Privacy Policy

Australia

Updated: 19 December 2016

This Privacy Policy applies to information collected in Australia by Fidante Partners Limited ABN 94 002 835 592, Fidante Partners Services Limited ABN 44 119 605 373 and/or Challenger Limited ABN 85 106 842 371 and their related bodies corporate ('Fidante Partners' or 'we'). It outlines how we manage your personal information and safeguard your privacy. At Fidante Partners, we understand your concerns about privacy and the security of your personal information. Your privacy is important to us and we are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles ('APPs'). We are committed to protecting the personal information that we hold about you.

If you are seeking information on  Fidante Partners Europe (our United Kingdom based business), please refer to the 'United Kingdom' section of this policy which sets out how personal information is collected and handled by Fidante Partners Europe.

1. What personal information is collected?

Fidante Partners collects personal information that is reasonably necessary for us to provide you with financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:

  • information you give us when you request a product or service from us. This information may include your name, date of birth, address, contact details and relevant identification documents;
  • communications between us and your financial, legal or other adviser, including your broker or other agent;
  • communications between us and associations that you are a member of and with which we have an affiliation;
  • transactional information about the use of a product if you have or had a product with us;
  • financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
  • in some cases sensitive information obtained with your consent or otherwise where required or permitted by law (e.g. in relation to anti-money laundering laws)
  • information such as your name, address and date of birth where an investor or borrower has listed you as a beneficial owner or other related party in connection with the investment or loan;
  • information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used). This information will be anonymous unless you are a registered user of the relevant Login Site (AdviserOnline or InvestorOnline). See the "Use of our website" section of this policy for further information.

2. How personal information is collected?

Fidante Partners collects personal information in a number of ways including:

  • directly from you (including via your financial, legal, or other adviser including your broker or other agent), such as when you provide the information by phone, email or in an application form, or when you access a user account for one of our login sites, or when you participate in a survey, promotion or competition;
  • from other Fidante Partners group companies where permitted by law;
  • from third parties such as your financial adviser, lawyer or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorise us to do so;
  • from an investor or borrower where they have nominated you as a beneficial owner or other related person in connection with the investment or loan;
  • from publically or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws)

3. What if you do not provide certain information?

If you provide us with an incomplete application, we may not be able to provide you with the product or service until the application is complete.

If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.

If you choose not to disclose your Tax File Number ('TFN'), TFN exemption or Australian Business Number ('ABN'), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you.

If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process transactions requested.

4. How do we use and disclose your personal information?

Fidante Partners may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:

  •  to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your application for products and services, such as beneficial owners, where applicable);
  •  to process your applications for our products and services;
  •  to administer and manage the provision of our products and services;
  •  to respond to queries, complaints or to provide you with our general customer services;
  • to provide your nominated financial adviser or other agent with details of your investment;
  •  to confirm your membership of an association with which we have an affiliation;
  •  to assess credit which you seek from Fidante Partners loan programs and to administer any credit a Fidante Partners loan program provides, including providing your nominated mortgage broker with details of your loan;
  •  to provide you with offers of other Fidante Partners products or services and to improve and personalise our products and services;
  •  to provide you with offers from organisations with whom we have an alliance;
  • to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
  • to comply with Fidante Partners' risk management policies and procedures;
  •  to conduct product and market research;
  •  to train our staff; or
  •  if attending our offices in person, to assist Fidante Partners in providing a safe and secure environment for employees and visitors.

We may disclose your personal information to;

  • your financial, legal or other adviser, including your broker or other agent;
  • professional service firms that provide services to us, such as, legal, audit or data/ information services;
  • electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment/product) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws);
  • our related companies and/or the investment manager that may also provide you with a financial product or financial service; or
  • organisations with which we have an association and you are a member; and otherwise in accordance with this Privacy Policy and the APPs. 

5. Overseas disclosures

Fidante Partners does not disclose personal information collected in Australia to recipients in foreign countries. However, if you are investing with Fidante Partners Europe (which engages UK-based investment managers to manage funds) then your personal information may be passed to Fidante Partners Europe for the purposes set-out in the 'United Kingdom' section of this policy. If applicable, please read that section of the policy to ensure you are familiar with its terms and how your personal information may be used or disclosed.

In some cases, Fidante Partners may utilise 'Cloud' storage solutions for data storage purposes, and the relevant servers may be located overseas. Please see 'Storage and security of information' section of this policy for further details. 

6. Use of service providers

We may contract out some of our administrative and support functions such as mailing, settlement services, document and data storage, background checking or identity verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.

7. Keeping us up-to-date

Personal information such as contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment/product (such as a beneficial owner), and the information is no longer current, you must provide up-to-date information. Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form (such as a change of bank account from which direct debits are deducted). Fidante Partners is unable to change any account details or provide any policy specific information through email. To change your contact information please download and complete the Change of details form (go to 'Investment Managers' then select 'Forms').

Please see the 'Contacting us' section of this policy if you would like to request an update to the personal information we hold about you.

8. Storage and security of information

Fidante Partners stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes) and Fidante Partners maintains effective control of the information under contractual arrangements.

We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure.

Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.

9. Openness

This Privacy Policy sets out Fidante Partner's policies on the management of personal information and is made freely available on our website, or in hardcopy if requested.

10. Access and correction

Generally, Fidante Partners will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

  • it would be unlawful to provide the information;
  • providing access would be likely to prejudice an investigation of possible unlawful activity;
  • the information is relevant to legal proceedings and would not be accessible in the normal discovery process;
  • giving access would have an unreasonable impact on the privacy of other individuals;
  • it would pose a serious and imminent threat to the life or health of any individual; or
  • the request is frivolous or vexatious.

If a request for access would divulge a commercially sensitive decision-making process, then Fidante Partners may provide an explanation rather than direct access to the information.

If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Fidante Partners disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.

Please see the 'Contacting us' information below if you would like to request an update or seek access to the personal information we hold about you.

11. Identifiers

Fidante Partners does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier for individuals. Instead, Fidante Partners issues numbers such as investor numbers and account numbers are used to identify individuals and the Fidante Partners products and services they obtain.

12. Anonymity and pseudonymity

Given legal requirements on financial institutions to identify their customers, in most situations Fidante Partners is unable to allow you to transact with it on the basis of anonymity (including the use of a pseudonym). Access to the Fidante Partners public website, and some other interactions with Fidante Partners may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.

13. Direct marketing

Fidante Partners will not use your personal information for direct marketing purposes unless;

  • we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
  • we have provided you with a simple means to 'opt-out' from receiving direct marketing; and
  • we have not received such a request from you.

Fidante Partners will not use any sensitive information collected from you for direct marketing purposes. To opt-out of receiving direct marketing, please contact us (see 'Contacting us' section below). 



14. Use of our website


We will collect some information from you when you visit the Fidante Partners website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.

The only personal information which we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email.  When you access a user account for one of our login sites (AdviserOnline or InvestorOnline), we may subsequently collect information about your use of the site. This may be used for direct marketing purposes or to help us understand whether you may benefit from additional support (e.g. we may contact you to determine whether you need assistance in finalising or progressing incomplete applications or quotes). You should refer to the 'Login Sites' section below.

Login sites

If you access one of our login sites (AdviserOnline and InvestorOnline), cookies may also store information related to your session and visit duration, which can be linked back to your login identification. For more information on cookies, please refer to the 'Cookies' section below.

Because our login sites have access restricted to users with an account, you will be required to use your secure login. Unique identifiers (such as your login identification) are collected from website visitors to verify the user's identity.

Unique identifiers may also be used to store information about preferences, to enable dynamic display of the site according to your preferences when you return.

Fidante Partners uses the data collected for statistical analysis and business purposes. We may also use your personal information to contact you via email or phone to tell you about other products or services that we think may be of interest to you, or seek feedback relating to improving the customer experience. If you do not wish to be contacted for these purposes, you can opt-out by contacting us (see the 'Contacting us' section of this policy). The data is accessible only to authorised staff. Information which is automatically collected may be published internally as aggregated (de-identified) information to assist with improving the services offered by Fidante Partners through the website.

Website analytics

Fidante Partners uses third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information. For more information on our web analytics providers, please visit Omniture and Google Analytics sites.

Online advertising

Fidante Partners uses several advertising companies for our online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements and if you have visited our website through an online advertisement. None of the information collected by the advertising companies will personally identify you. Visit Sizmek's website to view their privacy policy for more information on advertising cookies and how to opt out of Sizmek's targeted advertising from the use of these cookies.

Fidante Partners uses Google AdWords Remarketing to trigger advertisements across the Internet. AdWords remarketing will display advertising based on what parts of our website have been visited by placing a cookie on your machine. This cookie does not identify you as an individual. Google AdWords Remarketing allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google's Ads Preferences Manager  for more information on the Google AdWords Remarketing cookie and how to opt out from the use of these cookies.

Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies you may not be able to use some areas of our websites.

Clear gifs

Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.

15. Employment opportunities at Fidante Partners

If you are seeking employment or contracting opportunities with us, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.

We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf, including overseas agencies where you have prior residential or working history in those locations.  For some roles, we may request that candidates complete psychometric testing to assist in candidate selection. This may involve you taking an ability assessment or providing information about your work style and preferences.  Testing is undertaken via our service provider's online system, with results provided to Fidante Partners. Results are also stored by the provider in its Australian data centre and are backed-up in its UK data centre.

If you complete psychometric testing but are not subsequently employed by us, you may contact us at any time to request that your results are de-identified by Challenger and/or our third party provider, and we will take reasonable steps to comply with such requests.

16. Contacting us

If you would like more information about how we manage your personal information, our Client Services team is available Monday to Friday, from 8am to 6pm EST, and can be contacted on 13 51 53 or write to us at the following address:

The Privacy Officer
Level 2, 5 Martin Place
Sydney NSW 2000

Or send an email to: privacy@fidante.com.au.

17. Complaints about your privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following;

  • Your complaint should be made in writing to the Privacy Officer (via post or email)
  • We will attempt to respond within 30 days from receipt of your request
  • If you feel your concerns have not been resolved, you may take them to an external dispute resolution service (such as the Financial Ombudsman Service or Credit Ombudsman Service Limited)
  • The complaint may be taken to the Office of the Australian Information Commissioner (OAIC)

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au


18. Changes to our Privacy Policy

Fidante Partners may make changes to this Privacy Policy from time to time for any reason and we will update the website in a timely manner.

United Kingdom

Updated: 19 December 2016

This policy (together with the terms of use and any other documents referred to in it) sets out the basis on which any personal data Fidante Partners Europe Limited ('Fidante Partners Europe') collects from you, or that you provide to Fidante Partners Europe, will be processed by Fidante Partners Europe. Please read the following carefully to understand Fidante Partners Europe's views and practices regarding your personal data and how Fidante Partners Europe treats it.

For the purposes of the UK Data Protection Act 1998 (the 'Act'), the data controller is Fidante Partners Europe.

1.  Information Fidante Partners Europe may collect from you

Fidante Partners Europe may collect personal data about you, directly (where you are asked to provide the data), indirectly or implicitly when you communicate with Fidante Partners Europe in person, in writing, by e-mail, by SMS, by fax, when you use this website or by telephone. Fidante Partners Europe will, however, only use this personal data in accordance with the purposes set forth in this privacy policy and is committed to protecting and respecting your privacy.

Fidante Partners Europe may collect and process the following data about you:

  • Information that you provide by filling in forms. This includes information provided at the time of subscribing to any newsletter services via this website, e-mail, SMS, telephone or otherwise.
  • If you communicate with Fidante Partners Europe, it may keep a record of that correspondence.

2.  Sensitive data

Fidante Partners Europe does not seek to collect sensitive personal data (such as data revealing political opinions, religious beliefs or data concerning health or sex life). If Fidante Partners Europe does seek to collect such data, your prior consent will be sought.

3.  Where Fidante Partners Europe stores your personal data

The data that Fidante Partners Europe collects from you may be transferred to, and stored at, a destination inside or outside the European Economic Area ("EEA"). It may also be processed by staff operating inside or outside the EEA who work for Fidante Partners Europe, one of its associates or for one of its or its associates' agents. Such staff may be engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Fidante Partners Europe will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although Fidante Partners Europe will do its best to protect your personal data, Fidante Partners Europe cannot guarantee the security of your data transmitted to its website; any transmission is at your own risk.

4.  Purposes of processing

Fidante Partners Europe uses information held about you in the following ways:

  • To provide you with information including newsletters about products or services that you request from Fidante Partners Europe or products or services offered by Fidante Partners and/or its associates which Fidante Partners Europe feels may interest you, where you have consented to be contacted for such purposes.
  • To notify you about changes to products or services.

If you are an existing client, Fidante Partners Europe will only contact you by electronic means (e-mail or SMS) with information about products and services offered by Fidante Partners Europe and/or its associates similar to those which were the subject of a previous sale to you.

If you are a new client, and where Fidante Partners Europe permits any of its associates to use your data, Fidante Partners Europe (or they) will contact you by electronic means only if you have consented to this.

By providing your residential address, e-mail address, fax number or telephone number to Fidante Partners Europe you consent to receiving such communications by such medium.

If there is any change to your personal data which you have submitted to Fidante Partners Europe, please contact Fidante Partners Europe at the address below so that it may ensure its records of your personal data are accurate and, where necessary, kept up to date. Personal data shall not be retained on record for longer than is necessary for the purpose it is held.

5.  Disclosure of your information

Fidante Partners Europe may disclose your personal information to third parties if (i) substantially all of Fidante Partners Europe's assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or (ii) Fidante Partners Europe is under a duty to disclose or share your personal data in order to comply with any legal obligation (whether in your jurisdiction or elsewhere) or in order to enforce or apply the terms of use and other agreements, or to protect the rights and property of Fidante Partners Europe.

6.  Your rights

You have the right to ask Fidante Partners Europe not to process your personal data for the purposes listed in the Purposes Of Processing section above. You can exercise your right to prevent such processing (i) by contacting Fidante Partners Europe at the address given below; or (ii) for the purpose of providing newsletter(s) to you either by contacting Fidante Partners Europe at the address given below.

7.  Cookies

See the Australian privacy policy for information regarding the treatment of cookies.

8.  Access to information

Under the Act (and/or other relevant legislation), you have the right to access information held about you. Your right of access can be exercised in accordance with the Act (and/or other relevant legislation). Any access request may be subject to a fee of up to £10 to meet Fidante Partners Europe's costs in providing you with details of the information it holds about you.

9.  Amendments

Fidante Partners Europe reserves the right to modify sections of this privacy policy at any time.

10.  How to contact Fidante Partners

If you have any questions about this privacy policy, Fidante Partners Europe's data processing activities, or you wish to access or update the information held about you, you may contact Fidante Partners Europe at Fidante Partners Europe Limited, 1 Tudor Street, London EC4Y 0AH.