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Policies and Procedures

We’re committed to keeping your data secure, your private information private, and being transparent about our practices as a business.

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Privacy Policy

Our commitment to protecting your personal information

01. Your privacy is important to us. Altus Financial Pty Ltd and all its related entities (Altus) have created this privacy policy (Privacy Policy) in order to demonstrate our firm commitment to privacy.

This policy sets out:

  • what kind of information we collect;
  • how we collect it;
  • why we collect it;
  • how we use and/or disclose it;
  • opting in and out;
  • access to, including correcting / updating your information;
  • whether we will disclosure information to overseas business partners;
  • the location of any overseas business partners;
  • details on how we keep your information secure; and
  • how to complain about a possible breach of this Privacy Policy and how we will deal with your complaint.

What kind of information do we collect? APP1.4(a)

02. In general, the personal information we collect about you (Information) includes (but is not limited to):- name and contact details, including phone numbers and addresses;

  • financial information, including credit card information;
  • age, gender, marital status, occupation; and
  • in some cases, medical information.

03. We also collect information about you that is not personal, such as data relating to your activity on our websites (including IP addresses) via tracking technologies such as cookies, or we may collect information from you in response to a survey.  We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services.

How do we collect your personal information? APP1.4(b)

Altus may collect the Information in several different ways, including:

  • when you engage Altus so that we may provide you with our services;
  • from our contractors and business partners to provide you with our services;
  • when you communicate with us by phone, e-mail, or in writing, or when you participate in our surveys; and- from someone authorised by you to provide us with your Information.

Why do we collect your personal information? APP1.4(c)

04. Altus collects the Information to provide you with one or more of our primary services - wealth management, taxation advisory, self-managed superfunds, business performance, corporate advisory, asset protection & risk, audit and assurance, setting up businesses in Australia (Primary Services).

05. Altus also uses the Information to send you information that you request.

How do we use and/or disclose your information? APP1.4(c)

06. In addition to our Primary Services, we may also use your Information for the following secondary purposes (Secondary Purposes):

  • to provide you with news and information about our products and services;
  • to send marketing, educational and promotional material that we believe you may be interested in;
  • to personalise and customise your experiences;
  • the manage and enhance our products and services;
  • to communicate with you including by email, mail or telephone;
  • to verify your identity;
  • to investigate any complaints about or made by you; and/or
  • as required or permitted by any law.

07. We may also disclosure the Information to third party business partners in Australia in the course of delivering to you our Primary Services.

Opting In and Out APP1.4(d)

08. By being a client of Altus and engaging us for our Primary Services you consent to us using your Information and to receiving correspondence from us in relation to the Secondary Purposes.

09. You may opt out of receiving this correspondence at any time by:

  • Emailing your opt out request to mail@altusfinancial.com.au; and/or
  • Clicking the unsubscribe link at the bottom of all Secondary Purpose correspondence received.

Access to, including correcting / updating your information APP1.4(d)

10. You may have access to your Information at any time by sending a written request to your CRM or to mail@altusfinancial.com.au and we will endeavour to provide you with the Information as soon as possible.  Please note that we may need to take steps to confirm your identity to ensure that it is actually you making the request for the Information.

Will we disclose your information to overseas recipients? APP1.4(f)

11. At Altus we are always looking at ways to provide you with more efficient services that add value to your personal and financial world.  One way we do this is by outsourcing select transactional work to our overseas business associates.  If you engage us for one or more of the following services, we may engage these overseas business associates to perform some or all of the processing work:

  • individual tax returns, including those required to be prepared for Self-Managed Superannuation Funds;
  • financial statements to accompany individual tax returns, including those required to be prepared for Self-Managed Super Funds; and
  • business activity statements.

12. Also as part of Altus striving for continual improvement in our delivering our services to you, we utilise the modern technology of cloud accounting to store your Information for both our Primary and Secondary Services.

Location of overseas recipients APP1.4(g)

13. The overseas business associates to whom we may disclose your Information are currently located in Vietnam, India and the United States of America.

How will we keep your information secure?

14. Altus has security measures designed to protect against the loss, misuse and/or alteration of your Information under its control. These security measures are:

  • all employees sign to confidentiality clauses in their employee agreements;
  • access to the Information is restricted to employees based on the need to carry out his/her role to provide you with our Primary Services and/or Secondary Services;
  • the Information held on our premises is subject to advanced and up-to-date firewalls and encryptions;
  • regular back-ups are conducted of data stored in-house;
  • the Information stored in our client management system that is stored off-site (in the cloud) is stored by a reputable business partner in the United States of America who we are confident stores and manages the data securely.

How to register a concern about a possible breach of this Privacy Policy, and how we will deal with your concern APP1.4(e)

15. All concerns in regards to a possible breach of the Privacy Policy should be made in writing attention to the Privacy Officer at:
mail@altusfinancial.com.au or GPO Box 49, Sydney NSW 2001

16. Once we receive the written complaint, the relevant parties within Altus (Privacy Officer, CRM, etc.) will investigate the complaint and provide you with a response as soon as is reasonably practicable to do so.

If you have any queries on this Privacy Policy please do not hesitate to contact your CRM, or our Privacy Officer on 02 8908 3444.

Privacy Wealth Management

Privacy Policy and Collection Statement

Altus Financial Services Pty Ltd (AFS) ABN 24 637 026 825 (referred to as Licensee, we, our, us) is bound by the Privacy Act 1988 (Privacy Act), including the Australian Privacy Principles (APPs) and recognises the importance of ensuring the confidentiality and security of your personal information.  

To the extent that it is necessary to do so, Licensee also complies with the requirements of the EU General Data Protection Regulation (GDPR) as adopted by EU Member States.  The AAPs and the GDPR Policy share many common requirements.  Where an obligation imposed by the AAPs and the GDPR are the same, but the terminology is different, Licensee will comply with the terminology and wording used in the AAPs, and this will constitute Licensee’s compliance with the equivalent obligations in the GDPR.

If the GDPR imposes an obligation on Licensee that is not imposed by the APPs, or the GDPR obligation is more onerous than the equivalent obligation in the APPs, Licensee will comply with the GDPR (see Annexure A).

All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by Licensee, must abide by this Privacy Policy and Collection Statement (Privacy Policy).  Licensee makes this Privacy Policy available free of charge and can be downloaded from its website www.altusfinancial.com.au

In this Privacy Policy:

    • Credit information is personal information (other than sensitive information) that relates to an individual’s credit history or credit worthiness, and is further defined in the Privacy Act. Credit information includes information that we have obtained from third parties, including individuals, other lessors, credit providers, and Credit Reporting Agencies (CRBs);
    • Disclosure of information means providing information to persons outside of Licensee;
    • Personal information means information or an opinion relating to an individual, which can be used to identify that individual;
    • Privacy Officer means the contact person within Licensee for questions or complaints regarding Licensee’s handling of personal information;
  • Sensitive information is personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
  • Use of information means use of information within Licensee.

What kind of personal information do we collect and hold?

We may collect and hold a range of personal information about you to provide you with our services, including: 

  • name;
  • address;
  • phone numbers;
  • email addresses;
  • occupation;
  • bank account details;
  • driver’s licence details;
  • financial information, including details of:
    • your investments;
    • your insurance policies;
    • estate planning strategies;
    • taxation information; and
    • health information;

How do we collect personal information?

We generally collect personal information directly from you.  For example, personal information will be collected through our application processes, forms and other interactions with you in the course of providing you with our products and services, including when you visit our website, use a mobile app from us, call us or send us correspondence.

We may also collect personal information about you from a third party, such as electronic verification services, referrers, marketing agencies, credit providers or CRBs.  If so, we will take reasonable steps to ensure that you are made aware of this Privacy Policy.  We may also use third parties to analyse traffic at our website, which may involve the use of cookies.  Information collected through such analysis is anonymous.

We will not collect sensitive information about you without your consent, unless an exemption in the APPs applies.  These exceptions include if the collection is required or authorised by law, or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the personal information we request is not provided by you, we may not be able to provide you with the benefit of our services, or meet your needs appropriately.

We do not give you the option of dealing with them anonymously, or under a pseudonym.  This is because it is impractical, and, in some circumstances, illegal for Licensee to deal with individuals who are not identified.

Unsolicited personal information

We may receive unsolicited personal information about you.  We destroy or de-identify all unsolicited personal information we receive, unless it is relevant to our purposes for collecting personal information.  We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect.  If we do this, we will retain the information in the same way we hold your other personal information.

Who do we collect personal information about?

The personal information we may collect and hold includes (but is not limited to) personal information about: 

  • clients;
  • potential clients;
  • service providers or suppliers;
  • prospective employees, employees and contractors; and
  • other third parties with whom we come into contact. 

Website collection

We collect personal information from our website www.altusfinancial.com.au when we receive emails and online forms.  We may also use third parties to analyse traffic at that website, which may involve the use of cookies.  Information collected through such analysis is anonymous.  You can view and access our Privacy Policy by clicking on the privacy button on our website.

We also use analytics on the site.  We do not pass any personally identifiable information through this function, however, the data we collect may be combined with other information which may be identifiable to you. 

Why do we collect and hold personal information?

We may use and disclose the information we collect about you for the following purposes:

    • provide you with our products and services;
    • review and meet your ongoing needs;
    • provide you with information we believe may be relevant or of interest to you;
    • let you know about other products or services we offer, send you information about special offers or invite you to events;
    • consider any concerns or complaints you may have;
    • comply with relevant laws, regulations and other legal obligations; 
  • help us improve the products and services offered to our customers and enhance our overall business.

We may use and disclose your personal information for any of these purposes.  We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.  

Sensitive information will be used and disclosed only for the purpose for which it was provided (or a directly related secondary purpose), unless you agree otherwise, or an exemption in the Privacy Act applies.

Who might we disclose personal information to?

We may disclose personal information and credit information to:

  • a related entity of Licensee;
  • an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors or other advisers;
  • organisations involved in a transfer or sale of all or part of our assets or business;
  • organisations involved in managing payments, including payment merchants and other financial institutions, such as banks;
  • regulatory bodies, government agencies, law enforcement bodies and courts;
  • financial product issuers and credit providers; 
  • anyone else to whom you authorise us to disclose it or is required by law; and
  • any other recipients.

If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it.  We will ensure that all contractual arrangements with third parties adequately address privacy issues, and we will make third parties aware of this Privacy Policy.

We may disclose the following personal information to CRBs, in order to comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF obligations):

  • name;
  • date of birth; and
  • residential address.

The purpose of disclosing this information is to enable us to verify whether the personal information collected matches the identification information held by the CRB.  We may, upon request, provide you with an alternative method of verification, however, any alternative verification method must also comply with the AML/CTF legislation.

Sending information overseas

We will not send personal information to recipients outside of Australia unless:

  • we have taken reasonable steps to ensure that the recipient does not breach the Act, the APPs and the Credit Reporting Privacy Code; 
  • the recipient is subject to an information privacy scheme similar to the Privacy Act; or
  • the individual has consented to the disclosure.

If you consent to your personal information being disclosed to an overseas recipient, and the recipient breaches the APPs, we will not be accountable for that breach under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Management of personal information

We recognise the importance of securing the personal information of our customers.  We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure. 

Your personal information is generally stored in our computer database.  Any paper files are stored in secure areas.  In relation to information that is held on our computer database, we apply the following guidelines: 

  • passwords are required to access the system and passwords are routinely checked; 
  • data ownership is clearly defined;
  • we change employees’ access capabilities when they are assigned to a new position;
  • employees have restricted access to certain sections of the system;
  • the system automatically logs and reviews all unauthorised access attempts;
  • unauthorised employees are barred from updating and editing personal information;
  • all computers which contain personal information are secured both physically and electronically;
  • data is encrypted during transmission over the network; and
  • print reporting of data containing personal information is limited.

Where our employees work remotely or from home, we implement the following additional security measures: 

  • password complexity is enforced, and employees are required to change their password at regular intervals;
  • we ensure that employees only have access to personal information which is directly relevant to their duties;
  • employees are not permitted to work in public spaces;
  • we use audit trails and audit logs to track access to an individual’s personal information by an employee;
  • we monitor access to personal information, and will investigate and take appropriate action if any instances of unauthorised access by employees are detected; 
  • employees must ensure that screens are angled so that they cannot be used by anyone else, and are locked when not in use;
  • employees must ensure that no other member of their household uses their work device;
  • employees must store devices in a safe location when not in use;
  • employees may not make hard copies of documents containing personal information, nor may they email documents containing personal information to their personal email accounts; and
  • employees may not disclose an individual’s personal information to colleagues or third parties, via personal chat groups.

Direct marketing

We may only use personal information we collect from you for the purposes of direct marketing without your consent if:

  • the personal information does not include sensitive information; and
  • you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
  • we provide a simple way of opting out of direct marketing; and
  • you have not requested to opt out of receiving direct marketing from us.

If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent), and we will provide a simple means by which you can easily request not to receive direct marketing communications from us.  We will draw your attention to the fact you may make such a request in our direct marketing communications. 

You have the right to request us not to use or disclose your personal information for the purposes of direct marketing, or for the purposes of facilitating direct marketing by other organisations.  We must give effect to the request within a reasonable period of time.  You may also request that we provide you with the source of their information.  If such a request is made, we must notify you of the source of the information free of charge within a reasonable period of time.

Identifiers

We do not adopt identifiers assigned by the Government (such as drivers’ licence numbers) for our own file recording purposes, unless one of the exemptions in the Privacy Act applies.  

How do we keep personal information accurate and up-to-date?

We are committed to ensuring that the personal information we collect, use and disclose is relevant, accurate, complete and up-to-date.   

We encourage you to contact us to update any personal information we hold about you.  If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction.  Where we are satisfied information is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise.  We do not charge you for correcting the information.

Accessing your personal information

Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information that we hold about you by contacting the Licensee’s Privacy Officer.  We will provide access within 30 days of the individual’s request.  If we refuse to provide the information, we will provide reasons for the refusal.

We will require identity verification and specification of what information is required.  An administrative fee for search and photocopying costs may be charged for providing access. 

Updates to this Privacy Policy

This Privacy Policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and the business environment. 

Responsibilities

It is the responsibility of management to inform employees and other relevant third parties about this Privacy Policy.  Management must ensure that employees and other relevant third parties are advised of any changes to this Privacy Policy.  All new employees are to be provided with timely and appropriate access to this Privacy Policy, and all employees are provided with training in relation to appropriate handling of personal information.  Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.

Non-compliance and disciplinary actions 

Privacy breaches must be reported to management by employees and relevant third parties.  Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance.  Employees or other relevant third parties that do not comply with this Privacy Policy may be subject to disciplinary action.

Incidents/Complaints handling/Making a complaint

We have an effective complaints handling process in place to manage privacy risks and issues. 

The complaints handling process involves:

  • identifying (and addressing) any systemic/ongoing compliance problems;
  • increasing consumer confidence in our privacy procedures; and
  • helping to build and preserve our reputation and business.

You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer. 

If you have any questions about this Privacy Policy, or wish to make a complaint about how we have handled your personal information, you can lodge a complaint with us by:

  • writing – Complaints Manager of our Licensee using any of the contact details at the start of this FSG.
  • emailing –

    mail@altusfinancial.com.au

If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner by:

  • telephoning – 1300 363 992
  • writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
  • emailing – enquiries@oaic.gov.au

Contractual arrangements with third parties

We ensure that all contractual arrangements with third parties adequately address privacy issues, and we make third parties aware of this Privacy Policy.

Third parties will be required to implement policies in relation to the management of your personal information in accordance with the Privacy Act.  These policies include:

  • regulating the collection, use and disclosure of personal and sensitive information;
  • de-identifying personal and sensitive information wherever possible;
  • ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
  • ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.

Your rights

This Privacy Policy contains information about how:

  • you may access the personal information we hold about you;
  • you may seek the correction of your personal information; 
  • you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
  • you may complain about a breach of the Privacy Act, including the APPs; and
  • we will deal with a privacy complaint.

 

 

Loans Privacy Policy

Respecting your privacy

We respect your personal information, and this Privacy Policy explains how we handle it. The policy covers Julie Azzi (CR No. 366834) of BLSSA Pty Ltd ABN 69 117 651 760 (Australian Credit Licence 391237). 

This Policy also includes our credit reporting policy, that is, it covers additional information on how we manage your personal information collected in connection with a credit application, or a credit facility. We refer to this credit-related information below as credit information. 

If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (‘GDPR’) governs the way we collect, use, hold, process and disclose your personal information. Under the GDPR, we are a data controller. We make decisions on how and why your personal information is processed.

What personal information do we collect and hold?

General information

The types of information that we collect and hold about you could include:

  • ID information such as your name, postal or email address, telephone numbers, and date of birth;
  • other contact details such as social media handles;
  • financial details such as your tax file number; and
  • other information we think is necessary.

When the law authorises or requires us to collect information

We may collect information about you because we are required or authorised by law to collect it. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.

What do we collect via your website activity?

If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.

If you start but don’t submit an on-line application, we can contact you using any of the contact details you’ve supplied to offer help completing it. The information in applications will be kept temporarily then destroyed if the application is not completed.

We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum.

To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.

How do we collect your personal information?

How we collect and hold your information

Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.

There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details .

How we collect your information from other sources

Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:

  • we collect information from third parties about the loan or lease made available to you arising out of the services we provide you;
  • we can’t get hold of you and we rely on public information (for example, from public registers or social media) or made available by third parties) to update your contact details; or
  • we exchange information with your legal or financial advisers or other representatives.

What if you don’t want to provide us with your personal information?

If you don’t provide your information to us, it may not be possible:

  • for us to give you the credit assistance you seek from us;
  • to assist in finding a loan or lease relevant to your circumstances;
  • verify your identity or protect against fraud; or
  • to let you know about other products or services that might be suitable for your financial needs.

How we collect and hold your credit information

  • We will collect your credit information in the course of you answering the enquiries we make of you relating to the credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
  • your co-loan applicants or co-borrowers;
  • your guarantors/proposed guarantors;
  • your employer, accountant, real estate agent or other referees;
  • your agents and other representatives like the person who referred your business to us, your solicitors, conveyancers and settlement agents;
  • organisations that help us to process credit applications;
  • organisations that check the security you are offering such as valuers;
  • bodies that issue identification documents to help us check your identity; and
  • our service providers involved in helping us to process any application you make for credit through us.

What do we do when we get information we didn’t ask for?

Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.

When will we notify you that we have received your information?

When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we take care of your personal information?

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

  • document storage security policies;
  • security measures for access to our systems; and
  • only giving access to personal information to a person who is verified to be able to receive that information

We may store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

What happens when we no longer need your information?

We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

How we use your personal information

What are the main reasons we collect, hold and use your information? 

Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:

  • give you credit assistance;
  • give you information about loan products or related services including help, guidance and advice;
  • consider whether you are eligible for a loan or lease or any related service you requested including identifying or verifying you or your authority to act on behalf of a customer;
  • assist you to prepare an application for a lease or a loan;
  • administer services we provide, for example, to answer requests or deal with complaints; and
  • administer payments we receive, or any payments we make, relating to your loan or lease.


Can we use your information for marketing our products and services?

We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you.

We will always let you know that you can opt out from receiving marketing offers.

With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.

Yes, You Can Opt-Out

You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.

What are the other ways we use your information?

We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:

  • telling you about other products or services we make available and that may be of interest to you, unless you tell us not to;
  • identifying opportunities to improve our service to you and improving our service to you;
  • allowing us to run our business efficiently and perform general administrative tasks;
  • preventing any fraud or crime or any suspected fraud or crime;
  • as required by law, regulation or codes binding us; and
  • any purpose to which you have consented.

What are the grounds which we will deal with your personal information under the GDPR?

Under the GDPR, we must have a legal ground in order to process your personal information. The legal grounds that we may rely on are:

  • Performance of our contract with you;
  • Compliance with a legal obligation;
  • Where you have provided your consent; and
  • For our legitimate interests: our main legitimate interests for processing your personal information are: fraud, security, due diligence, business operations and direct marketing.

How long do you keep your information?

We required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example. 

We are required to keep your information for 7 years from the closure of accounts, or otherwise as required for our business operations or by applicable laws.

We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.

Who do we share your personal information with?

To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.

Sharing Your Information

We may use and share your information with other organisations for any purpose described above. 

Sharing with your representatives and referees 
We may share your information with:

  • your representative or any person acting on your behalf (for example, lawyers, settlement agents, accountants or real estate agents); and
  • your referees, like your employer, to confirm details about you.

Sharing with third parties

We may share your information with third parties in relation to services we provide to you. Those third parties may include:

  • the mortgage aggregator through whom we may submit loan or lease applications to lenders or lessors on the mortgage aggregator’s panel;
  • the Australian Credit Licence holder that authorises us to engage in credit activities;
  • referrers that referred your business to us;
  • valuers;
  • lenders, lessors, lender’s mortgage insurers and other loan or lease intermediaries;
  • organisations, like fraud reporting agencies, that may identify, investigate and/or prevent fraud, suspected fraud, crimes, suspected crimes, or other misconduct;
  • government or regulatory bodies (including ASIC and the Australian Taxation Office) as required or authorised by law. In some instances, these bodies may share the information with relevant foreign authorities;
  • guarantors and prospective guarantors of your loan or lease;
  • service providers, agents, contractors and advisers that assist us to conduct our business for purposes including, without limitation, storing or analysing information;
  • any organisation that wishes to take an interest in our business or assets; and
  • any third party to which you consent to us sharing your information.

Sharing outside of Australia

We may use overseas organisations to help conduct our business. As a result, we may need to share some of your information (including credit information) with such organisations outside Australia.

We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.

Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

Where we transfer your information from the EEA’ to a recipient outside the EEA we will ensure that an adequate level of protection is in place to protect your personal information such as putting in place contractual protections to ensure the security of your information.

How do you access your personal information?

How you can generally access your information 

We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone. 

We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first. 

We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:

  • we believe there is a threat to life or public safety;
  • there is an unreasonable impact on other individuals;
  • the request is frivolous;
  • the information wouldn’t be ordinarily accessible because of legal proceedings;
  • it would prejudice negotiations with you;
  • it would be unlawful;
  • it would jeopardise taking action against serious misconduct by you;
  • it would be likely to harm the activities of an enforcement body (e.g. the police); or
  • it would harm the confidentiality of our commercial information.

If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.

How do you correct your personal information?

How we correct your information

Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:

  • inaccurate;
  • out of date;
  • incomplete;
  • irrelevant; or
  • misleading.

If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can - if we can’t, then we’ll let you know in writing.

What additional things do we have to do to correct your credit information?

If you ask us to correct credit information, we will help you with this in the following way.

Helping you manage corrections

Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.

Where we correct information

If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.

Where we can’t correct information

If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.

Time frame for correcting information

If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you. 

If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:

  • let you know about the delay, the reasons for it and when we expect to resolve the matter;
  • ask you to agree in writing to give us more time; and
  • let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

How do you make a complaint?

How do you generally make a complaint?

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us. 

You can contact us by using the details below

Julie Azzi
Julie.Azzi@altusfinancial.com.au
02 8908 3444

Julie Azzi is a credit representative (CR No. 366834) of BLSSA Pty Ltd ABN 69 117 651 760 (Australian Credit Licence 391237).

We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.

Need more help?

If you still feel your issue hasn't been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:

  • Online: www.oaic.gov.au/privacy
  • Phone: 1300 363 992
  • Email: enquiries@oaic.gov.au
  • Fax: +61 2 9284 9666
  • Mail: GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

If you are located in the EEA, you can contact the relevant data protection authority (for example in the place you reside or where you believe we breached your rights). For example, the Office of the UK Information Commissioner:

Office of the UK Information Commissioner

  • Online: www.ico.gov.uk
  • Phone: 0303 123 1113
  • Live chat: https://ico.org.uk/global/contact-us/live-chat

What additional things do we have to do to manage your complaints about credit information?

If your complaint relates to how we handled your access and correction requests

You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.

For all other complaints relating to credit information

If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.

Ask for more time if we can’t fix things in 30 days

If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

Letting you know about our decision

We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

Your Rights under GDPR

If you reside in the EEA, you can also:

  • object to the processing or your personal information or ask us to delete, or restrict or stop using your personal information. There may be circumstances where we are required to, or entitled to retain or continue using your information.
  • withdraw your consent to our processing of your information. We may continue to process our information if we have another legitimate ground to do so.
  • ask us to send an electronic copy of your personal information, including to another organisation.

You can contact us if you wish to exercise these rights. See ‘Contact Us’ for more information If we refuse any request you make in relation to these right, we will write to you to explain why and how you can make a complaint about our decision.

Contact Us

We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback. 

You can contact us by using the details below:

Julie Azzi
Julie.Azzi@altusfinancial.com.au
02 8908 3444
 
Julie Azzi is a credit representative (CR No. 366834) of BLSSA Pty Ltd ABN 69 117 651 760 (Australian Credit Licence 391237).
 

What if you want to interact with us anonymously or use a pseudonym?

If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way, however, as we are often governed by regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:

  • it is impracticable; or
  • we are required or authorised by law or a court/tribunal order to deal with you personally.

What do we do with government-related identifiers?

In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.

Changes to this Privacy Policy

This Policy may change. We will let you know of any changes to this Policy by making changes to this page directly.

Legals

Disclaimer

Whilst Altus Financial Pty Limited ("Altus Financial") have made every effort to keep the information on this website factually correct and up to date, we advise that the information on the website is intended to be either promotional or for matters of general interest only. We do not warrant that the information we provide on this website is up to date, accurate and complete. We do not intend that any information on this website be used as advice for your specific situation.

Given the changing nature of law and regulation and the fact that the application of law can vary widely depending on the precise circumstances and specific facts involved, we caution users of this website not to use the information on the website as a substitute for professional advice specific to your facts and circumstances.

Accordingly, the information in this site is not intended to serve as financial, legal, accounting, taxation or other form of advice.

Altus Financial disclaims all and any liability to any person in respect of the use of the information on this website or linked websites. Altus Financial disclaims all warranties with regard to this information, including all implied warranties of merchantability and fitness for a particular purpose.

Liability limited by a scheme approved under Professional Standards Legislation, other than for the acts or omissions of financial services licensees.

Links

This website may contain links to other third party web sites. Except as otherwise indicated, Altus Financial does not sponsor, endorse or approve the contents of any such sites and accepts no responsibility for information provided on any such sites by independent providers.

Copyright

Altus Financial retains copyright on all content on this website, including but not limited to logos and trade marks.

Users are prohibited from using the content on this site for commercial purposes. This may include modifying, copying, transmitting, distributing, displaying, publishing content, creating derivative works or otherwise using the content for commercial purposes.

Permission is given for the downloading and temporary storage of one or more of these pages for the purpose of viewing on a personal computer. The reproduction, permanent storage, or retransmission of the contents of this website is prohibited without the prior written consent of Altus Financial. Please contact us for permission to reproduce any content.

 

Terms & Conditions of Site

Terms & Conditions of Site

Altus Wealth Pty Ltd ABN 55 649 956 212 an authorised representative of Altus Financial Services Pty Ltd ABN 24 637 026 825 AFSL no. 520266 (“our Licensee”), as shown in our Financial Services Guide.

Your access to this website is subject to these terms and conditions, our Privacy Policy, notices, disclaimers and any other terms and conditions or other statements contained on this website (referred to collectively as "Terms and Conditions"). By using this website you agree to be subject to the Terms and Conditions.

Access for persons from within Australia only

This website is only for use by persons accessing the website from within Australia. The services described in this website are only available to persons accessing the website from within Australia.

No personal financial or investment advice provided to you

Unless otherwise expressly stated to the contrary, this website is not designed for the purpose of providing personal financial or investment advice. Information provided does not take into account your particular investment objectives, financial situation or investment needs.

You should assess whether the information on this website is appropriate to your particular investment objectives, financial situation and investment needs. You should do this before making an investment decision on the basis of the information on this website. You can either make this assessment yourself or seek the assistance of an adviser.

Unless otherwise expressly stated to the contrary, the information on this website is not a recommendation or a statement of opinion to influence you to make a decision about a financial product or class of financial products or to invest in any investments, securities or financial products offered by any product issuer.

Investment performance

Unless otherwise stated to the contrary, neither we nor the Licensee guarantees any particular rate or return, the performance of any investment or the repayment of capital from any investment. Investments are subject to possible risks, including delays in repayment and loss of income or capital invested.

Third party offers and links to other websites

This website may contain references to other special offers or promotions by third parties that have not been verified by us or our Licensee. The website may contain links to other websites or pages of third parties. Neither we nor our Licensee are responsible for the content of any third party websites or pages linked to or linking to this website. Such links are provided for convenience and information purposes only. Neither we nor our Licensee endorse, approve or recommend the operators of third party websites or the content of those websites.

Subject to any applicable law which cannot be excluded, we make no warranties or representations regarding the quality, accuracy, merchantability or fitness for purpose of the goods or services available from third parties. Your obtaining of goods or services from third parties is at your own risk. You indemnify us and our Licensee against all liability, loss, damage, cost and expense arising from or relating to your obtaining goods or services from a third party referred to in this website.

This website may also contain references to offers or promotions by us, or links to pages owned and/or operated by us for services unrelated to our authorisations from our Licensee. Our Licensee does not endorse or recommend and is not responsible for the offers, promotions or content on the websites linked from or linking to this website for these unrelated services.

You may not use this website or provide a link to this website on another website, where the use:

  1. contains any material that is offensive or distasteful;
  2. contravenes any law;
  3. disparages or adversely affects us or our Licensee’s brand or reputation or the services that we provide;
  4. makes any representations about us or our Licensee or the services we provide, including any representations of any endorsement, sponsorship, affiliation or approval of you or the website by us or our licensee;
  5. passes off our documents or information as your own.

Following links to any other websites or pages or linking this website to another website is entirely at your own risk and neither we nor our Licensee shall be responsible or liable for any losses, damages or expenses arising in connection with such linking. If you wish to link to this website, you must first seek our written approval.

Disclaimer and limitation of liability

To the maximum extent permitted by law, neither we nor our Licensee will be liable in any way for any loss or damage suffered by you through use or access to this website, or our failure to provide this website. Our liability for negligence, breach of contract or contravention of any law as a result of our failure to provide this website or any part of it, or for any problems with this website, which cannot be lawfully excluded, is limited, at our option and to the maximum extent permitted by law, to resupplying this website or any part of it to you, or to paying for the resupply of this website or any part of it to you.

General conditions

These Terms and Conditions are governed by the law in force in the State of New South Wales, and the parties irrevocably submit to the non-exclusive jurisdiction of the courts of New South Wales and courts of appeal from them for determining any dispute concerning the Terms and Conditions.

These Terms and Conditions can be modified at any time by us and you agree to continue to be bound by these Terms and Conditions as modified. We will give you notice of these changes by publishing revised Terms and Conditions on this website. We will not separately notify you of these changes.

If the whole or any part of a provision of these Terms and Conditions are void, unenforceable or illegal in a jurisdiction it is severed for that jurisdiction. The remainder of the Terms and Conditions have full force and effect and the validity or enforceability of that provision in any other jurisdiction is not affected. This clause has no effect if the severance alters the basic nature of the Terms and Conditions or is contrary to public policy.

Copyright

Except where necessary for viewing the information on this website on your browser, or as permitted under the Copyright Act 1968 (Cth) or other applicable laws or these Terms and Conditions, no information on this website may be reproduced, adapted, uploaded to a third party, linked to, framed, performed in public, distributed or transmitted in any form by any process without the specific written consent of the owner of the copyright in that material.

 

General Advice Warning

The advice and information provided on this site may not be suitable to you because it is general advice that has not been tailored to your personal circumstances, goals or financial situation. Please seek personal financial advice prior to acting on any of this information.

If you have any questions, please contact your Altus Adviser.

Complaints Policy

Overview

This policy explains how you can make a complaint, our measures for handling your complaint, and the steps you can take if you are not satisfied with our response to your complaint or the time that it takes for us to respond.

When we use the term “IDR”, we mean “internal dispute resolution”.

We acknowledge the importance of having an effective and efficient complaints handling and IDR framework, and we adopt a customer- focused approach. While we acknowledge your right to make a complaint, we expect that you will treat our staff with respect when they are dealing with your complaint.

The purpose of this Complaints Policy is to set out the information required to be in a Complaints policy by ASIC Corporations, Credit and Superannuation (Internal Dispute Resolution) Instrument 2020/98 (“the Instrument”). The Instrument is a legislative instrument made by the Australian Securities and Investments Commission (“ASIC”).

We adopted the current version of this Complaints Policy on 13th September 2021.

What Is A Complaint?

A complaint is:

“An expression of dissatisfaction made to or about us; related to our products, services, staff or our handling of a complaint, where a response or resolution is explicitly or implicitly expected or legally required”.

How To Make A Complaint?

You can make a complaint to us in any of the following ways:

Telephone 02 8908 3444
Email service@altusfinancial.c om.au
Writing GPO Box 49, Sydney NSW 2001

When making your complaint please tell us:

  • Your name
  • How you wish us to contact you (for example, by phone, email)
  • What your complaint is about; and
  • What you are seeking to resolve your complaint

If You Need Help To Make A Complaint

If you need help to make or manage your complaint, you can appoint someone (for example, a relative or friend) to represent you. Please note that we will need your authority to speak to any representative that you appoint.

We can also help you to fill out forms or express your complaint.

How We Will Deal With Your Complaint

Acknowledgement

We will acknowledge receipt of your complaint and try to resolve it as quickly as possible.

Generally, where your complaint is made:

  • Verbally – we will acknowledge your complaint in the same manner and, in writing, within one business day, or as soon as practicable;
  • In writing – by email or via social media, we will acknowledge your complaint, in writing, within one business day or as soon as practicable thereafter.

When acknowledging your complaint, we will also have regard to any preferences you have communicated to us in relation to the way in which you wish for us to communicate with you.

Investigation Of Your Complaint

If we cannot resolve your complaint immediately, we will need some time to investigate your concerns.

We may also request that you provide us with further information to assist with our investigation.

IDR Response

We will provide you with our written reasons for the outcome of your complaint (“IDR Response”) within the following timeframes where:

  • Your complaint is not resolved within 5 business days of us receiving your complaint;
  • If you request a written response; or
  • If your complaint is about a declined insurance claim; the value of an insurance claim or if your complaint is about a decision of a superannuation trustee.
Standard complaints No later than 30 calendar days after receiving your complaint
Traditional trustee complaints No later than 45 calendar days after receiving your complaint
Superannuation trustee complaints, except for complaints about death benefit distributions No later than 45 calendar days after receiving your complaint
Complaints about superannuation death benefits No later than 90 calendar days after the expiry of the 28- calendar day period for objecting to a proposed death benefit distribution referred to in section 1056(2)(a) of the Act

Our IDR Response will also inform you of your right to escalate your complaint to the Australian Financial Complaints Authority (AFCA). AFCA offers a free and independent dispute resolution for financial complaints to individuals and small businesses.

If we reject your complaint (whether in full or in part), our IDR Response will:

  • Identify and address the issues you raised in your complaint;
  • Set out our findings on the material questions of fact raised in your complaint, making reference to the relevant supporting information; and
  • Provide a sufficient level of detail in order for you to understand the reasons for our decision so that you can decide whether to escalate the complaint to AFCA or another forum. We are not required to provide you with an IDR Response if:
  • Your complaint is resolved to your complete satisfaction within 5 business days and you have not requested an IDR Response; or
  • Within 5 business days of receiving your complaint, we have given you an explanation and/or apology in circumstances where we cannot take any further action to reasonably address your complaint.

>Delay In Providing An IDR Response
If we are not able to provide our IDR Response to you on time because your complaint is complex or because of circumstances beyond our control, we will write to you to explain the reasons for the delay, and inform you of your right to complain to AFCA and provide you with AFCA’s contact details.

Escalating Your Complaint
If you are not satisfied with our response to your complaint, you can escalate your complaint to AFCA.

AFCA
We are required to be a member of an external dispute resolution scheme. Accordingly, we are a member of AFCA and our membership number is 67018.

You can contact AFCA using the following details:

  • Email: info@afca.org.au
  • Phone: 1800 931 678 (or +61 1800 931 678 if calling from overseas)
  • Online: afca.org.au
  • Mail: GPO Box 3, Melbourne, VIC, 3001.

Endnotes

Time stops running when (a) another person commences legal proceedings to be included as a beneficiary and the outcome would affect the handling of the complaint at IDR; or (b) the traditional trustee applies for an opinion, advice or direction from a court to reasonably handle the complaint at IDR. Time will start to run again once the court determines whether the other person should be included as a beneficiary, or provides an opinion, advice or otherwise gives a direction, and the time to lodge an appeal (if relevant) has passed.

Any objection to a proposed death benefit distribution will trigger the start of the IDR process. When an objection is made, the 90- calendar day maximum IDR timeframe begins from the end of the 28-calendar day objection period.