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PRIVACY POLICY

At Cambio Group, we are committed to protecting your privacy in accordance with the Privacy Act1988 (Cth). This Policy describes our policies and practices for collecting, handling, storing, using and disclosing personal information. It also deals with how you can complain about a breach of the privacy laws, access the personal information we hold about you and have that information corrected (where necessary).

What personal information do we collect and hold?

When we conduct Tax Planning, Financial Planning, Lending and Commercial Insurance services, we may ask you for some personal information we require to provide you with the relevant financial services and/or products. We collect your information through our client forms, website enquiries, through written and verbal communication and online data collection. This can include a broad range of information from your name, address, contact details and age to information about your personal affairs including copies of your will, financial statements, health details and insurance information.
We may also collect your information from third parties and associated businesses such as your Lawyer, Mortgage Broker, Bank, Superannuation or Pension provider, Investment provider, Insurance provider, Accountant, Bookkeeper and Payroll. As an integrated financial service provider, we may also share your information internally when it is required for a particular product or service. We note that when we collect this information it may not always have your direct involvement; however we will always seek your permission to do so.

We only collect sensitive information such as health information, criminal history, sexual orientation and bankruptcy record with your agreement and it is necessary for us to do so to provide you with such services as Insurance Advice or Lending Services. We note that we will only collect such personal information if and when we are required to do so for that particular service or product. At times, we may also collect your Tax File Number when providing you with tax and financial products and services. The Privacy (Tax File Number) Rule 2015 issued under s 17 of the Privacy Act 1988 (Privacy Act) regulates how we must manage the use of this information. Also as a TFN recipient (Accounting Division), we must abide by strict policies and procedures when in possession or control of records that contain TFN information.

How do we use your information?

Understanding and meeting our client’s financial needs is a central part of our business. We do this by providing financial products and services under various entities that are offered within the Cambio Group. To do this effectively, we need to collect certain personal information.

We may collect, hold, use and disclose your personal information so we can establish, manage and administer the products and services provided by us, and comply with legal and regulatory obligations. We use your personal information to formulate professional advice, find you the best lending options, act as a key Representative in your financial affairs, analyse your tax planning and distinguish your business risks and needs. We also use your personal information to manage your ongoing requirements and our relationship with you, e.g. assisting with your questions or complaints, arranging for services to be provided by third parties, enhancing our customer service relationship and internal operations (audits, record keeping, staff training and data analytics). This includes contacting you by mail or electronically (unless you tell us you do not wish to receive electronic communications). From time to time we will use your contact details to send you offers, updates, articles, newsletters or other information about products and services that we believe will be of interest to you. We may also send you regular updates by email or by post. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us that you wish to do so.

What if you don’t provide information to us?

It’s your choice whether to provide your personal information. If you do not provide us with some or all the information that we ask for, we might be unable to fulfil your request for a specific product or service or be unable to identify you to protect you against fraud. You can contact us without using your name or by using a pseudonym. However we may need your name or contact details to respond to you and in many cases it will not be possible for us to assist you with your specific needs if you wish to remain anonymous or use a pseudonym.

How do we store and protect your personal information?

We strive to maintain the relevance, accuracy and completeness and currency of the personal information we hold and to protect its privacy and security. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal reporting or document retention requirements. We hold majority of the information we collect from you on Westpac Group owned data centres which are located within Australia or in our privately owned secure database. We utilise Xero as one of our main software providers, Xero utilise top tier third party hosting providers that are located in the U.S. These U.S. data hosting providers do not control, and are not permitted to access or use your personal information, except for the limited purpose of storing the information.

This means that, for the purposes of Australian privacy legislation and Australian users, Xero does not currently “disclose” personal information to third parties located overseas. Another main system we use, AFG Flex utilises cloud storage and IT servers throughout Australia and may also disclosed information to overseas entities that provide support functions to AFG (including USA, Canada, Malaysia, India, Ireland, the United Kingdom and the Philippines). When we utilise IRESS software, IRESS utilise data storage mainly in Australia, however may share storage with members of their corporate group located overseas. Countries include the United Kingdom, Singapore, Malaysia, Hong Kong, South Africa, New Zealand and Canada. IRESS have appropriate controls in place in relation to intra-group transfers. Some information we hold about you will be stored in paper files too. We use a range of physical and electronic security measures to protect the security of the personal information we hold. We maintain physical security over our paper and electronic data and premises, by using locks and security systems. We ensure that your information is safe by having unique user and password precautions in place for online data input and storage systems, operate with a controlled identify and access management system, ensure employees are bound by security conduct and policies as part of their contracts, comprehensive staff straining about privacy content and our requirements and ensure third party agreements include information security measures. As best practice, we regularly review and monitor our internal procedures and policies to ensure our business surpasses industry standards.
We may use technology such as cookies, beacons, tags, scripts, analytics and tracking pixels to collect, store and use anonymous data about how you use our website / mobile technology. This includes your server address, the date and time of your visit, the pages and links accessed the type of browser used and other information about your browsing activities. This data is used to increase functionality and can also enable us to display information and content that is tailored to our understanding of your interests. This information alone cannot be used to discover youridentity.

Will we disclose your personal information to anyone?

We do not sell, trade, or rent your personal information to others. We may disclose your information to entities both within and external to Cambio Group. The entities that we might share your personal information with vary according to the product or service involved, but could include the following:

  • service providers and specialist advisers we engage to provide us with services such asadministrative, audit, financial, insurance or research services, some of whom  may contact you onour behalf
  • other areas and organisations within Cambio Group that provide financial and other services, for reas onable business purposes only
  • insurers, including reinsurance companies and credit providers
  • courts, tribunals and other dispute resolution bodies in the course of a dispute
  • credit reporting or reference agencies or insurance investigators
  • anyone authorised by you or to whom you have provided your consent (either expressly or impliedly), including but not limited to other financial services providers that we may need to deal with on your behalf
  • anyone to whom we, or our service providers, are required or authorised by law to disclose your personal information (for example, law enforcement agencies,
    and national and international government and regulatory authorities including but not limited to the Australian Taxation Office, the Australian Prudential Regulation Authority, the Australian Securities and Investments Commission, the Australian Transaction Reports and Analysis Centre and the United States Internal Revenue Service)
  • other financial services institutions – in order to detect, investigate or prevent actual or potential fraud in connection with the products or services we provide to you.

We may also need to provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers, conduct auditing of your file or generate corporate documents. We may also provide your information to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. We will take all reasonable steps to ensure that they protect your information in the same way that we do. We may provide your information to others if we are required to do so by law or under some other unusual circumstances which the Privacy Act permits. We will not disclose your information to overseas recipients unless we have your permission or request to do so.

How can you check, update or change the information we are holding?

You may ask us for access to your personal information and to correct it at any time. Upon receipt of enough information to allow us to identify the information, we will tell you what personal information we hold about you. We will also correct, amend or delete your personal information if we agree is inaccurate, irrelevant, out of date or incomplete. We do not charge for receiving a request for access to personal information or complying with a correction request.
To access or correct your personal information, please write to Cambio Group, Attention: Privacy
Officer, PO Box 7973 GCMC Qld 9726.

We do not charge for providing access to personal information. In some limited situations, we may need to refuse access to your information or refuse a request for
correction. We will advise you as soon as possible after your request if this is the case and the reasons for our refusal.

What happens if you want to complain?

We welcome your questions and comments about how we manage your privacy. If you have any concerns about whether we have complied with the Privacy Act, the Australian Privacy Principles or this Privacy Policy, please write to our Privacy Officer at Cambio Group, Attention: Privacy Officer, PO Box 7973 GCMC Qld 9726.
We will contact you within 5 days of receiving your compliant to acknowledge it has been received. We may also seek further information and discuss concerns with you as we aim to resolve complaints as soon as possible. We will consider your complaint through our internal complaints resolution process and we will try to respond with a decision within 30 days of you making the complaint. If your complaint is not resolved to your satisfaction by our internal dispute resolution process, you
may take your complaint to the:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Web: www.oaic.gov.au

Your consent

By asking us to assist with your tax planning, financial planning, lending or commercial insurance needs, you consent to the collection and use of the information you have provided to us for the purposes described above. To access Third Party information about you, we will request you to sign a Third Party Authority or confirm your consent to provide an Ethical Request.

About this policy

This Privacy Policy was prepared on the 10th April 2018. We will update this policy when our information handling practices change, and any amendments will apply to the information we hold at the time of the update, this can be at any time. The current version can be requested from any staff member or requested in writing by contacting Cambio Group, Attention: Privacy Officer, PO Box 7973 GCMC Qld 9726.
This policy incorporates the relevant provisions of the Privacy Act and the Australian Privacy Principles.

Terms used such as ‘Cambio Group’, ‘we’, ‘us’ and ‘our’ refer to the group of entities that make up the Cambio brand. This includes Cambio Group Pty Ltd (Accounting), Cambio Group Financial Planning Pty Ltd (Financial Planning), Cambio Group Lending Pty Ltd (Lending) and Cambio Group Insurance Pty Ltd (Commercial Insurance). This policy applies to these entities. Cambio Group Pty Ltd is a CPA Practice ABN 17 125 518 694. Cambio Group Financial Planning Pty Ltd is a Corporate Authorised Representative of Cambio Group AFSL Pty Ltd ABN 90 611 074 241 AFSL 487 125. Cambio Group Lending Pty Ltd ATF Cambio Group Lending Unit Trust ABN 72 690
273109 Australian Credit License 386 147. Cambio Group Commercial Insurance Pty Ltd ABN 57 616 996 564 AFS (Rep 001 252 675) is an Authorised Representative of Australian Insurance Solutions Pty Ltd ABN 64 088 550 074 AFS 264 939.