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Introduction

Collins House Advisory Pty Ltd, ACN 637 292 490, ABN 17 637 292 490, Collins House Private Wealth ACN 166 528 758 and Collins House Online Investment Services Pty Ltd ACN 620 936 567 ATF CHOIS Trust ABN 30 492 640 027, have adopted the Collins House Privacy Policy and this document outlines how we handle the personal information that we collect about clients and prospective clients.

We respect the confidentiality of your information and take your privacy seriously, abiding by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).

When we request personal information from you, we explain why we need it, how we will use it and who we may share it with. Collins House Online Investment Services Pty Ltd (Collins House Online) is a Corporate Authorised Representative of Collins House Private Wealth Pty Ltd AFSL 449146, and provides scaled Online Independent Investment Advice for

  • Investors looking to save for a specific purpose such as saving for a home deposit
  • Investing as an alternative to Super or
  • Investing for the benefit of children and grandchildren.

Collins House Advisory Pty Ltd, ACN 637 292 490, ABN 17 637 292 490 trading as Collins House Private Wealth is also a Corporate Authorised Representative of Collins House Private Wealth Pty Ltd, Australian Financial Services Number 449146, provides independent investment, financial planning, and accounting advice, as well as support services, based on our client’s best interest.

The types of independent investment, financial planning, and accounting advice that Collins House Private Wealth provide includes:

  • Investment advice in relation to portfolio construction and investment selection, execution, monitoring, rebalancing and reporting
  • public offer superannuation fund recommendations
  • retirement income product recommendations
  • other investment product recommendations including listed and unlisted securities
  • self- managed superannuation funds (SMSF) advice and administration
  • life insurance and tax paid bond recommendations
  • recommendations on managed funds, shares, ETFs, fixed interest and cash
  • property recommendations through a licenced Real Estate Agent
  • establishment of companies, family trusts, unit trusts, partnerships and SMSFs
  • income tax returns for companies, trusts, partnerships, SMSFs and individuals
  • preparation of statutory accounts and assistance with administration of SMSFs
  • preparation of statutory accounts for companies, trusts, and partnerships

To effectively deliver these services, we need to collect detailed personal information from clients and potential clients.

Personal information, for the purposes of this Privacy Policy, is any information that could identify you or perhaps be used to establish your identity.

Any information we hold is governed by the most current Collins House Privacy Policy.

The policy is publicly available via our website www.collinshouse.com or you can contact us as above to obtain a hard copy of the policy.

This policy is reviewed from time to time to take account of new laws and technology and changes to our operations and practices, and to make sure it remains appropriate to the changing environment.


Your personal information

Collins House Online and Collins House Private Wealth collects, holds, uses and discloses clients’ personal information so we can establish, manage and provide scaled online independent investment, in the case of Collins House Online and comprehensive Independent Investment and Financial Planning Advice as well as accounting advice and support services, in the case of Collins House Private Wealth.

We may also use and disclose your information for purposes related to those mentioned above, such as arranging for a Licenced Estate Agent to provide us with a property appraisal etc., or to an insurance company to arrange life insurance cover, where appropriate. In addition to the above, some laws require us to collect personal information.

These include the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth), the National Consumer Credit Protection Act 2009 (Cth) and the U.S Foreign Account Tax Compliance Act.

We will not use your personal information for direct marketing without your permission, other than in the normal course of corresponding with our clients.

Where we provide your personal information to a third party for the purposes of identifying you when we, for example, open a bank account, or share a trading account, purchase an investment, assist you when entering into a lease, or assist you comply with your income tax obligations etc. We do not expect those third parties to use your personal information to Direct Market to you, however we cannot prevent them from doing so.

If you chose not to provide us with the information that we request, we may be unable to assist you with the matter at hand. For example, if you are seeking investment, financial planning, or accounting advice we may not be able to properly analyse your personal circumstances, objectives, and needs, which may result in Collins House Private Wealth declining to assist you.

In a similar manner, Collins House Online may not be able to provide you with a scaled online Statement of Advice (SOA) unless you provide us with sufficient information.

We may ask for a range of personal information or your authority for us to obtain the same such as, but is not limited to; your full name and any other names that you may be known as, your residential, business and post addresses where appropriate, your date of birth, your telephone numbers and email contact details, your income etc.

And in the case of Collins House Private Wealth, additional information such as but not limited to statements of assets and liabilities, bank account balances, life and other insurance details, copies of income tax returns and financial statements, health information, employment details, domicile and citizenship status, copies of titles, municipal rate and utility notices, Centrelink details, a copy of your Will and Powers of Attorney, contracts of employment, trust deeds, company registrations and superannuation fund details may be required so that we may prepare a more comprehensive SOA.

Collins House Private Wealth may sometimes need to collect and use sensitive information, such as when we assist you apply for life insurance with a third party or when assisting with an insurance claim. Sensitive information includes information or an opinion relating to a person’s racial or ethnic origin, sexual orientation or practices, criminal record, current state of health and medical history.

We will only use or disclose sensitive information for the purposes for which it was provided. Collins House Private Wealth will collect your personal information directly from you either through questionnaires that you complete, by us contacting third parties on your behalf, or by keeping a record of phone calls, interviews emails and other electronic device applications.

If you wish to remain anonymous or to use a pseudonym when dealing with us, we may be able to provide you with limited information or services, such as general details about our services, however would most likely decline to act for you should you wish to remain anonymous or use a pseudonym.

For example, neither Collins House Online or Collins House Private Wealth are permitted to advise or deal in a financial product for a person, nor are we able to act for a person, when dealing with Approved Deposit Taking Institutions, Life Insurance Companies, Australian Financial Services Licensees, the Australian Taxation Office or other Local Government, State and/or Federal Government Authorities etc., without first collecting their personal information.

When personal information is gathered through face-to-face meetings or by interacting with us via telephone, mail, internet or other methods of data collection, we take steps to store your information securely. We hold your personal information in a combination of secure computer storage facilities, paper-based files and other formats.

We also protect your personal information from misuse, loss, unauthorised access, modification or improper disclosure by instructing our staff, financial advisers, accountants and lawyers, who handle personal information to respect the confidentiality of customer information and the privacy of individuals.

We maintain high data security standards to reduce the risk of unauthorised access to your information. However, should a data breach occur, we will contact you to notify you of the information that was compromised.  In certain data breach situations, we will also be required to report to the Office of the Australian Information Commissioner.

We engage an experienced third party IT consultancy firm to assist us to protect your personal information in conjunction with an experienced Individually Managed Account Operator, licenced by ASIC, Licenced ASX participants, Licenced Exchange Traded Fund (ETF) providers, an experienced separately managed Account operator, cloud server technology and physical off site backups of data.

From time to time we may share your personal information with third parties such as;

  • auditors, insurance companies, and barristers
  • 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.

As your personal information may change from time to time we request that you update your details in writing as soon as possible, through the post or by email.

We may use social networks to communicate with the public about our services and financial industry updates and thoughts. When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you. Each social network service will also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for each service on their respective websites.

It is very important that you take the time to notify us of any changes immediately, especially change of address etc, so as to reduce the risk of Collins House Online or Collins House Private Wealth attempting to correspond with you at an address, you no longer use.

We may be legally required to maintain some of your records for a significant period of time. However once we believe information is no longer needed we may remove any identifying details or destroy the records entirely.


Access to your personal information

Under the Privacy Act you have the right to access the personal information we hold about you, with some exceptions.

To make a request you need to write or email Collins House Online or Collins House Private Wealth as the case may be, indicating what information you require.

Unless giving access would be unlawful, or where denying access is required or authorised by an Australian law or a court order, we will provide you with an estimate of any potential costs associated with your request including retrieving, reviewing and copying any of the material you need.


Changes to this policy

This policy is subject to change from time to time as Collins House deems necessary.

Any changes will be posted on our website as and when they occur.


Your privacy and the internet

The website www.collinshouse.com provides you with information to help you make an informed choice about using Collins House Online or some or all the multidisciplinary services offered by Collins House Private Wealth.

We may also collect personal information about yourself through you completing Questionnaires or other requests through a secure server.

Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on the web site, when you return to the web site, where you came from, and to ensure your information is secure.

The purpose of this information is to provide you with a more relevant and effective experience on our website including presenting web pages according to your needs or preferences.

We use cookies to give you access to certain pages of the websites without having to log in each time you visit.

Collins House Online and Collins House Private Wealth may also use external service providers to track the traffic and usage on the web site.

Cookies are frequently used on many websites on the internet and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser.

You may not be able to access some parts of our website if you choose to disable the cookie acceptance in your browser, particularly the secure parts of the website.

We therefore recommend you enable cookie acceptance to benefit from all the services on the website.

Our website has links to external third party websites that may benefit the user.

External websites should contain their own privacy statements and we recommend you review them when using their websites.

Please note, however, that third party websites are not covered by this policy, and these sites are not subject to the Collins House policy standards and procedures.

Website analytics measurement software is used to assist in tracking traffic patterns to and from our website, anonymously surveying users of the sites.

The system is used to collect such information as the number of unique visitors, how long these visitors spend on the website when they do visit, and common entry and exit points into and from the website.

This non-personal information is collected and aggregated by third party software and provided to us to assist in our analysis of our websites.

You cannot be identified personally from this information and no personal information is stored about you.


What to do if you have a complaint

We take all complaints very seriously and consider all complaints carefully as part of our commitment to being open, and honest in dealing with our clients.

The first step is to write to the Collins House Privacy Officer
By email – mail@collinshouse.com
In writing – Collins House, P.O. Box 24175 Melbourne Vic 3001

In most cases, we’ll contact you within five working days of receiving your complaint and let you know what action we intend to take with regard to the matter.

If you feel your complaint has not been satisfactorily addressed or that it is taking too long to resolve, you can ask for your concerns to be escalated by contacting the Collins House Privacy Officer as above.


If you still have concerns further assistance may be available from:

The Australian Financial Complaints Authority
Phone: 1800 931 678
Website: www.afca.org.au
Email: info@afca.org.au
or

The Office of the Australian Information Commissioner
Phone: 1300 363 992
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au