Accordius

Updated: 12 March 2014

This Privacy Policy applies to information collected by Accordius Pty Ltd ACN 128 900 603 ('Accordius' or 'we'). It outlines how we manage your personal information and safeguard your privacy.

At Accordius, we understand your concerns about privacy and the security of your personal information. Your privacy is important to us and we are bound by the Privacy Act 1998 (Cth) and the Australian Privacy Principles ('APPs'). We are committed to protecting the personal information that we hold about you.

What personal information is collected?

Accordius collects personal information that is reasonably necessary for us to provide you with financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:

information you give us when you request a product or service from us. This information may include your name, date of birth, address, contact details and relevant identification documents;
communications between us and your financial, legal or other adviser, or your broker or agent;
communications between us and associations that you are a member of and with which we have may an affiliation;
transactional information about the use of a product or service if you have or had a product or service with us;
financial information about you such as your financial position;
in some cases sensitive information (e.g. relating to your personal health, racial or ethnic origin); and
employment history and contact details, if seeking employment or contracting opportunities with us.

Accordius collects sensitive information where required by law (e.g. to verify your identity) or where the collection has been consented to. Sensitive information may also be collected and disclosed to employee screening agencies for background checking purposes if you are seeking formal employment with Accordius

How personal information is collected?

Accordius usually collects your personal information in a number of ways including:

directly from you (including via your financial, legal, or other adviser, or your broker or agent), such as when you provide the information by phone, email or in an application form, or when you participate in a survey; and
from third parties such as your financial adviser, lawyer or other agents, credit providers, or identity verification service providers, if you authorise us to do so.

What if you do not provide certain information?

If you provide us with incomplete information, we may not be able to provide you with the product or service.

If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.

If you choose not to disclose your Tax File Number ('TFN'), TFN exemption or Australian Business Number ('ABN'), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you.

If you choose not to disclose your account details or correctly answer verification questions, we may not be able to execute transactions on your behalf.

Use and disclosure of your personal information

Accordius may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:

to verify your identity or transactions which you may enter into with us;
to process your applications for products and services;
to administer and manage the provision of products and services;
to respond to queries, complaints or to provide you with our general customer services;
to provide your nominated financial adviser or other agent with details of your investment;
to provide you with offers of products or services and to improve and personalise our products and services;
to provide you with offers from organisations with whom we may have an alliance;
to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
to comply with Accordius’ risk management policies and procedures;
to conduct product or service research;
to train our staff;
if applying for employment with Accordius, to complete appropriate background checks; or
if attending our offices in person, to assist Accordius in providing a safe and secure environment for employees and visitors.

We may disclose your personal information to:

your financial, legal or other adviser, or your broker or agent;
professional service firms that provide services to us, such as legal and audit services or data or information services; or
organisations with which we have an association and you are a member, and otherwise in accordance with this Privacy Policy and the APPs.

Use of service providers

We may contract out some of our administrative and support functions such as settlement services or document and data storage from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

Keeping us up-to-date

Personal information such as your contact details change from time-to-time and we ask that you keep us informed of any changes by notifying us. Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form (such as a change of bank account from which direct debits are deducted).

To change your contact information you can access this via the secure internet connection we have provided (password and PIN protected) and edit the details listed.

Please see the 'Contacting us' information below if you would like to request an update to the personal information we hold about you.

Storage and security of information

Accordius stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes), however Accordius maintains effective control of the information under contractual arrangements. We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

Openness

This Privacy Policy sets out Accordius’ policies on the management of personal information and is made freely available on our website, or in hardcopy if requested.

Access and correction

Generally, Accordius will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

it would be unlawful to provide the information;
providing access would be likely to prejudice an investigation of possible unlawful activity;
the information is relevant to legal proceedings and would not be accessible in the normal discovery process;
giving access would have an unreasonable impact on the privacy of other individuals;
it would pose a serious and imminent threat to the life or health of any individual; or
the request is frivolous or vexatious.

If a request for access would divulge a commercially sensitive decision-making process, then Accordius may provide an explanation rather than direct access to the information.

If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Accordius disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.

Please see the 'Contacting us' information below if you would like to request an update or seek access to the personal information we hold about you.

Identifiers

Accordius does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier. Instead, Accordius issued numbers such as investor numbers are used to identify individuals and the Accordius products and services they obtain.

Anonymity and pseudonymity

Given legal requirements on financial institutions to identify their customers, in most situations Accordius is unable to allow you to transact with it on the basis of anonymity (including the use of pseudonym). Access to the Accordius public website and some other interactions with Accordius may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.

Overseas disclosures

Accordius does not disclose personal information to recipients in foreign countries.

Direct marketing

Accordius will not use your personal information for direct marketing purposes unless:

we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
we have provided you with a simple means to "opt-out" from receiving direct marketing; and
we have not received such a request from you.

Accordius will not use any sensitive information collected from you for direct marketing purposes.

Changes to our Privacy Policy

Accordius may make changes to this Privacy Policy from time to time for any reason and we will update the website in a timely manner.

Contacting us

If you would like more information about how we manage your personal information, please contact our Privacy Officer on (03) 8623 3378 or write to us at the following address:

The Privacy Officer

Level 24, 333 Collins Street

Melbourne VIC 3000

Or send an email to: information@accordius.com.au.

Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following;

your complaint should be made in writing to the Privacy Officer (via post or email)
we will attempt to respond within 30 days from receipt of your request
if you feel your concerns have not been resolved, you may take them to an external dispute resolution service (such as the Financial Ombudsman Service)
the complaint may be taken to the Office of the Australian Information Commissioner (OAIC).

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au.

Use of our website

We will collect some information from you when you visit the Accordius website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.

Accordius may use third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information.

Accordius may uses advertising companies for online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements and if you have visited our website through an online advertisement. None of the information collected by the advertising companies will personally identify you.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form or by asking for a document for our products and services or by sending us an email. We will record your email address if you send us an email.

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. However, if you do not wish to receive any cookies you may set your web browser to refuse cookies.

Clear gifs

Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.