PRIVACY POLICY
At Paxton Bridge Pty Ltd we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

What information do we collect and how do we use it?
When we provide advice in relation to superannuation, retirement planning, portfolio management, personal risk insurance, managed investments, direct equities and business management and consulting, we ask you for the information we need to understand your personal situation and provide you with advice which meets your needs and objectives.

Our ability to provide you with service and advice that meets your particular needs and objectives may cause us to collect information which may include any or all of the following:

a. Your contact details including names, address, phone and email address;
b. details of your financial needs and objectives and what hardship means to you;
c. personal details including your date of birth, associated entities, visa and residency status, private healthcare and smoking status;
d. your occupation, marital status, financial dependants and identification details such as copies of birth certificate or drivers licenses or other documentation;
e. details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover, general insurance, superannuation and taxation;
f. details of your investment preferences, past experience and aversion or tolerance to risk;
g. details of any professional advisers you engage with;
h. estate planning details;
i. information about your employer, your employment history including future, family commitments including dependents and social security eligibility;
j. your tax file number;
k. personal and family medical history and /or lifestyle pursuits; and
l. your agreement to grant access to a spouse or partner’s information.

We provide the information that you provide to other service providers, such a lawyers, funding specialists, accountants, and the Certainty Advice Group to enable them to execute your requirements and to align to the advice we provide in support of the development of the Advice Map® and Advice Path® tailored to your personal circumstances.

We also use your information to enable us to manage your ongoing requirements and our relationship with you to project manage the advice. We may do so by mail or electronically unless you tell us that you do not wish to receive electronic communications.

From time to time we will use your contact details to send you offers, updates, events, 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.

We may also use your information internally to help us improve our services and help resolve any problems.

Tax File Numbers and Other Identifiers
We will only request or collect a Tax File Number (TFN) from clients if it is necessary and relevant for the services we provide and /or for a purpose which is authorised by taxation, personal assistance or superannuation law. Because financial institutions will often need a client’s TFN (particularly if a deposit account is opened), we may need to collect them from clients.

When requesting a TFN, we will inform you:
• Of the law which authorises us to request or collect it;
• Of the purpose for which it is collected;
• That declining to provide a TFN is not an offence; and
• Of the consequences of declining to provide a TFN (e.g. that money will be withheld from interest and investment income).

What if you don’t provide some information to us?
If you do not provide us with some or all of the information that we ask for, we may not be able to provide comprehensive advice that is specific to your personal circumstances and if information is neglected may be detrimental to your short, medium and long term circumstances.

How do we hold and protect your information?
We strive to maintain the relevance, reliability, accuracy, 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 or ethical reporting or document retention requirements. We maintain a record of your personal profile including details of your objectives, financial situation and needs. We also maintain records of any recommendations made to you.

We hold the information we collect from you in hard and/or soft copies within our business premises and within a cloud based technology provider, such as Dropbox. In some cases, your hard copy file is archived and sent to an external data storage provider for a period of time. We only use storage providers in Australia who are also regulated by the Privacy Act.

We ensure that your information is safe by only allowing personal engaged by Paxton Bridge Pty Ltd to access the information and if accessing via a computer via their individual sign on. We maintain physical security over our paper and electronic data and premises, by using locks and security systems.

Will we disclose the information we collect to anyone?
We do not sell, trade, or rent your personal information to others. We will disclose your information to business or service providers that will support in the execution of your requirements and may need to provide your information to contractors who supply services to us, e.g. to handle mailings on our behalf, external data storage providers, investment providers, personal insurance companies, mortgage brokers or lawyers or to other companies in the event of a corporate sale, merger, reorganisation, dissolution or similar event. However, we will take all reasonable steps to ensure that they protect your information in the same way that we do.

We may also provide your information to others if we are required to do so by law or under some unusual other circumstances which the Privacy Act permits.

We may disclose your information to recipients in overseas countries for the purpose of administration and you should also be aware of the following:

a. your personal information may be accessed by representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;
b. from time to time, information may be loaded to the cloud for storage or access through programs such as Dropbox etc; and
c. it is possible that product and services providers we recommend may outsource functions using overseas contractors or companies that process these services using offshore resources. Where this is a concern to you, we suggest that you carefully read their privacy policy to determine the extent to which they send information overseas.

We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of Australia to provide services. Where this is the case, these service providers have committed to adhere to the Australia Privacy Principles

How can you check, update or change the information we are holding?
Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We will also correct, amend or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.

If you wish to access or correct your personal information please write to the Privacy Officer at Paxton Bridge Pty Ltd via email at [email protected] or telephone (03) 8391 9310.

We do not charge for receiving a request for access to personal information or for complying with a correction request. We do not charge for providing access to personal information.

In some limited cases, 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?
If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy when collecting of handling your personal information, please write to our Privacy Officer at Paxton Bridge Pty Ltd at [email protected] or telephone (03) 8391 9310.

We will consider your complaint through our internal complaints resolution process and we will try to respond with a decision within 45 days of you making the complaint.

Your consent
By asking us to assist with your personal and business financial advice requirements, including insurance, superannuation, estate planning, etc needs, you consent to the collection and use of the information you have provided to us for the purposes described above.

Tell us what you think
We welcome your questions and comments about privacy. If you have any concerns or complaints, please contact the Privacy Officer at Paxton Bridge Pty Ltd via email at [email protected] or telephone (03) 8391 9310.