The Privacy Principles can be viewed in full here:
Myonlineadvisers are committed to managing any personal information we collect from our clients in an open and transparent way, if you have any questions about how we use your personal information please contact us.
Personal Information is any information or opinion about you that is capable, or reasonably capable, of identifying you, whether the information is true or not and is recorded in material form or not.
Sensitive information includes such things as your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or criminal record that is also personal information. Your health, genetic and biometric information and biometric templates are also sensitive information.
The Privacy Act makes provision for people to remain anonymous or use pseudonyms in some circumstances, with respect to the collection of their personal information. We believe that it wouldn’t be possible for us to provide our services to you under those circumstances, and therefore we cannot accept personal information provided anonymously or under a pseudonym.
We collect personal information from you and about you as part of our advisory role, we require this information in order to ensure you receive the appropriate advice and services from us and associated third parties.
The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and email) and financial information.
Your personal and/or sensitive information may be used by us to administer our products and services, for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We cooperate with police and other enforcement bodies as required or allowed by law.
We collect the personal information in a variety of ways, including asking you for data about yourself, and in some cases, by asking third parties to provide or confirm personal information about you, for example we may collect information from a super fund that you invest in. We may disclose personal information to external organisations that help us to provide services. These organisations are bound by confidentiality agreements and may include overseas organisations.
We never collect or attempt to collect personal information about you from either you or a third party without your consent and we will always be clear about the purposes for which the information is intended.
We only collect information from you that we believe we need in order to deliver our services to you. If we believe it is necessary to collect “sensitive”1 personal information from you we will seek your consent first.
If we determine that we have obtained unsolicited personal information from you (i.e. information we don’t actually need in order to deliver our services to you) we will contact you and return it or otherwise promptly destroy it and/or remove it from our records.
Where we collect information about you from a third party we will advise you of this and provide any relevant information to you about the circumstances of the collection as is required by 5.1 and 5.2 of the APP2s.
You can seek access to the personal information we hold about you. If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will let you know why. For example, we may give an explanation of a commercially sensitive decision, or give you access to the information through a mutually agreed intermediary, rather than direct access to evaluative information connected with it.
Where we have collected personal information about you for a particular purpose (“the initial purpose”) we will not use or disclose that information for another purpose (“the secondary purpose”) unless:
- we have first obtained your consent to do so;
- the secondary purpose directly relates to the initial purpose such that you would reasonably expect us to use the information for this purpose; or
- the use or disclosure of the information is permitted or required under Australian Law or a Tribunal/Court order.
If we use or disclose your personal information for any purpose other than the primary purpose of its collection (or any secondary purpose you have expressly consented to) we will advise you as soon as practicable.
1 ‘Sensitive information’ is defined in the Privacy Act to mean information or an opinion about an individual’s: health information and genetic information as well as racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual preferences or practices; or criminal record.
Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact our office. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.
We will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that we collect, use or disclose is accurate, up-to-date, complete and relevant.
We will take all reasonable steps to maintain and store your personal information securely so long as we reasonably require it to deliver our services. Once we no longer require this information we will take all reasonable steps to ensure it is securely destroyed or returned to you or your nominated agent.
If we wish to use any information we have gathered from you for the purpose of direct marketing we will seek your consent first, unless the circumstances of collection gave rise to a reasonable assumption that we collected the information for that purpose – even if this is not the primary purpose of the collection. We will always provide a clear option for you to opt out of this marketing.
We will not direct market to you based on any sensitive personal information that you have provided.
We won’t use any Government related identifier as our own identifier of you unless it is necessary for us to deliver our services to you and in doing so we need to liaise or communicate with a Government Department or agency that requires us to use a Government related identifier.
The only potential overseas recipient of your personal information is a party that hosts any IT infrastructure that we back up our business data to – e.g. cloud-based storage. If in the future we determine it is necessary to disclose your personal information to a service provider that is not based within an Australian territory we will first seek confirmation from the provider that they will treat your data securely and in alignment with the APPs. If we form the view that they are not able to treat client personal information in this way we will seek an alternative service provider.
If we determine that some other overseas party may also receive your personal information in the course of providing our services to you we will perform the assessment outlined above before we engage them.
We disclose personal information when we outsource certain functions. We also seek expert help from time to time to help us improve our systems, products and services. In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there are confidentiality arrangements in place. Contractors, agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.
Any personal information we hold about you will be securely stored either in hard copy or on a secure computer hard drive that requires password entry.
We store much of our business data electronically and may back some or all of this data up using cloud-based technology. As discussed above there is, therefore, a chance that some of your personal information may be disclosed to overseas recipients in the sense that its transmission via the cloud will mean it is “disclosed” to the party that operates the IT infrastructure where the data is backed up.
We are unable to say with complete certainty which countries this infrastructure may be located in however if this is of concern to you we are happy to investigate and to advise.
We will provide you with access to the personal information we hold about you within a reasonable period of your request for such information. Should we decide not to disclose the personal information to you based on one of the limited exceptions that are set out in APP 12.3., we will notify you within a reasonable period of time; the APP on which our decision is based, the basis for our decision and the mechanisms available for you to appeal our decision.
We endeavour to ensure that all personal information that we hold is up to date, accurate and complete. If for any reason we believe that this is not the case we will take steps to remedy this. If you have any reason to believe that personal information that we hold is no longer accurate, up to date or complete please let us know and we will (if appropriate) correct the information.
If you would like to make a complaint about the way that we have treated your personal information you may contact us or the Privacy Regulator.
The Privacy Regulator can be contacted here: https://www.oaic.gov.au/about-us/contact-us.
Further information about the complaint process can be found here: https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint
Myonlineadvisers Pty Ltd
PO Box 427
Fortitude Valley QLD 4006