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
What kind of information do we collect? APP1.4(a)
1. 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.
2. 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)
3. 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)
4. 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).
5. Altus also uses the Information to send you information that you request.
How do we use and/or disclose your information? APP1.4(c)
6. 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.
7. 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)
8. 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.
9. You may opt out of receiving this correspondence at any time by:
- Emailing your opt out request to email@example.com; 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 firstname.lastname@example.org 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.
email@example.com 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.
Rod Dickinson, Matthew W.B. Smith, Adam Montana, Altus Financial Pty Limited ABN 62 081 162 843 Authorised Representatives of Apogee Financial Planning Limited ABN 28 056 426 932, an Australian Financial Services Licensee, registered office 105-153 Miller Street, North Sydney, NSW