When you trust us with your personal information, you expect us to protect it and keep it safe. We take this responsibility seriously and we are bound by the Privacy Act 1988 (Cth) (‘Privacy Act’). We will protect your personal information in accordance with the Australian Privacy Principles. These principles govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information. If you would like more information about how we protect your privacy, please contact us.
FLP Financial – Family, Lifestyle and Purpose
Helping you live the lifestyle you want to live.
Privacy
policy
About this policy
This Privacy Policy explains how we manage your personal information. We may provide more details on how we manage your personal information when we collect your personal information.
What is personal information?
Personal information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information.
What kinds of personal information do we collect and hold?
As part of building our relationship and understanding of you and your personal circumstances to provide you personalised advice, we need to collect personal information. The personal information we are likely to collect, and hold includes:
- Your name, address and contact details
- Your date of birth, gender and tax residency
- Details about members of your family and related entities
- Your occupation, employer and educational qualifications
- Government identifiers such as your tax file number, Centrelink identifier, director identification number, Australian business number, identification document numbers and photographs
- Details about your current and/or future financial circumstances, including assets, liabilities, income and expenses, bank details, goals and strategies, risk tolerance, insurance and estate planning arrangements
- Recordings of our discussions either in audio or video format (voice and image) through telephone (landline or mobile services) or digital (e.g. Zoom video communications, with your consent
- Your signature either in hard copy or digitally
The information that we seek to collect about you will depend on the products or services that we provide.
When we communicate with you via telephone services (landline or mobile), in electronic format, email, through our Client Portal, digitally or via social media platforms, we may keep records of your communication with us, acknowledgements, signatures (including digital), video and or audio through audio and/or video conferencing platform recordings (where you verbally consent).
If you apply for insurance, we may collect information about what is being insured, the beneficiaries along with your health and financial situation, depending on the type of insurance.
Where we arrange finance or credit on your behalf, in addition we may ask for information about your finance needs, in history borrowing capacity, council rate notices, contracts of sale and property insurance.
Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints you make and, if you make an insurance claim, collecting additional information to assess the claim.
The collection of sensitive information is restricted by the Privacy Act. This includes information about your religion, racial or ethnic origin, political opinions, criminal record and sexual orientation. It also includes health information and biometric information.
Generally, we only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection. For example, we may collect health information about you to process a claim under an insurance policy or collect voice biometric information to verify your identity or authorise transactions.
When we communicate with you in electronic format, via email, our client portal, social media platforms, we may keep records of your communication with us. These records may extend to acknowledgements, signatures (including digital), video and audio through video conferencing platform recordings (obtained with your separate consent).
When we communicate with you via telephone services (landline or mobile), in electronic format, email, through our Client Portal, digitally or via social media platforms, we may keep records of your communication with us, acknowledgements, signatures (including digital), video and or audio through audio and/or video conferencing platform recordings (where you verbally consent).
If you apply for insurance, we may collect information about what is being insured, the beneficiaries along with your health and financial situation, depending on the type of insurance.
Where we arrange finance or credit on your behalf, in addition we may ask for information about your finance needs, in history borrowing capacity, council rate notices, contracts of sale and property insurance.
Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints you make and, if you make an insurance claim, collecting additional information to assess the claim.
The collection of sensitive information is restricted by the Privacy Act. This includes information about your religion, racial or ethnic origin, political opinions, criminal record and sexual orientation. It also includes health information and biometric information.
Generally, we only collect this sort of information if it is necessary to provide you with a specific product or service and you have consented to that collection. For example, we may collect health information about you to process a claim under an insurance policy or collect voice biometric information to verify your identity or authorise transactions.
When we communicate with you in electronic format, via email, our client portal, social media platforms, we may keep records of your communication with us. These records may extend to acknowledgements, signatures (including digital), video and audio through video conferencing platform recordings (obtained with your separate consent).
Do I have to provide you my full information?
You have the right to remain anonymous and or not to provide us with any or all of your personal information. However, we specialise in providing personal financial advice and developing strategies that consider your personal circumstances, objectives and needs. Where we do not have the necessary information to ensure our advice is in your best interests, for example if it is inaccurate or incomplete, we may not be able to provide you with advice and or services and the advice may not be appropriate given you full needs and circumstances.
Where you provide limited information, we will make you aware of any limitations or risks we can identify given any limited advice we may provide.
Where you provide limited information, we will make you aware of any limitations or risks we can identify given any limited advice we may provide.
Why do we collect, hold, use and disclose personal information?
We collect, use, hold, and disclose personal information to provide you with products and services . This includes:
- Checking whether you are eligible for the product or service
- Identifying you
- Assisting you where online applications
- Providing the product or service
- Managing our product or service, such as invoicing or client surveys or with your consent passing your information to other specialist advice providers you agree to engage.
- Assisting you with your questions and requests
- Communicating with you
- Managing fraud and security risks (including using your mobile phone number and any other relevant identifier for two-factor authentication purposes)
We may also use your information to comply with legislative or regulatory requirements in any jurisdiction, prevent fraud, crime or other activity that may cause harm in relation to our products or services and to help us run our business.
We may also use your information to internally help us improve our services with you.
We may also use your information to internally help us improve our services with you.
How do we collect personal information?
We collect most personal information directly from you. For example, we will collect your personal information when you apply for or use a product and/or service, or when you talk to us in person or on the phone.
We also collect information from you electronically. For instance, when you visit our website or if you send us electronic correspondence (see “Do we collect personal information electronically?”).
Sometimes we collect personal information about you from other people or organisations. This may happen without your direct involvement. For instance, we may collect personal information about you from:
- Publicly available sources of information, such as public registers
- Your representatives (including your legal advisor, accountant, mortgage broker, executor, administrator, guardian, trustee, or attorney)
- Your employer
- Other organisations, who jointly with us, provide products or services to you
- Commercial information service providers, such as companies that provide fraud prevention reports
- Insurers, re-insurers and health care providers.
- Banks, financial institutions, mortgage intermediaries, and other financial product providers;
- Electronic sources, such as you visiting our website and or accessing our client portal.
What laws require or authorise us to collect personal information?
We are required or authorised to collect:
- Certain identification information about you as outlined in the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1)
- Your Tax File Number, if you choose to provide it as specified in the Income Tax Assessment Act 1936 (Cth)
- Certain information in relation to your application if you have applied for insurance as required by the Insurance Contracts Act 1984 (Cth).
How do we hold personal information?
We have implemented security measures on all computers, programs and mobile devices accessing our IT systems and data backups. We have controlled access to our principal place of business, secure paper files, provide employee training and clauses in employee and contractor agreements regarding confidentiality and destroying and de-identifying data when it is no longer required or inadvertently provided by a third party.
Unfortunately, the transmission and storage of any data, including your personal information, over the internet or within cloud-based storage systems may not be completely secure. Whilst we will endeavour to protect your personal information, it is possible that third parties, outside our control, may be able to access, obtain or intercept transmissions or private communications without our knowledge or consent. As a result, we cannot ensure the security of data, and any transmissions or electronic communications between us knowing this risk. Just as we take reasonable steps to secure all computing devices used in connection with our website, software, system and services, we recommend you do the same and ensure any internet accessible storage or portable devices, such as your mobile phone are secure.
If you have reason to believe that your interaction with us is no longer secure, for example, if you fear the security of any account, please change your passwords and contact us immediately.
Unfortunately, the transmission and storage of any data, including your personal information, over the internet or within cloud-based storage systems may not be completely secure. Whilst we will endeavour to protect your personal information, it is possible that third parties, outside our control, may be able to access, obtain or intercept transmissions or private communications without our knowledge or consent. As a result, we cannot ensure the security of data, and any transmissions or electronic communications between us knowing this risk. Just as we take reasonable steps to secure all computing devices used in connection with our website, software, system and services, we recommend you do the same and ensure any internet accessible storage or portable devices, such as your mobile phone are secure.
If you have reason to believe that your interaction with us is no longer secure, for example, if you fear the security of any account, please change your passwords and contact us immediately.
What is a Notifiable Data Breach?
The Privacy Act includes a Notifiable Data Breaches (NDB) scheme, which requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain breaches likely to cause harm and recommend steps you can take to limit the impacts of a breach (for example, a password change).
If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.
If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.
Who do we disclose your personal information to, and why?
- We may provide personal information about our clients to organisations outside of FLP Licence Holdings Pty Ltd and FLP Financial Pty Ltd. We only authorise our service providers to use or disclose your personal information for the specific role we ask them to perform, under your direction.
- Generally, we disclose personal information to organisations that help us with our business. These may include:
- Our agents, contractors and external service providers (for example, mailing houses and technology service providers)
- Paraplanning service providers
- Insurers, re-insurers and health care providers
- Payment systems operators (for example, merchants receiving card payments)
- Other organisations, who jointly with us, provide products or services to you
- Financial services organisations, including banks, lenders, superannuation funds, stockbrokers, custodians, fund managers and portfolio service providers
- Our representatives (including legal advisors, compliance advisors or auditors)
- Your representatives (including your legal adviser, accountant, mortgage broker, property valuer, guarantors, (including prospective) family members, executor, administrator, guardian, trustee, or attorney)
- Any government and regulatory bodies required by law, to prevent fraud or other misconduct
- IT and data security service providers
- External dispute resolution schemes
- Regulatory bodies, government agencies and law enforcement bodies in any jurisdiction. Other third party organisations, who jointly with us, provide products or services to you or with whom we partner to provide products or services to you. Information that we provide to third parties will be handled in accordance with their privacy policy, which is further detailed below.
- You may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances
- We are otherwise permitted to disclose the information under the Privacy Act.
Do we use cloud base services and disclose personal information overseas?
We may store your information in cloud or other types of networked or electronic systems. Electronic or networked systems can be accessed from various countries via an internet connection, so it’s not always practicable to know in which country your personal information may be held.
We use administrative services based the Philippines. This team is directly trained and managed by us. They assist our local team in the provision of administrative services and this team have access to most of systems detailed below.
We may disclose your personal information overseas. We engage the services of these providers, who may be based both in Australia and or overseas. Some of these providers may have all or part of their operations overseas, store data overseas, access services overseas or utilise third parties who are overseas.
FLP Financial maintains an Outsourcing Policy when selecting service providers to ensure quality providers are selected and that their privacy policy aligns with our philosophy of protecting our clients’ privacy.
We provide a list below of the third-party service providers, third-party applications or cloud base applications we may use, including links to their privacy policy and their data centre locations where available.
We use administrative services based the Philippines. This team is directly trained and managed by us. They assist our local team in the provision of administrative services and this team have access to most of systems detailed below.
We may disclose your personal information overseas. We engage the services of these providers, who may be based both in Australia and or overseas. Some of these providers may have all or part of their operations overseas, store data overseas, access services overseas or utilise third parties who are overseas.
FLP Financial maintains an Outsourcing Policy when selecting service providers to ensure quality providers are selected and that their privacy policy aligns with our philosophy of protecting our clients’ privacy.
We provide a list below of the third-party service providers, third-party applications or cloud base applications we may use, including links to their privacy policy and their data centre locations where available.
- SuiteFiles (Document Storage)
- DASH (Financial Planning Software)
- Astute Wheel and Astute Wheel Estate Planning (Financial Planning Software)
- Xero (Accounting Software)
- Sharepoint (Cloud File Storage)
- NowInfinity (Document Generation Platform)
- DocuSign (Electronic Signature and Document Storage Application)
- Microsoft Office 365 (Email, Calendar, Cloud File Storage and Business Applications)
- BGL (SMSF Software)
- Morningstar (Portfolio Research Tool and Finametrica Risk Profiling Tool)
- Practice Ignition (Payment Software)
- Zapier (Automation Tool)
- Keap (Sales and Marketing Automation Platform)
- Zoom (Online Meeting Assistant)
- Teams (Online Meeting Assistant and Calendar)
- Chantwest (Superannuation Research and Consultancy)
- Reach (Financial Planning Software and Modelling Tool)
- TIQK (Portfolio Reporting and Financial Planning Software)
- Omnilife (Life Insurance Company)
- Calendly (Scheduling Software, Calendars, and Online Meetings)
Overseas organisations may be required to disclose information we share with them under a foreign law.
Do we use or disclose personal information for marketing?
We may use your personal information to offer you products and services we believe may interest you. We may send you direct marketing communications such as offers, updates, events, articles or newsletters. We will always give you the option of electing not to receive any of these communications in the future by notifying us or unsubscribing at any time.
Do we collect personal information electronically?
We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications, or using our client portal.
Each time you visit our website, we collect information about your use of the website, which may include the following:
Each time you visit our website, we collect information about your use of the website, which may include the following:
- The date and time of visits
- Which pages are viewed
- How users navigate through the site and interact with pages (including fields completed in forms and applications completed)
- Location information about users
- Information about the device used to visit our website
- IP addresses
We use technology called cookies when you visit our site. Cookies are small pieces of information stored on your hard drive or in memory. They can record information about your visit to the site, allowing it to remember you the next time you visit and provide a more meaningful experience.
One of the reasons for using cookies is to offer you increased security. The cookies we send to your computer cannot read your hard drive, obtain any information from your browser or command your computer to perform any action. They are designed so that they cannot be sent or retrieved by any another website.
We won’t ask you to supply personal information publicly over Facebook, Twitter, or any other social media platforms that we use. Sometimes we may invite you to send your details to us via private messaging, for example, to answer a question. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions.
One of the reasons for using cookies is to offer you increased security. The cookies we send to your computer cannot read your hard drive, obtain any information from your browser or command your computer to perform any action. They are designed so that they cannot be sent or retrieved by any another website.
We won’t ask you to supply personal information publicly over Facebook, Twitter, or any other social media platforms that we use. Sometimes we may invite you to send your details to us via private messaging, for example, to answer a question. You may also be invited to share your personal information through secure channels to participate in other activities, such as competitions.
Can I gain access to and correct my personal information?
You can request access to the personal information we hold about you. You can also ask for corrections to be made. To do so, please contact us.
There is no fee payable for updating or correcting your personal information. Should you request access to your personal information, a reasonable cost may apply. This cost may apply to the time it takes to locate, compile and supply the information to you.
There are some circumstances in which we are not required to give you access to your personal information. If we refuse to give you access to or to correct your personal information we will give you a notice explaining our reasons, except where it would be unreasonable to do so.
If we refuse your request to access or correct your personal information, we will also provide you with information on how you can complain about the refusal.
There is no fee payable for updating or correcting your personal information. Should you request access to your personal information, a reasonable cost may apply. This cost may apply to the time it takes to locate, compile and supply the information to you.
There are some circumstances in which we are not required to give you access to your personal information. If we refuse to give you access to or to correct your personal information we will give you a notice explaining our reasons, except where it would be unreasonable to do so.
If we refuse your request to access or correct your personal information, we will also provide you with information on how you can complain about the refusal.
How long do we keep your personal information?
We will keep your personal information for as long as you continue to be client of the FLP Financial.
We also generally retain your personal information for at least seven years after you stop being a client. This is a legal requirement that allows us to demonstrate we have complied with relevant financial service laws and respond to any questions or complaints.
We also generally retain your personal information for at least seven years after you stop being a client. This is a legal requirement that allows us to demonstrate we have complied with relevant financial service laws and respond to any questions or complaints.
Who does the European Union General Data Protection Regulation (GDPR) apply to?
If you are a resident of or a business ‘established’ in a country that is a member of the European Union Economic Area (the EU and Norway, Lichtenstein and Iceland), you are entitled to additional protections provided by the GDPR, other than the protections already afforded to you under the Privacy Act.
In certain circumstances, this may include, but is not limited to, the right to:
In certain circumstances, this may include, but is not limited to, the right to:
- Have your personal information erased
- Access your personal information in an electronic and portable format
- Restrict, object or withdraw your consent to the processing of your personal information
If you require more information about your eligibility to and or these rights, please let us know.
How we resolve your privacy concerns and make you aware of your rights?
If you are concerned about how your personal information is being handled or if you have a complaint about a breach of the Australian Privacy Principles, please contact us.
We are committed to resolving complaints within a fair and reasonable timeframe. Wherever possible, complaints will be resolved promptly at the first point of contact. Where this is not possible, we aim to resolve complaints within 30 calendar days as explained fully in our complaints policy can is also accessible from our website, www.flpfinancial.com.au.
If you are unhappy with our response, there are other bodies you can go to including the Australian Financial Complaints Authority and or the Office of the Australian Information Commissioner.
Office of the Australian Information Commissioner
Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can be contacted at:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au www.oaic.gov.au
We are committed to resolving complaints within a fair and reasonable timeframe. Wherever possible, complaints will be resolved promptly at the first point of contact. Where this is not possible, we aim to resolve complaints within 30 calendar days as explained fully in our complaints policy can is also accessible from our website, www.flpfinancial.com.au.
If you are unhappy with our response, there are other bodies you can go to including the Australian Financial Complaints Authority and or the Office of the Australian Information Commissioner.
Office of the Australian Information Commissioner
Under the Privacy Act you may complain to the Office of the Australian Information Commissioner about the way we handle your personal information. The Commissioner can be contacted at:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au www.oaic.gov.au
Contact us
Our Privacy Officer can also be contacted in relation concerned by writing to:
Attention: Privacy Officer
FLP Licence Holdings Pty Ltd
Suite 1, Level 1, 333 Whitehorse Road
Balwyn, Vic, 3103
You can also call or visit our offices in person:
Phone: 03 9816 4200
In-person: Suite 1, Level 1, 333 Whitehorse Road, Balwyn, VIC 3103
Links to other sites
Where our website may provide links to other sites for you to access, you should be aware that these other sites are not subject to this Privacy Policy or our privacy standards and our procedures. You will need to contact them directly to ascertain their privacy standards.
Changes to our Privacy Policy
We may change the way we handle personal information from time to time for any reason. If we do so, we will update this Privacy Policy and we encourage you to review this policy periodically. While we seek to maintain the currency of the third-party links in this policy, third party privacy policies may change prior to our own review of our policy. We therefore encourage you to check any link is the most up to date privacy policy from any of our listed third-party providers.
Providing us information about your family members
Please make anyone in which you have provided their personal information to us aware of this Privacy Policy. Where you have provided personal information about children under the age of 16, as their parent or guardian in this capacity you have given your consent for us to hold this information. If you are providing us with another person’s sensitive information, you must first obtain their consent to sharing it with us and their consent to us collecting and handling their sensitive information in accordance with this Privacy Statement
Client consent
By asking us to assist with your financial needs, you consent to the collection and use of your personal information you have provided us with for the purposes described in this policy.
If you do not agree with the terms of this Privacy Policy, please do not use the website or otherwise provide us with your personal information.
If you do not agree with the terms of this Privacy Policy, please do not use the website or otherwise provide us with your personal information.
Meaning of words
We, us or our means:
FLP Licence Holdings Pty Ltd | ABN 92 637 432 994 | Australian Financial Services Licence no 520431.
FLP Financial Pty Ltd | 42 637 716 664 | Corporate Authorised Representative no 1282360
Version
January 2024