Altitude Wealth Management Pty Ltd ACN 618 850 347 (referred to as Altitude Wealth Management Pty Ltd, 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.
- Disclosure of information means providing information to persons outside of Altitude Wealth Management Pty Ltd;
- Personal information means information or an opinion relating to an individual, which can be used to identify that individual;
- Privacy Officer means the contact person within Altitude Wealth Management Pty Ltd for questions or complaints regarding Altitude Wealth Management Pty Ltd’s handling of personal information;
- Sensitive information is personal information that includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information; and
- Use of information means use of information within Altitude Wealth Management Pty Ltd.
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:
- name, address, phone numbers and email addresses;
- bank account details;
- driver’s licence details;
- tax file number (TFN)
- financial information, including details of:
- your investments;
- your insurance policies;
- estate planning strategies;
- taxation information; and
- health information
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 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 Altitude Wealth Management Pty Ltd 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:
- potential clients;
- service providers or suppliers;
- prospective employees, employees and contractors; and
- other third parties with whom we come into contact.
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 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:
- provide you with our products and services;
- review and meet your ongoing needs;
- provide you with information we believe may be relevant or of interest to you;
- let you know about other products or services we offer, send you information about special offers or invite you to events;
- consider any concerns or complaints you may have;
- comply with relevant laws, regulations and other legal obligations;
- help us improve the products and services offered to our customers and enhance our overall business;
- to assist in providing wealth management, financial planning, and personal risk services.
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:
- a related entity of Altitude Wealth Management Pty Ltd;
- an agent, contractor or service provider we engage to carry out our functions and activities, such as our lawyers, accountants, debt collectors or other advisers;
- organisations involved in a transfer or sale of all or part of our assets or business;
- organisations involved in managing payments, including payment merchants and other financial institutions, such as banks;
- regulatory bodies, government agencies, law enforcement bodies and courts;
- financial product issuers and credit providers; and
- anyone else to whom you authorise us to disclose it or is required by law;
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):
- date of birth; and
- residential address.
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 Salesforce, a customer relationship management (CRM) system which uses servers based in the USA. We use Salesforce as part of managing our ongoing compliance functionality. The types of information which may be stored in Salesforce may include personal information for the purposes of auditing financial advice files and testing the quality of our advice.
We will not send personal information to recipients outside of Australia unless:
- we have taken reasonable steps to ensure that the recipient does not breach the Act, the APPs;
- the recipient is subject to an information privacy scheme similar to the Privacy Act; or
- the individual has consented to the disclosure.
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:
- passwords are required to access the system and passwords are routinely checked;
- data ownership is clearly defined;
- we change employees’ access capabilities when they are assigned to a new position;
- employees have restricted access to certain sections of the system;
- the system automatically logs and reviews all unauthorised access attempts;
- unauthorised employees are barred from updating and editing personal information;
- all computers which contain personal information are secured both physically and electronically;
- data is encrypted during transmission over the network; and
- print reporting of data containing personal information is limited.
Where our employees work remotely or from home, we implement the following additional security measures:
- two-factor authentication is enabled for all remote working arrangements;
- password complexity is enforced, and employees are required to change their password at regular intervals;
- we ensure that employees only have access to personal information which is directly relevant to their duties;
- we use audit trails and audit logs to track access to an individual’s personal information by an employee;
- we monitor access to personal information, and will investigate and take appropriate action if any instances of unauthorised access by employees are detected;
- employees must ensure that screens are angled so that they cannot be used by anyone else, and are locked when not in use;
- employees must ensure that no other member of their household uses their work device;
- employees must store devices in a safe location when not in use;
- employees may not make hard copies of documents containing personal information, nor may they email documents containing personal information to their personal email accounts; and
- employees may not disclose an individual’s personal information to colleagues or third parties, via personal chat groups.
We may only use personal information we collect from you for the purposes of direct marketing without your consent if:
- the personal information does not include sensitive information; and
- you would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
- we provide a simple way of opting out of direct marketing; and
- you have not requested to opt out of receiving direct marketing from us.
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.
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 Altitude Wealth Management Pty Ltd’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.
Non-compliance and disciplinary actions
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:
- identifying (and addressing) any systemic/ongoing compliance problems;
- increasing consumer confidence in our privacy procedures; and
- helping to build and preserve our reputation and business.
You can make a complaint to us about the treatment or handling of your personal information by lodging a complaint with the Privacy Officer.
- writing – PO BOX 3141, Hermit Park, Qld, 4812
- emailing – email@example.com
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:
- telephoning – 1300 363 992
- writing – Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
- emailing – firstname.lastname@example.org
If you are not satisfied with our response to your complaint, you can also refer your complaint to the Australian Financial Complaints Authority (AFCA) by:
- telephoning – 1800 931 678
- writing – GPO Box 3, Melbourne, VIC, 3001
- emailing – email@example.com
Contractual arrangements with third parties
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:
- regulating the collection, use and disclosure of personal and sensitive information;
- de-identifying personal and sensitive information wherever possible;
- ensuring that personal and sensitive information is kept securely, with access to it only by authorised employees or agents of the third parties; and
- ensuring that the personal and sensitive information is only disclosed to organisations which are approved by us.
- you may access the personal information we hold about you;
- you may seek the correction of your personal information;
- you may ask us to provide an alternative means of identity verification for the purposes of the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- you may complain about a breach of the Privacy Act, including the APPs; and
- we will deal with a privacy complaint.