Introduction
Future Private Wealth Pty Ltd ACN 644 103 417, including any Authorised Representatives, (referred to as FPW,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.
All third parties (including clients, suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by FPW, must abide by this Privacy Policy and Collection Statement ( Privacy Policy). FPW makes this Privacy Policy available free of charge and can be downloaded from its website futurepw.com.au.
In this Privacy Policy:
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:
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 FPW 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:
Website collection
We collect personal information from our website futurepw.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.
To use our website, you consent to our use of cookies. You can withdraw or modify your consent to our use of cookies at any time. If you no longer wish to receive cookies you can use your web browser settings to accept, refuse and delete cookies. To do this, follow the instructions provided by your browser. Please note that if you set your browser to refuse cookies, you may not be able to use all of the features of our website.
Cookies do not contain personal information in themselves, but can be used to identify a person when combined with other information. Cookies are small text files which are transferred to your computer’s hard drive through your web browser that enables our website to recognise your browser and capture and remember certain information.
We may also use cookies to understand how users interact with our website, to compile aggregate data about our website traffic, including where our website visitors are located, and interaction so that we can offer better user experiences.
We may 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:
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 to:
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):
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 may disclose personal information to overseas recipients in order to access services they provide, such as paraplanning and administration. If this is the case, we will provide you with details, including the relevant countries. It is not practical to list all of the countries in which personal information is likely to be disclosed, however, they are likely to include the Philippines and the United State of America.
We may store your information in the 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.
We will not send personal information to recipients outside of Australia unless:
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:
Where our staff work remotely or from home, we implement the following additional security measures:
Direct marketing
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
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 FPW’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 staff and other relevant third parties about this Privacy Policy. Management must ensure that staff and other relevant third parties are advised of any changes to this Privacy Policy. All new staff members are to be provided with timely and appropriate access to this Privacy Policy, and all staff are provided with training in relation to appropriate handling of personal information. Staff 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 staff and relevant third parties. Ignorance of this Privacy Policy will not be an acceptable excuse for non-compliance. Staff members 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:
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:
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:
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:
Your rights
This Privacy Policy contains information about how:
Dated: 1 July 2021