering and Counter Terrorism Financing Act or any other relevant laws.
For certain investors, LIFE Financial Planners may also be required to collect and disclose certain personal information to the Australian Taxation Office in order to comply with the Foreign Account Tax Compliance Act (FATCA) or Common Reporting Standard (CRS).
A failure to provide your personal information may affect LIFE Financial Planners’ ability to provide our range of products and services to you and may result in LIFE Financial Planners not being able to process your application for investment in our funds or other products or otherwise provide services to you.
3.5 Direct Marketing
In addition to the purposes set out above, LIFE Financial Planners may collect, use and disclose your personal information to inform you of products, services or offers of LIFE Financial Planners which may be of interest to you. Where you are an investor in a fund or other product of LIFE Financial Planners, this may include providing you with direct marketing information regarding the other funds or products of LIFE Financial Planners.
LIFE Financial Planners may contact and communicate with you for the purpose of direct marketing via the telephone, post, facsimile, email or SMS.
If you do not want to receive this information or do not want LIFE Financial Planners to use or disclose your personal information for direct marketing purposes, you can opt out by contacting our Privacy Officer or by letting us know that you wish to opt out of receiving this information and/or LIFE Financial Planners using or disclosing your personal information for direct marketing purposes.
3.6 Spam Act
Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.
‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone.
Life Financial Planners complies with the provisions of the Spam Act when sending commercial electronic messages.
Equally importantly, Life Financial Planners makes sure that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details.
3.7 Cookies and other web technologies we use
Some personal information may be collected automatically, without your knowledge, whilst navigating through and interacting with the content of our website. The electronic methods of collection we use may include cookies, log files and web beacons.
You can choose if and how a cookie will be accepted by changing your browser settings; but please be aware that this may affect your access to some parts of our websites.
Web beacons are small pixel files that help us better manage content on our websites by allowing us to understand usage patterns, fix issues, and improve the products and services offered to you on our websites. Log files contain information about the devices and browsers used to access our websites and help us to diagnose problems, analyse trends, administer the site or mobile application.
The information we collect by these electronic means is generally not stored for long – they are temporary records – and can include device-specific data or log data such as your IP address, device screen size, device type, browser information, referring domain, pages visited, the date and time website pages were visited, and geographic location (country only).
3.8 Sharing Information with other Organisations
LIFE Financial Planners may disclose your personal information to third parties for the purposes detailed in paragraphs 3.4 and 3.5 on the previous page.
The types of organisations to which LIFE Financial Planners may disclose the personal information LIFE Financial Planners holds about you include:
- your adviser and dealer group;
- any third party service provider LIFE Financial Planners may engage to provide custody, administration, technology, auditing, mailing, printing or other services;
- Government authorities when and to the extent required by law; and
- LIFE Financial Planners’ professional advisers (including legal and accounting firms, auditors, consultants and other advisers). Such disclosure will only be done on a confidential basis.
3.9 Security of your Personal Information
LIFE Financial Planners may hold personal information in both hard copy and electronic forms.
LIFE Financial Planners will take all reasonable steps to ensure that the personal information it holds is protected against misuse, loss, unauthorised access, modification or disclosure. Personal information is held on secured servers or in storage located in controlled, access restricted environments. LIFE Financial Planners’ employees (including senior management) are aware of their obligations and the importance of good information handling and security obligations. They are required to maintain the confidentiality of any personal information held by LIFE Financial Planners.
Personal information may also, in certain circumstances, be held on behalf of LIFE Financial Planners in hard copy or electronic forms by LIFE Financial Planners’ service providers (such as offsite document storage providers or electronic data storage providers). LIFE Financial Planners enters into agreements with such service providers which impose confidentiality and privacy obligations on the service provider.
3.10 LIFE Financial Planners will also take reasonable steps to destroy or permanently de-identify Personal Information if no longer needed for purposes stated under section 3.4 above. Data Breach Notification
From 22 February 2018, in accordance with the Privacy Act, LIFE Financial Planners will report certain data breaches (known as Notifiable Data Breaches) to both individuals affected by the breach and the Office of the Australian Information Commissioner (OAIC). A data breach is when personal information held by an entity is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference. Some data breaches are notifiable under the Privacy Act.
A notifiable data breach may occur where personal information held by an agency or organisation is lost or subjected to unauthorised access or unauthorised disclosure.
To be a notifiable data breach, the data breach must, depending on the circumstances, be one that may or is likely to result in serious harm to an individual whose personal information was part of the data breach. Whether the harm is serious harm to an individual depends upon a variety of circumstances but may include serious physical, psychological, emotional, economic, financial and reputational harm.
LIFE Financial Planners has procedures in place to ensure that any identified or suspected data breaches are dealt with promptly, appropriately and escalated accordingly.
3.11 Can you access the personal information LIFE Financial Planners holds about you?
LIFE Financial Planners will take steps reasonable in the circumstances to ensure that the personal information LIFE Financial Planners collects, holds, uses and discloses is accurate, complete, up-to-date, relevant and not misleading.
You have the right to request access to the personal information LIFE Financial Planners collects and holds about you. You also have the right to request correction of the personal information LIFE Financial Planners collects and holds about you,
If at any time you would like to request access to or correction of the personal information about you LIFE Financial Planners collects and holds you can contact our Privacy Officer using any of the below contact details:
LIFE Financial Planners
Suite 12, 643 Murray Street
WEST PERTH WA 6005
Phone: 08 9322 1882
Fax: 08 9322 1883
LIFE Financial Planners will seek to respond to requests for access to or correction of personal information within 30 days of the date of the request.
If LIFE Financial Planners refuses any request for access to or correction of personal information held by LIFE Financial Planners, written reasons for that refusal will be provided by Marijana Ravlich.
LIFE Financial Planners has appointed a Privacy Officer to assist you with any enquiries, complaints or feedback you may have. Please contact our Privacy Officer:
LIFE Financial Planners
Suite 12, 643 Murray Street
WEST PERTH WA 6005
Phone: 08 9322 1882
Fax: 08 9322 1883
4.1 Privacy Complaints
Please direct all privacy complaints to our Privacy Officer in the first instance. Privacy complaints will normally need to be made in writing.
A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information. This could include matters such as:
- if you believe LIFE Financial Planners has breached the APP’s, a binding registered APP code or any other relevant obligations under the Privacy Act with respect to your personal information;
- how your personal information is collected;
- how your personal information is stored;
- how your personal information is used or disclosed; or
- how access to your personal information is provided. At all times, privacy complaints will:
- be treated seriously;
- be dealt with promptly;
- be dealt with in a confidential manner; and
- not affect your existing obligations to the commercial arrangements that exist between LIFE Financial Planners and you.
The Privacy Officer will commence an investigation into your complaint and will respond to the complaint within a reasonable period of time. You will be informed of the outcome of your complaint following the completion of the investigation. In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.
5 Questions & Concerns
If any individual including LIFE Financial Planners Staff has questions or concerns from time to time about the subject matter or requirements of this policy, that person should contact the LIFE Financial Planners Privacy Officer in the first instance. using the contact details set out in paragraph 4 of this policy.
6 Review of Policy
This policy will be reviewed at least annually (or more regularly if there are changes to the legal or regulatory framework which applies to this policy) to ensure it is renewed and updated appropriately. LIFE Financial Planners will notify any changes by posting an updated version of the policy on LIFE Financial Planners website at www.lifefinancialplanners.com
7 Legal & Regulatory Framework
LIFE Financial Planners’ collection, storage, use, disclosure and other management of personal information is subject to relevant legislation, including the Privacy Act.
Amongst other things, the Privacy Act sets out 13 Australian Privacy Principles, which are binding principles that LIFE Financial Planners is required to comply with in relation to LIFE Financial Planners’ collection, storage, use, disclosure and other management of personal information
The Office of the Australian Information Commissioner is the statutory agency responsible for a number of functions in relation to the Privacy Act, including conducting investigations handling complaints and reviewing notifiable data breaches in relation to the Privacy Act and the Australian Privacy Principles.
In this policy, unless the context otherwise requires:
LIFE Financial Planners Entity means LIFE Financial Planners Pty Ltd.
APP means the Australian Privacy Principles as set out in the Privacy Act 1988 (Cth).
Corporations Act means the Corporations Act 2001 (Cth).
Privacy Act means the Privacy Act 1988 (Cth).
Privacy Officer means the LIFE Financial Planners staff member appointed from time to time to assist with overseeing privacy compliance within LIFE Financial Planners.