1. Your rights in relation to privacy
The privacy of personal information is important to PFM Melton Syndicate Pty Ltd (PFM Melton) (ACN 623 838 666) and its related bodies corporate. The PFM Melton is committed to protecting the privacy of an individual’s personal information. This statement sets out how PFM Melton aims to protect the privacy of your personal information, your rights in relation to your personal information
managed by PFM Melton and the way PFM Melton collects, holds, uses and discloses your personal information.
By using PFM Melton’s services you agree to the collection, use and disclosure of your personal information in the manner set out in this policy.
This privacy statement may be updated from time to time. You should check our website for changes to the Policy.
2. What kinds of personal information does PFM Melton collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, PFM Melton may collect your personal information.
The personal information PFM Melton collects depends on, and is specific to, the products and services you engage us to provide.
Generally, the kinds of personal information PFM Melton collects includes:
- contact and identification information such as your name, address, telephone number, email address and date of birth;
- other identification verification information, including photographic information, from documents including your birth certificate, passport, driver’s licence, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices;
- financial information about your assets, occupation and income, account balances, bank account details, account activities, trust arrangements, payment history and transactions with us and third parties;
- tax information including your tax file number, tax returns and related information;
- professional and business information about your membership of a professional association, partnerships, directorships, business names and trust arrangements.
In some circumstances, PFM Melton may also hold other personal information provided by you.
3. How does PFM Melton collect personal information?
Generally, PFM Melton collects your personal information directly from you, through:
- completion of an application or other form either online or in hard copy;
- provision of original, or copies of, documentation whether delivered in person, by post or electronically;
- face-to-face meetings or telephone meetings and exchanges;
- recordings of conversations (in which case you will be informed of such recording prior to the recording commencing);
- email, or other electronic, correspondence; or
- receipt of mail which you have directed to be sent to PFM Melton.
There may be occasions when PFM Melton collects your personal information from other sources such as from an information services provider, publicly maintained record or third parties such as your family members or professional advisors where we are authorised to do so. Generally, PFM Melton will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does PFM Melton need your personal information?
PFM Melton collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of providing its products and services to you, including providing:
- wealth management and investment products and services;
- treasury services;
- funds management products and services;
- document and asset custody services;
- family office services, being financial and intergenerational wealth management products and services specific to family groups;
- products and services in accordance with any agreement you
enter into with PFM Melton;
- for accounting, billing , investment statements and other administrative purposes;
- identifying and informing you of products and services that may be of interest to you from PFM Melton or other selected third parties; and
- compliance with any legal requirements, including PFM Melton’s obligations under: the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- applicable taxation law;
- the Corporations Act 2001 (Cth);
- the Australian Securities and Investments Commission Act 2001 (Cth); and
- the Bankruptcy Act 1966 (Cth).
In particular, tax file numbers are collected for tax-related purposes only. PFM Melton does not adopt government agency identifiers, for example, tax file numbers, as a primary means of identifying you. Some identity verification information is collected in order to satisfy PFM Melton’s obligations under anti-money laundering laws.
Where personal information is used or disclosed, PFM Melton takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information but without certain personal information, PFM Melton may not be able to provide the products or services you require.
5. To whom does PFM Melton disclose your personal information?
PFM Melton discloses your personal information for the purpose for which PFM Melton collects it. That is, generally, PFM Melton will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to various entities within PFM Melton and third parties where necessary to provide you with our products and services.
These third parties may include government departments or other regulatory authorities, financial market and clearing and settlement facility operators, lenders, credit providers, audit insurance providers, custodians, share registries, certain software providers, third parties engaged to perform administrative tasks, professional advisors or, if authorised by you, your staff, family members, associated entities and other professional advisors. This disclosure is always on a confidential basis. PFM Melton may also disclose your personal information with your consent or if disclosure is required or authorised by law.
6. Overseas disclosure
PFM Melton may disclose personal information to overseas investors in order to provide its products and/or services and for administrative or other business management purposes.
Before disclosing any personal information to an overseas recipient, PFM Melton takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or authorised by law.
7. Credit Checks
PFM Melton does not provide loan or credit facilities and therefore, does not generally handle credit information. However, in the event you default on a payment owing to PFM Melton, PFM Melton may, in some circumstances, undertake a credit check for the purpose of collecting payments that are overdue.
8. Direct marketing
PFM Melton may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting PFM Melton Privacy Officer on the contact details set out in paragraph 12 or through any opt-out mechanism contained in a marketing communication to you.
9. Security of your personal information
PFM Melton regards the security of personal information as very important and takes steps reasonable in the circumstances to ensure the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. PFM Melton holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised personnel.
PFM Melton has a number of physical and electronic protection measures in place including:
- confidentiality requirements for employees;
- confidentiality statements on all outgoing correspondence including email;
- document storage security policies;
- security measures for systems of access including encryption, firewalls, site monitoring and intrusion detection;
- providing a discreet environment for confidential discussions; and
- only allowing access to personal information where the individual seeking access has satisfied PFM Melton’s identification requirements.
However, PFM Melton cannot guarantee the security of personal information provided to PFM Melton by way of email nor can it guarantee the safe delivery of personal information via ordinary post. The security arrangements are reviewed and tested from time to time.
PFM Melton will destroy or de-identify personal information in circumstances where it is no longer required, unless PFM Melton is otherwise required or authorised by law to retain the information.
10. Can you access and correct the personal information that PFM Melton holds about you?
PFM Melton takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that PFM Melton collects and holds. If at any time you would like to access or correct the personal information PFM Melton holds about you, or you would like more information on PFM Melton’s approach to privacy, please contact PFM Melton’s Privacy Officer on the details set out in paragraph 12. PFM Melton will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- PFM Melton requests that you be reasonably specific about the information you require; and
- PFM Melton may charge you a reasonable administrative fee, which reflects the cost to PFM Melton, for providing access in accordance with your request.
If PFM Melton refuses your request to access or correct your personal information, PFM Melton will provide you with written reasons for the refusal and details of complaint mechanisms. PFM Melton will also take steps reasonable in the circumstances to provide you with access in a manner that meets your needs and the needs of PFM Melton.
PFM Melton will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
11. Anonymous information and cookies
When you access our website, PFM Melton may record anonymous information such as your IP address, the time and date you accessed our website, how you were referred to our website and the sections/pages you accessed.
Cookies may be used by PFM Melton to enable a user to be provided with the full range of services offered by PFM Melton, to remember the user’s preferences, to measure and analyse usage of our website and for security.
- Cookies may also collect and store your personal information. This Policy applies to information collected in this way.
- You may adjust your Internet browser to disable cookies, however this may result in you not being able to access the full range of website content.
12. How to contact us – further information, enquiries, requests or complaints
For further information, enquiries, requests or complaints regarding your personal information, or if you would like to opt-out of receiving any promotional and marketing communications, please contact:
The Privacy Officer
Mr Barry J Daniels
PFM Melton Syndicate Pty. Ltd.
Aldersgate House, Level 2, 405-407 Collins Street Melbourne VIC 3000
Phone: +61 3 9618 6888
13. Complaint handling processes
Please direct all privacy complaints to PFM Melton’s Privacy Officer on the details set out in paragraph 12. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and PFM Melton.
PFM Melton’s Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Federal Office of the Australian Information Commissioner.