ADOPTED: 3RD OCTOBER 2017
Our commitment to your privacy
The privacy of individuals, including our staff, our contractors, and our clients, is of utmost importance to Audeara. This includes information or opinions about you that we collect and record which reasonably could be used to identify you. We adhere to the National Privacy Principles and the Privacy Act 1988 (Cth).
This document sets out our policies for managing personal information across our business operations in Australia. We have a Privacy Officer, whose contact details are below.
Types of personal information we collect
When dealing with our customers and clients we generally collect your name, address, telephone number, e-mail address and other contact details. Depending on the type of interaction you may have with Audeara, we may also collect and update personal information necessary to establish your identity and personal financial situation, such as date of birth, employment details, bank account details, tax file number, basic financial information, and other information about your financial history.
We generally do not collect sensitive information (such as relating to ethnic origin, religious or philosophical beliefs, membership of a political or trade association, sexual preferences or health), and would not do so without your consent. Audeara does not collect information in a way that is unfair or unlawful. The collection of information will not intrude unreasonably on the personal affairs of the individual concerned.
Why we collect personal information
Generally, we collect, update and use personal information about you related to our functions and activities, including
- to assess your classification as a ‘wholesale investor’ or otherwise under the Australian Financial Services provisions of the Corporations Act 2001 (Cth);
- to provide requested services to you, and bill you for our services and collect overdue payments;
- for our research and development of new products and services;
- for training, quality control and verification purposes (including monitoring and recording your telephone conversations with us from time to time);
- to communicate our promotional materials to you; and
- to meet our legal obligations.
How we collect information
Generally, we collect personal information directly from you, in response to our website, direct mail or when you have other dealings with us. We may collect that information over the telephone or internet, in person (when you visit us at a Audeara office) and when you write to us.
We may also collect personal information through third parties such as
- a business that provides commercial financial information;
- referees (if you give us the name of someone who can give a reference about you); and
- publicly available sources of information.
How we store information
We store personal information in a combination of secure computer storage facilities and paper based files and other records. We have taken a number of steps to protect the personal information we hold from misuse, loss and unauthorised access, modification or disclosure. We use generally accepted technology and security so that we are satisfied that your information is transmitted safely to us through the internet or other electronic means. We will take reasonable steps to securely destroy or permanently de-identify personal information when we no longer need it.
When we may disclose your personal information
Generally, we may disclose personal information about you in the following circumstances:
- to comply with our legal obligations (we notify you any time we are required to produce information in this way unless we are prohibited by court order or law or there is suspicion of fraud and/or criminal activity);
- where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter;
- where we are satisfied on reasonable grounds that disclosure is necessary to lessen or prevent a serious threat to the life, health, safety or welfare of an individual or to public health, safety or welfare;
- the disclosure is necessary for research or the compilation or analysis of statistics in the public interest, but does not involve the publication of the personal information in a form which would identify an individual.
Keeping us up-to-date
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If your personal details change, such as your telephone number or billing address, please contact us so that we can continue to provide you with our services.
You can access your personal information
Following a request, we will provide you with a copy of personal information which we hold about you in accordance with our obligations under the Privacy Act. We may charge a fee for retrieving this information (we will inform you of the fee before providing the information). Please note that there are some circumstances set out in the Privacy Act where we may refuse your request.
We will promptly acknowledge and investigate any complaints about the way we manage personal information.