LEGAL

PRIVACY POLICY

When you trust us with your personal information, you expect us to protect it and keep it safe.

We take this responsibility seriously and we are bound by the Privacy Act 1988 (Cth) (‘Privacy Act’). We will protect your personal information in accordance with the Australian Privacy Principles and other applicable laws, such as the Spam Act 2007 (Cth) (‘Privacy Laws’). These principles govern how we can collect, use, hold and disclose your personal information and ensure the quality and security of your personal information.

If you would like more information about how we protect your privacy, please contact us.

About this policy

This Privacy Policy explains how we use, disclose, manage your personal and sensitive information.

What is personal information?

Personal information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information.

What is sensitive information?

Personal information is sensitive information that includes information about your religion, racial or ethnic origin, political opinions, criminal record and sexual orientation. It also includes health information and biometric information.  Therefore, any references in this policy to personal information may also include sensitive information.

The collection of sensitive information is restricted by the Privacy Act. Generally, we only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection. For example, we may collect health information about you to process a claim under an insurance policy.

In addition, sensitive information may also be obtained in relation to hardship circumstances and or where we need to provide additional care to clients in vulnerable circumstances.

What kinds of personal information do we collect and hold?

As part of building our relationship and understanding of you and your personal circumstances to provide you personalised advice, we need to collect personal information. The personal information we are likely to collect, and hold includes:

• Your name, address and contact details
• Your date of birth, gender and tax residency
• Details about members of your family and related entities
• Your occupation, employer, employer history and educational qualifications
• Any corporate or trustee relationships, where you are shareholder, beneficiary, settlor or controlling person under these entities.
• Preferences or values in relation to financial products or strategies
• Government identifiers such as your tax file number, Centrelink identifier, director identification number, identification document numbers and photographs
• Details about your current and/or future financial circumstances, including assets, liabilities, income and expenses, bank details, goals and strategies, risk tolerance, insurance and estate planning arrangements
• Records of our discussions (with your consent)
• Your signature either in hard copy or digitally, and/or
• We may also ask for this identification information from your power of attorney.

The information that we seek to collect about you will depend on the products or services that we provide.

If you apply for insurance, we may collect information about what is being insured, the beneficiaries along with your health and financial situation, depending on the type of insurance.

Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints you make and, if you make an insurance claim, collecting additional information to assess the claim.

Tax file numbers

Taxation laws generally prohibit the collection, use and disclosure of TFNs. However, an investment body may be informed of a TFN by a person acting on behalf of another person. Partners in Planning may need to collect your TFN to administer and/or implement our recommendations in line with the information below. Upon completion of use, your TFN will be removed and or redacted from our records. An alternative is for you to provide your TFN directly to the relevant body.

Investment and superannuation bodies generally ask for your TFN , for the following reasons:

You are not required to provide us or any other body with your TFN and it is not an offence to choose not to do so. However, if you do not quote your TFN or exemption status to authorised bodies (as applicable):

• Your investment income and concessional super contributions may be taxed at the highest marginal rate plus Medicare levy
• You may pay more tax on your super benefits than required (you may get a refund at the end of the financial year in your income tax assessment)
• Your super fund may be required to reject your personal after-tax contributions
• It may be difficult to find and consolidate your superannuation accounts

You may be exempt from the TFN quotation requirements and however you are generally required to quote your TFN exemption arrangements to the investment body:  Typically, the following exemptions apply.

• Persons receiving a qualifying pension/benefit
• Children under the age of 16
• Entities not required to lodge income tax returns
• Non-residents

Do I have to provide you my full information?

You have the right to remain anonymous and or not to provide us your personal or sensitive information. However, we specialise in providing personal financial advice and developing strategies that consider your personal circumstances, objectives and needs. Where we do not have the necessary information to ensure our advice is in your best interests, for example if it is inaccurate or incomplete, we may not be able to provide you with advice and or services and the advice may not be appropriate given you full needs and circumstances. Where you provide limited information, we will make you aware of any limitations or risks we can identify given any limited advice we may provide.

Why do we collect, hold, use and disclose personal information?

We collect, use, hold, and disclose personal information to provide you with products and services. This includes:

• Checking or obtaining third party checks into whether you are eligible for the product or service
• Assisting you with online applications
• Providing the product or service
• Managing or improving the product or service we provide you, for example, as invoicing or client surveys.
• Assisting you with your questions, and requests, feedback and or complaint; and
• Communicating with you

We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.

We may also use your information to internally help us improve our services with you.

How do we collect personal information?

We collect most personal information directly from you. For example, we will collect your personal and or sensitive information when you apply for or use a product and/or service or talk to us in person or on the phone.

We also collect information from you electronically. For instance, when you visit our website or if you send us electronic correspondence (see “Do we collect personal information electronically?”).

Sometimes we collect personal or sensitive information about you from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from:

• Publicly available sources of information, such as public registers
• Your representatives (including your legal adviser, accountant, mortgage broker, executor, administrator, guardian, trustee, or attorney)
• Your employer
• Other organisations, who jointly with us, provide products or services to you
• Insurers, re-insurers and health care providers

What laws require or authorise us to collect personal information?

We are required or authorised to collect:

• Certain identification information about you as outlined in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1)
• Your Tax File Number, if you choose to provide it as specified in the Income Tax Assessment Act 1936 (Cth)
• Certain information in relation to your application if you have applied for insurance as required by the Insurance Contracts Act 1984 (Cth).

How do we protect the personal and or sensitive information we hold?

We have implemented security measures on all computers, programs and mobile devices accessing our IT systems and data backups. We have controlled access to our principal place of business, secure paper files, provide employee training and clauses in employee and contractor agreements regarding confidentiality and destroying and de-identifying data when it is no longer required or inadvertently provided by a third party.

Unfortunately, the transmission and storage of any data, including your personal information, over the internet, email or within cloud-based storage systems may not be completely secure. Whilst we will endeavour to protect your personal information through privacy controls it is possible that third parties, outside our control, may be able to access, obtain or intercept transmissions or private communications without our knowledge or consent. Please also take this into consideration when sending us your personal information.

As a result, we cannot ensure the security of data, and any transmissions or electronic communications between us knowing this risk. We take reasonable steps to password sensitive and or personal information, secure all computing devices used in connection with our website, software, system and services, we recommend you do the same and ensure any internet accessible storage or portable devices, such as your mobile phone are secure.  We also recommend you use multifactor authentication on any applications where this functionality is available.

If you have reason to believe that your interaction with us is no longer secure, for example, if you fear the security of any account, please change your passwords and contact us immediately.

What is a notifiable data breach?

The Privacy Act includes a Notifiable Data Breaches (NDB) scheme, which requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain breaches likely to cause harm and recommend steps you can take to limit the impacts of a breach (for example, a password change).

If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.

Who do we disclose your personal information to, and why?

We may provide personal or sensitive information about our clients to organisations outside of Partners in Planning. To protect personal information, we require our service providers comply with the Privacy Act. We only authorise our service providers to use or disclose your personal and or sensitive information for the specific role we ask them to perform.

Generally, we disclose personal or sensitive information to organisations that help us with our business. This includes:

• Our agents, contractors and external service providers (for example, mailing houses and technology service providers)
• Administrative and paraplanning service providers
• Insurers, re-insurers and health care providers
• Payment systems operators (for example, merchants receiving card payments)
• Financial services organisations, superannuation funds, stockbrokers, custodians, fund managers and portfolio service providers
• Debt collectors
• Our representatives (including legal advisors, compliance advisors or auditors)
• Your representatives (including your legal advisor, accountant, mortgage broker, property valuer, guarantors, (including prospective) family members, executor, administrator, guardian, trustee, or attorney)
• Any government and regulatory bodies required by law, to prevent fraud or other misconduct
• IT and cyber and data security service providers
• External dispute resolution schemes, courts or tribunals
• Financial services, regulatory bodies, disciplinary panels, government agencies and law enforcement bodies in any jurisdiction.
• The trustee of your superannuation fund where this information is requested by them to satisfy their compliance requirements to deduct adviser service fees from my account.
• Other third party organisations, who jointly with us, provide products or services to you or with whom we partner to provide products or services to you. Information that we provide to third parties will be handled in accordance with their privacy policy, which is further detailed below.

We may store your information in cloud or other types of networked or electronic systems.  Electronic or networked systems can be accessed from various countries via an internet connection, so it’s not always practicable to know in which country your personal information may be held.

We may disclose your personal information overseas.  We engage the services of these providers, who may be based both in Australia and or overseas. Some of these providers may have all or part of their operations overseas, store data overseas, access services overseas or utilise third parties who are overseas.

Partners in Planning maintains an Outsourcing Policy which governs the selection of service providers to ensure quality providers are selected and that their privacy policy aligns with our philosophy of protecting our clients’ privacy.

We provide a list below of our main third-party service providers, third-party applications or cloud base applications we may use, including links to their privacy policy and their data centre locations where available.

Microsoft Office / Windows

Link to Privacy Policy 

Gemini

Link to Privacy Policy 

Plaud

Link to Privacy Policy  

Monday

Link to Privacy Policy 

ChatGPT

Link to Privacy Policy 

Do we use or disclose personal information for marketing?

We may use your personal information to offer you products and services we believe may interest you. We may send you direct marketing communications such as offers, updates, events, articles or newsletters. We will always give you the option of electing not to receive any of these communications in the future by notifying us or unsubscribing at any time.

Do we collect personal information electronically?

We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications.

Each time you visit our website, we collect information about your use of the website, which may include the following:

• The date and time of visits
• Which pages are viewed
• How users navigate through the site and interact with pages (including fields completed in forms and applications completed)
• Navigation patterns and user interactions
• Location information about users
• Information about the device used to visit our website, and
• IP addresses.

We use technology called cookies when you visit our site. Cookies are small pieces of information stored on your hard drive or in memory. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.

One of the reasons for using cookies is to offer you increased security. The cookies we send to your computer cannot read your hard drive, obtain any information from your browser or command your computer to perform any action. They are designed so that they cannot be sent or retrieved by any another website.

We won’t ask you to supply personal information publicly any social media platforms.

Can I gain access to and correct my personal information?

You can request access to the personal information we hold about you. You can also ask for corrections to be made. To do so, please contact us.

There is no fee payable for updating or correcting your personal information. Should you request access to your personal information, a reasonable cost may apply. This cost may apply to the time it takes to locate, compile and supply the information to you.

There are some circumstances in which we are not required to give you access to your personal information. If we refuse to give you access to or to correct your personal information, we will give you a notice explaining our reasons, except where it would be unreasonable to do so.

If we refuse your request to access or correct your personal information, we will also provide you with information on how you can complain about the refusal.

How long do we keep your personal information?

We will generally keep your personal and or sensitive information for as long as the laws require us to you continue to be client of the Partners in Planning.

We also generally retain your personal information for at least seven years after you stop being a client.  This is a legal requirement that allows us to demonstrate we have complied with relevant financial service laws and respond to any questions or complaints.

We periodically review the information we no longer need and take steps to delete this.

How we resolve your privacy concerns and make you aware of your rights?

If you are concerned about how your personal or sensitive information is being handled or if you have a complaint about a breach of the Australian Privacy Principles, please contact us.

We are committed to resolving complaints within a fair and reasonable timeframe. Wherever possible, complaints will be resolved promptly at the first point of contact. Where this is not possible, we aim to resolve complaints within 30 calendar days as explained fully in our complaints policy can is also accessible from our website www.apartnerinplanning.com.au

If you are unhappy with our response, there are other bodies you can go to including the Australian Financial Complaints Authority and or the Office of the Australian Information Commissioner.

Office of the Australian Information Commissioner

Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can be contacted at:

GPO Box 5218

Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

www.oaic.gov.au 

Contact us

Our Privacy Officer can also be contacted in relation to privacy concerns by writing to:

Attention

Privacy Officer – Partners in Planning

Mailing/In-person Address:241 Koornang Rd, Carnegie VIC 3163

Phone: 1300 880 100

Email: info@partnersinplanning.com.au

Links to other sites

Where our website may provide links to other sites for you to access, you should be aware that these other sites are not subject to this Privacy Policy or our privacy standards and our procedures. You will need to contact the owner of any link directly to ascertain their privacy standards.

Changes to our Privacy Policy

We may change the way we handle personal information from time to time for any reason. If we do so, we will update this Privacy Policy and we encourage you to review this policy periodically.  While we seek to maintain the currency of the third-party links in this policy, third party privacy policies may change prior to our own review of our policy.  We therefore we encourage you to check any link is the most up to date privacy policy from any of our listed third-party providers.  This policy was last reviewed as per the version date at recorded at the bottom of this policy.

Providing us other information

Please make anyone in which you have provided their personal information to us aware of this Privacy Policy.  If you provide us another person’s sensitive information, ensure you seek their consent and make them aware of this policy.  Where you have actively provided personal information about children under the age of 16, as their parent or guardian in this capacity, by providing us this information, you have given your consent for us to hold this information. Where you provide any information in this regard in the absence of the other parent or guardian, please seek their consent and make them aware of this Privacy Policy.

Client consent

By asking us to assist with your financial needs, you consent to the collection and use of your personal information you have provided us with for the purposes described in this policy.

We will request a separate signed consent in relation to the following:

• Collecting, using and or disclosing sensitive information as described in this Privacy Policy
• Obtaining your Tax File Number where you decide to provide it.

If you do not agree with the terms of this Privacy Policy, please do not use the website or otherwise provide us with your personal and or sensitive information.

Meaning of words

We, us or our means:

Partners in Planning Asset Management Pty Ltd (‘Partners in Planning’) is a Corporate Authorised Representative no 344562014, of A Partner in Planning (Aus) Pty Ltd ABN 16 605 522 638, Australian Financial Services License Number 476202.

Version

July 2025