This policy applies to IVCM (AUST) Pty Ltd and all our representatives. It explains our policy in relation to the collection and management of personal information we collect from individuals. The Privacy Act 1988 requires us to handle personal information in accordance with the Australian Privacy Principles (APP).
Personal information means information, or an opinion about, an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. We are an Australian Financial Services Licensee (AFSL). When we provide you with financial services, we may be required by Corporations Act 2001 and regulatory requirements to seek to obtain certain personal information about you, including, but not limited to, your:
- Name, date of birth, contact details and tax file number.
- Employment details and employment history.
- Financial details.
- Details of your investment preferences and attitude or tolerance to investment and financial risk.
- Information about your financial needs and objectives.
- Information about your employment history, employment circumstances, family commitments and social security eligibility.
We may also need to collect sensitive information if we organise insurance covers for you. Sensitive information includes health information, racial information, genetic information, etc.
We will only collect sensitive information that is reasonably necessary for us to perform our functions or activities in advising you and dealing with you.
We collect personal and sensitive information in a number of ways, including:
- Directly from you such as when you provide the information at meetings, by phone, email, in data collection forms, and when you visit our websites.
- Our website may use “cookies”. Cookies are small data files that are downloaded from our website and stored on your computer when you visit our website. Cookies are used to allow us to see which pages and what information is of most interest to visitors to our website, which in turn enables us to improve our offerings to our customers. Your computer’s web browser will allow you to configure your computer to refuse to accept cookies. You can also delete cookies from your computer’s hard drive at any time. However, please note that doing so may hinder your access to valuable areas of information within our site.
- Indirectly from fund managers, superannuation funds, life insurance companies and other product issuers once you have authorised us to obtain such information or authorised other parties to provide us with this information.
You are not required to provide us the information that we request, or to allow us to collect information from third parties. However, where you choose not to provide us with the information we request, we may not be able to provide you with services that you have requested from us, and we may elect to terminate our arrangement with you. Importantly, if you provide either inaccurate or incomplete information to us you risk obtaining products or services that may not be appropriate or suitable for your needs and you may risk suffering a financial detriment or financial loss.
Where we receive unsolicited personal information about you, we will consider if we could have collected the information if we had solicited the information. Where we determine that we could have collected the personal information from you, we will treat your personal information in the same manner as if we have solicited the information directly from you. Where we determine that we could not have collected the personal information, we will destroy the information or ensure that the information is de-identified as soon as practicable.
We use your personal information for the primary purpose for which the information was obtained: i.e. for the provision of financial services. As an AFS licensee, that will typically mean for the purpose of:
- Providing financial services, tax (financial) services to you.
- Implementing investment or risk management recommendations on your behalf.
We may also use the information for the secondary purpose of:
- Attempting to identify other products and services that may be of interest to you.
- Referring you to our related entities including IVCM Pty Ltd
- Conducting any professional quality review program.
- Managing our business operations such as maintaining secure IT systems.
We may use your personal information to offer you products and services that we believe may interest you. We may also disclose your personal information to external associates and service providers who assist us to market our products and services.
If you do not want to receive marketing offers from us, please inform us. Our contact details could be found at the end of this policy.
With your permission, we may disclose your information to:
- Our representatives.
- The product issuers of products and services that you have elected to acquire, vary or dispose of using our assistance.
- Parties who we think are necessary or convenient to provide financial services to you.
- Our external service providers.
- Our related entities including IVCM Pty Ltd
- Prospective entities interested in acquiring all or part of our business.
For example, information may be disclosed to the following parties:
- Product issuers for the purpose of giving effect to the recommendations made by us, and other organisations who support the products and services we offer.
- Other parties involved in the administration of your financial products or insurance cover (e.g. custodians, brokers, actuaries, call centres, mail houses, product registries, claims assessors etc.).
- Our external service providers (e.g. IT providers, professional advisers and contractors).
- Government and regulatory authorities and other organisations, as required or authorised by law.
- Any person considering acquiring, or acquiring, an interest in our business.
Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required, authorised by law or unless you have voluntarily consented to disclose this information to any third party.
We may transfer information to related bodies corporate or external service providers in locations outside Australia, including, but not limited to, India, United States, China, Poland, Philippines, in the course of storing that information and when using or disclosing it for one of the purposes referred to above. When transferring information to foreign jurisdictions, we will ensure that we satisfy one of the requirements below:
- we will take reasonable steps to ensure the overseas recipient does not breach the APP in relation to the information;
- we form a reasonable belief that the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the APP protect the information and there are mechanisms that the individual can access to take action to enforce that protection of the law or binding scheme; or
- we will seek your informed consent prior to disclosing your information overseas.
We store personal information in our computer database and hard copy files. We take reasonable steps to ensure the personal information collected and held by us is protected from misuse, interference, loss, unauthorised access, modification or disclosure.
In the event you cease to be a client of ours, any personal information which we hold about you will be maintained for a period of not less than 7 years in order to comply with legislative and professional requirements.
We are required to notify you and the Information Commissioner of an eligible data breach. An eligible data breach happens if:
- there is unauthorised access to, unauthorised disclosure of, or loss of personal information held by us; and
- the access, disclosure or loss is likely to result in serious harm to you.
If you receive a statement of an eligible data breach from us, you should read and implement the recommendations about the steps you should take in response to the eligible data breach.
You may request access to the personal information we hold about you, and we will respond within a reasonable period after the request is made. Where we provide you access to such information, we may charge a reasonable fee to cover our costs. We will disclose the amount of such costs to you prior to providing you with the information.
We will take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, up-to-date, complete and relevant. In the event that you become aware, or believe, that any personal information which we hold about you is inaccurate or incomplete, you may contact us to correct the information.
If we disagree about the correction you have supplied, and refuse to correct the personal information, or if we believe that we are unable to comply with your request to access the personal information that you have provided us, we will give you a written notice to that effect. You have a right to make a complaint if you disagree with our decisions in relation to these matters (see below).
Your complaint will be investigated and responded to within 30 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner (OAIC). OAIC can be contacted on 1300 363 992, GPO Box 5218, Sydney NSW 2001. You may also lodge a privacy complaint via OAIC’s website at www.oaic.gov.au.
Alternatively, if your complaint in relation to the breach of your privacy relates to a broader dispute, you may contact the Australian Financial Complaints Authority Limited (AFCA). We are a member of AFCA. AFCA offers a dispute resolution service for the financial services industry.
AFCA can be contacted on 1800 931 678 or via mail – Australian Financial Complaints Authority Limited, GPO Box 3
Melbourne, VIC 3001. A complaint can also be lodged on AFCA website at www.afca.org.au/make-a-complaint
IVCM (AUST) – Privacy Officer
Sussex Street, Tower 2, Level 20, Darling Park, Sydney, NSW 2000
1300 323 489
+61 (0) 8 8188 1026
Information published on this website has been prepared for general information purposes only and not as specific advice to any particular person. Any advice contained on this website is General Advice and does not take into account any person’s particular investment objectives, financial situation and particular needs.
Before making an investment decision based on this advice you should consider, with or without the assistance of a qualified adviser, whether it is appropriate to your particular investment needs, objectives and financial circumstances.
The IVCM (Gibraltar) Retirement Annuity Trust is a ‘Qualifying Recognised Overseas Pension Scheme’ under HMRC number QROPS 510207. The Trustees are IVCM Trustees (Gibraltar) Limited who are located at IVCM Trustees (Gibraltar) Ltd 215B Neptune House, Marina Bay, Gibraltar and are fully regulated and licensed by the Gibraltar Financial Services Commission.
This summary is of a general nature only and is not intended to be relied upon, nor to be a substitute for professional advice, or used in formulating any personal decisions without first seeking such advice. No liability is accepted for any consequences arising from any transaction in connection with this summary. The benefits in this summary may vary according to residence and domicile and different rules apply to different individuals. No warranty regarding the appropriateness of investing in this type of structure is being given and none of the above comments should be construed as tax advice. You should always take independent advice as personal circumstances may mean the comments above do not apply. We do not in any circumstances give advice directly to prospective or existing members, all business is accepted only through professional advisers and they and your other professional advisers should advise you if you have any questions relating to this plan. Advice should be sought from tax advisers as to the tax implications on payment of benefits in the individual’s country of residence.
In the unlikely event that you should wish to register a complaint in relation to your Plan, then such complaints should be made in writing to:
IVCM Pensions, 215B Neptune House, Marina Bay, Gibraltar
Ranfurly Strategic Limited or any of their authorised agents (each an “Authorised Person”) may collect and use the information set out in (or in connection with) the Application Form for the purpose for which it is provided. Each Authorised Person will hold the information securely and may use it in developing and running IVCM (NZ) PIE Superannuation Fund. You may ask any Authorised Person, in writing, to show you the personal information it holds about you to make corrections to it. The information set out in this form will be collected and held by IVCM (NZ) PIE Superannuation Fund whose address is Level 3, 120 Featherston Street, Wellington Central, Wellington 6011.
How to Complain
In the first instance, please direct any complaints to:
Ranfurly Strategic Limited
Level 1, Awly Building
293 Durham Street
If for any reason we can’t resolve things, you can contact:
Public Trust Customer Feedback
PO Box 13 853
Telephone: 0800 371 471
Ranfurly and Public Trust are Members of Financial Services Complaints Limited (FSCL), an approved dispute resolution scheme. If you’ve complained and you’ve reached the end of Ranfurly and Public Trust internal complaints processes without your complaint being resolved to your satisfaction, FSCL may be able to consider your complaint.
Financial Services Complaints Limited
PO Box 5967
Telephone: 0800 347 257
FSCL will not charge a fee to any complainant to investigate or resolve a complaint.