Updated: 1 November 2018
If you are seeking information on how our international business manages personal information, please refer to the Fidante Global site, accessed via www.fidante.com.au
1. What personal information is collected?
Fidante Partners collects personal information that is reasonably necessary for us to provide you with financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:
- information you give us when you request a product or service from us. This information may include your name, date of birth, address, contact details and relevant identification documents;
- communications between us and your financial, legal or other adviser, including your broker or other agent;
- communications between us and associations that you are a member of and with which we have an affiliation;
- transactional information about the use of a product if you have or had a product with us;
- financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
- in some cases sensitive information obtained with your consent or otherwise where required or permitted by law (e.g. in relation to anti-money laundering laws)
- information such as your name, address and date of birth where an investor or borrower has listed you as a beneficial owner or other related party in connection with the investment or loan;
- if you are a financial adviser or other authorised representative of a customer, your name, contact details and any other information you provide when communicating with us in relation to our products and services, or in connection with a mutual customer; and
- information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used). This information will be anonymous unless you are a registered user of the relevant Login Site (AdviserOnline or InvestorOnline). See the “Use of our website” section of this policy for further information.
2. How is personal information collected?
Fidante Partners collects personal information in a number of ways including:
- directly from you (including via your financial, legal, or other adviser including your broker or other agent), such as when you provide the information by phone, email or in an application form, or when you access a user account for one of our login sites, or when you participate in a survey, promotion or competition;
- from other Fidante Partners group companies where permitted by law;
- from third parties such as your financial adviser, lawyer or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorise us to do so;
- from our appointed unit registry services provider, if you are investing in one of our Exchange Traded Products (ETPs);
- from an investor or borrower where they have nominated you as a beneficial owner or other related person in connection with the investment or loan;
- from publicly or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws)
3. What if you do not provide certain information?
If you provide us with an incomplete application, we may not be able to provide you with the product or service until the application is complete.
If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.
If you choose not to disclose your Tax File Number (‘TFN’), TFN exemption or Australian Business Number (‘ABN’), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you.
If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process transactions requested.
4. How do we use and disclose your personal information?
Fidante Partners may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:
- to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your application for products and services, such as beneficial owners, where applicable);
- to process your applications for our products and services;
- to administer and manage the provision of our products and services;
- to respond to queries, complaints or to provide you with our general customer services;
- to provide your nominated financial adviser or other agent with details of your investment;
- to confirm your membership of an association with which we have an affiliation;
- to assess credit which you seek from Fidante Partners loan programs and to administer any credit a Fidante Partners loan program provides, including providing your nominated mortgage broker with details of your loan;
- to provide you with offers of other Fidante Partners products or services and to improve and personalise our products and services;
- to provide you with offers from organisations with whom we have an alliance;
- to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
- to comply with Fidante Partners’ risk management policies and procedures;
- to conduct product and market research;
- to train our staff; or
- if attending our offices in person, to assist Fidante Partners in providing a safe and secure environment for employees and visitors.
We may disclose your personal information to;
- your financial, legal or other adviser, including your broker or other agent;
- professional service firms that provide services to us, such as, legal, audit or data/ information services;
- our appointed unit registry services provider, if you are an investor in one of our ETPs
- electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment/product) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws);
- our related companies and/or the investment manager that may also provide you with a financial product or financial service; or
- organisations with which we have an association and you are a member; and
- otherwise in accordance with this policy and the APPs.
5. Overseas disclosures
In some cases, Fidante Partners may utilise ‘Cloud’ storage solutions for data storage purposes, and the relevant servers may be located overseas. Please see ‘Storage and security of information’ section of this policy for further details.
6. Use of service providers
We may contract out some of our administrative and support functions such as mailing, settlement services, unit registry services, document and data storage, background checking or identity verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.
7. Keeping us up-to-date
Personal information such as contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment/product (such as a beneficial owner), and the information is no longer current, you must provide up-to-date information. Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form (such as a change of bank account from which direct debits are deducted). Fidante Partners is unable to change any account details or provide any policy specific information through email. To change your contact information please download and complete the Change of details form (go to ‘Investment Managers’ then select ‘Forms’).
Please see the ‘Contacting us’ section of this policy if you would like to request an update to the personal information we hold about you. If you are an investor in one of our ETP products, please contact our appointed unit registry provider (see ‘Contacting us’) to update your information.
8. Storage and security of information
Fidante Partners stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as ‘Cloud’ service providers for data storage and management purposes) and Fidante Partners maintains effective control of the information under contractual arrangements.
We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure. Where data is held by a third party administrator (such as our appointed unity registry services provider), we take reasonable steps to ensure that the provider has appropriate security measures in place to protect your information.
Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.
This policy sets out Fidante Partner’s policies on the management of personal information and is made freely available on our website, or in hardcopy if requested.
10. Access and correction
Generally, Fidante Partners will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:
- it would be unlawful to provide the information;
- providing access would be likely to prejudice an investigation of possible unlawful activity;
- the information is relevant to legal proceedings and would not be accessible in the normal discovery process;
- giving access would have an unreasonable impact on the privacy of other individuals;
- it would pose a serious and imminent threat to the life or health of any individual; or
- the request is frivolous or vexatious.
If a request for access would divulge a commercially sensitive decision-making process, then Fidante Partners may provide an explanation rather than direct access to the information.
If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Fidante Partners disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.
Please see the ‘Contacting us’ information below if you would like to request an update or seek access to the personal information we hold about you. If you are an investor in one of our ETP’s, please contact our appointed unit registry provider (see ‘Contacting us’) to correct or request access to your information.
Fidante Partners does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier for individuals. Instead, Fidante Partners issues numbers such as investor numbers and account numbers are used to identify individuals and the Fidante Partners products and services they obtain.
12. Anonymity and pseudonymity
Given legal requirements on financial institutions to identify their customers, in most situations Fidante Partners is unable to allow you to transact with it on the basis of anonymity (including the use of a pseudonym). Access to the Fidante Partners public website, and some other interactions with Fidante Partners may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.
13. Direct marketing
Fidante Partners will not use your personal information for direct marketing purposes unless;
- we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
- we have provided you with a simple means to ‘opt-out’ from receiving direct marketing; and
- we have not received such a request from you.
Fidante Partners will not use any sensitive information collected from you for direct marketing purposes. To opt-out of receiving direct marketing, please contact us (see ‘Contacting us’ section below).
14. Use of our website
We will collect some information from you when you visit the Fidante Partners website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.
The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. When you access a user account for one of our login sites (AdviserOnline or InvestorOnline), we may subsequently collect information about your use of the site. This may be used in order to ‘personalise’ your experience on the site by displaying content that is likely to be most relevant to you. This information may also be used to help us understand whether you may benefit from additional support (e.g. we may contact you to determine whether you need assistance in finalising or progressing incomplete applications or quotes). You should refer to the ‘Login Sites’ section below.
If you access one of our login sites (AdviserOnline and InvestorOnline), cookies may also store information related to your session and visit duration, which can be linked back to your login identification. For more information on cookies, please refer to the ‘Cookies’ section below.
Because our login sites have access restricted to users with an account, you will be required to use your secure login. Unique identifiers (such as your login identification) are collected from website visitors to verify the user’s identity.
Unique identifiers may also be used to store information about preferences, to enable dynamic display of the site according to your preferences when you return.
Fidante Partners uses the data collected for statistical analysis and business purposes. We may also use your personal information to contact you via email or phone to tell you about other products or services that we think may be of interest to you, or seek feedback relating to improving the customer experience. If you do not wish to be contacted for these purposes, you can opt-out by contacting us (see the ‘Contacting us’ section of this policy). The data is accessible only to authorised staff. Information which is automatically collected may be published internally as aggregated (de-identified) information to assist with improving the services offered by Fidante Partners through the website.
Fidante Partners uses third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use “cookies” and in some cases “clear gifs/web beacons” to collect information. For more information on our web analytics providers, please visit Omniture and Google Analytics sites.
Fidante Partners uses Google AdWords Remarketing to trigger advertisements across the Internet. AdWords remarketing will display advertising based on what parts of our website have been visited by placing a cookie on your machine. This cookie does not identify you as an individual. Google AdWords Remarketing allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google’s Ads Preferences Manager for more information on the Google AdWords Remarketing cookie and how to opt out from the use of these cookies.
Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies you may not be able to use some areas of our websites.
Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.
15. Employment opportunities at Fidante Partners
If you are seeking employment or contracting opportunities with us, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.
We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf, including overseas agencies where you have prior residential or working history in those locations. For some roles, we may request that candidates complete psychometric testing to assist in candidate selection. This may involve you taking an ability assessment or providing information about your work style and preferences. Testing is undertaken via our service provider’s online system, with results provided to Fidante Partners. Results are also stored by the provider in its Australian data centre and are backed-up in its UK data centre.
If you complete psychometric testing but are not subsequently employed by us, you may contact us at any time to request that your results are de-identified by Challenger and/or our third party provider, and we will take reasonable steps to comply with such requests.
16. Contacting us
If you would like more information about how we manage your personal information, our Client Services team is available Monday to Friday, from 8am to 6pm EST, and can be contacted on 13 51 53 or write to us at the following address:
The Privacy Officer
Level 2, 5 Martin Place
Sydney NSW 2000
Or send an email to: firstname.lastname@example.org
If you are an investor in one of our ETP’s, please contact our unit registry service provider on +61 1300 554 474 or at the following address:
Locked Bag A14
Sydney South NSW 1235
Or send an email to: Activex@linkmarketservices.com.au
17. Complaints about your privacy
If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following;
- Your complaint should be made in writing to the Privacy Officer (via post or email)
- We will attempt to respond within 30 days from receipt of your request
- If you feel your concerns have not been resolved, you may take them to an external dispute resolution service (such as the Australian Financial Complaints Authority)
- The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC)
For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email email@example.com
Fidante Partners may make changes to this policy from time to time for any reason and we will update the website in a timely manner.