Maddern Accountants & Maddern Financial Advisers are committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act.) This policy sets out how Maddern Accountants & Maddern Financial Advisers handles personal information. This privacy policy does not apply to personal information collected by Maddern Accountants & Maddern Financial Advisers that is exempted under the Privacy Act, for example employee records.

Our privacy policy will be reviewed regularly to take account of changes in legislation, technology, and our operations and practices. We aim to ensure the policy in appropriate to the changing environment.

We will inform you of any changes we make to this privacy policy as necessary.

Our privacy policy is based on openness about how we use and protect your information. Requesting a copy of Maddern Accountants & Maddern Financial Advisers Privacy Policy.

On request, we may be able to provide you with a copy of the policy in the alternate format. If you have any enquires or would like to make a request for a copy of the policy, please contact our Privacy Officer (refer to contact details below.)

1. Purposes for which Maddern Accountants & Maddern Financial Advisers collects, holds, uses and discloses personal information: We only collect, hold, use and disclose personal information which is reasonably necessary to ensure that we are able to provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use and disclose your personal information.
2. Kinds of personal information Maddern Accountants & Maddern Financial Advisers collects: Due to the nature of the products and services we provide, and the requirements of legislation and regulations, we ask for a range of personal information from our customers.

The types of personal information we may collect can include details such as:  Names, employment titles, contact details, date of birth and gender;

Information in identification documents (e.g. passport, driver’s licence);  Tax file numbers and other government related identifiers;  Assets and liabilities; Educational qualifications and employment history ;  Personal income;  Visa and work permit status;  Bank account details;  Shareholdings and details of investments;  Superannuation details;  Tax and financial statements;  Information regarding insurance;  Personal information about your spouse and dependants. It may be necessary in some circumstances for Maddern Accountants & Maddern Financial Advisers to collect sensitive information about you in order to provide specific services. The types of sensitive information we may collect include:  Health status;  Ethnic origin;  Details of any membership/s to professional associations;  Criminal record.

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients with the services we were engaged to perform.

3. Collection, holding, using and disclosing of personal information:

(a) Collection – General: When we collect, hold, use and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles. If you would like more information on these requirements, please contact our Privacy Officer.

(b) Methods of collection: Maddern Accountants & Maddern Financial Advisers use a variety of formats for the collection of personal and sensitive information. These include: ? Requiring clients to complete a Client Profile or other forms; ? Receipt of emails, letters and other correspondence; ? Telephone calls; ? Appointments in person; ? Publicly available records; ? Through a customer’s personal representative; ? Through use of our website, such as via contact mailboxes or online enquiry forms, or through the registration process (see more information about ‘web analytics’ in Clause 2). In every circumstance we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources in accordance with Clause 3(a) above.

(c) Collection of someone else’s personal information: You should only provide us with someone else’s personal information where you have their express consent to do so and it is for the purpose of us providing services to you. Matters in this policy should be communicated to any person whose information you collect and provide to us. Unsolicited personal information: There may be circumstances where we are provided with personal information which we did not actively seek. An example may be misdirected mail, or an excess of documents provided to us by clients. In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully in accordance with the APPs. If the information was not lawfully obtained it will be destroyed or de-identified. We will try to notify the relevant person, whose information has been mistakenly received, if this situation arises.

4. Security of personal information Safeguarding the privacy of your information is important to us.

We hold personal information in a combination of secure computer storage facilities and paper based files, and take steps to protect the personal information we hold from misuse, loss, interference, unauthorised access, modification or disclosure. Maddern Accountants & Maddern Financial Advisers trains its employees carefully on handling personal information and confidentiality of such information. Once we have no purpose for holding your personal information, we will take all reasonable steps to destroy or de-indentify the information.

5. Disclosure of personal information overseas and sharing personal information amongst and within the Maddern Accountants & Maddern Financial Advisers network

a) Disclosure amongst and within Maddern Accountants & Maddern Financial Advisers, Maddern Financial Advisers and Maddern Private Wealth: The business Maddern Accountants & Maddern Financial Advisers is operated in conjunction with Maddern Financial Advisers and Maddern Private Wealth. To meet the purposes for which your personal information has been collected we may disclose your information to others in the MADDERN Group.

b) Disclosure overseas: Maddern Accountants & Maddern Financial Advisers utilises some service providers overseas to process data and help deliver services to you. We may disclose your personal information to these providers from time to time. Such overseas disclosure would be to Sri Lanka or another country as advised. When required, your personal information will only be disclosed to an overseas person or business in the following circumstances.

c) Where the overseas recipient has signed a contract with us which creates legal obligations to comply with Australian Privacy Law (i.e. the APPs); & if the recipient is subject to similar privacy law as Australian privacy law, and you are able to personally access avenues to enforce the protection of those laws; & if you provide written consent for Maddern Accountants & Maddern Financial Advisers to disclose the information after we provide you with full information; or

d) If the disclosure is required or authorised by or under an Australian law or a court/tribunal order. On collection of your personal information, we will inform you whether it is likely we will disclose the information to an overseas recipient and, if so, where those recipients are likely to be located.

6. Privacy on our websites The Maddern Accountants & Maddern Financial Advisers website uses Google Analytics to analyse aggregate user behaviour.

Google Analytics uses first party cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant Maddern Accountants & Maddern Financial Advisers access to your personally identifiable information. Non-identifiable information (such as the pages you visit) may be tracked. By directing your browser to delete your cookies, this data will be erased. For more information about Google Analytics, please follow the links provided on our website. The information is collected using first party cookies, meaning that only Maddern Accountants & Maddern Financial Advisers is able to access your information.

Your information may be aggregated with information from other users for the purpose of improving our website and offerings. We will not associate any data gathered from our website with any personally identifiable information, unless you explicitly submit that information (e.g. your email address) via our online information form. Any links to third party website on Maddern Accountants & Maddern Financial Advisers website are not covered by our privacy policy. Adwords & Facebook re-marketing. The re-marketing feature in AdWords allows Maddern Accountants & Maddern Financial Advisers to reach people who have previously visited our website, and match the right people with the right message. This means that several third-party vendors, including Google and Facebook, show our ads on sites that you access across the internet as well as using cookies to serve ads based on your past visits to our website. To opt out of Re-marketing, you can opt out of Google’s use of cookies by visiting Google’s Ads Settings (click here). Alternatively, you can also opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page (click here)

7. Direct marketing Maddern Accountants & Maddern Financial Advisers may engage in direct marketing to you from time to time.

When required, your personal information will only be used or disclosed for direct marketing where the information is not sensitive information, is collected directly from you and there is an easy means to opt out of such marketing (and such an opt out request has not been made) in the following circumstances: a. Where you would expect Maddern Accountants & Maddern Financial Advisers to use or disclose the information for direct marketing purposes; or b. You have consented to the use or disclosure of the information for direct marketing purposes.

8. Access to personal information You have the right to access any personal information regarding you that Maddern Accountants & Maddern Financial Advisers holds.

This is subject to some limited exceptions, which the Privacy Officer can provide further information on. Such requests should be made in writing to the Privacy Officer. We will acknowledge your request within 14 days and respond to it within a reasonable time.

Maddern Accountants & Maddern Financial Advisers may charge a fee only to cover the cost of locating, retrieving, reviewing and copying any material requested.

We will not charge any fee to make the request or to for us to give effect to the request. Responding to your request: If your request is approved, we will provide you with access to the information in the manner requested if it is reasonable and practicable to do so.

9. Correction of personal information Maddern Accountants & Maddern Financial Advisers endeavours to ensure that the personal information it holds is accurate and up-to-date.

You are able to make a request to correct the information by contacting our Privacy Officer, or by telephoning or emailing us with your corrected information. In some limited circumstances your request may be refused or partially refused.

10. Procedure if your request to access or correct is refused There may be limited circumstances where your request is refused or partially refused. If this occurs we will give you a written notice that sets out:

• The reasons for the refusal, including the reasons why access cannot be granted in an alternative way (except where it would be unreasonable to provide those reasons);
• How to make a complaint about the refusal;
• Any other matter as prescribed by the regulations. If your request to correct is refused you have the option of submitting a statement associated with your personal information. For more information contact the Privacy Officer.

11. How to make a complaint

If you consider that any action of Maddern Accountants & Maddern Financial Advisers breaches this policy or the Australian Privacy Principles, you are able to make a complaint.

Once we have received your complaint, it will be assessed and acted upon within a reasonable time. To make a complaint please contact our Privacy Officer. If you are not satisfied with our response to your complaint, you may contact the Office of the Privacy Commissioner.

Adwords & Facebook Re-marketing

The remarketing feature in AdWords allows Maddern Financial Advisers Pty Ltd to reach people who have previously visited our website, and match the right people with the right message.

This means that several third-party vendors, including Google and Facebook, show our ads on sites that you access across the internet as well as using cookies to serve ads based on your past visits to our website.

To opt out of Re-marketing

You can opt out of Google’s use of cookies by visiting Google’s Ads Settings (click here). 

Alternatively, you can also opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page (click here)

Your Personal Information:

As a financial planning organisation we are subject to certain legislative and regulatory requirements which necessitate us to obtain personal information about you, including s945A of the Corporations Act. Detailed below is some of the information you are required to provide:

• your name, date of birth,  tax file number,  current addresses, telephone/mobile/fax numbers, e-mail address;
• information regarding your dependents and family commitments
• your  occupation, employment history,  details family commitments,  social security eligibility,
• health information or other information the organisation considers necessary.
• your financial needs and objectives;
• your assets and liabilities (current and future), income, expenses;
• your superannuation and insurance details;
• your social security entitlements; and
• your risk profile details.
• Maddern Financial Advisers Pty Ltd collects personal information in a number of ways, including:
• directly from you, when you attend a face-to face interview;
• directly from you, when you provide information through a data collection form;
• directly from you, when you provide information by phone;
• directly from you via an email or the internet; and
• directly  from fund managers, superannuation funds, life insurance companies and other product issuers once authorisation has been provided by you.  You have a right to refuse  us authorisation to collect information from a third party.

How We Collect Personal Information

• Maddern Financial Advisers Pty Ltd collects personal information in a number of ways, including:
• directly from you, when you attend a face-to face interview;
• directly from you, when you provide information through a data collection form;
• directly from you, when you provide information by phone;
• directly from you via an email or the internet; and
• directly  from fund managers, superannuation funds, life insurance companies and other product issuers once authorisation has been provided by you.  You have a right to refuse  us authorisation to collect information from a third party.

How We Use Your Personal Information

The information in this document details how we comply with the Privacy Act including:

• What is the purpose?
• Who is my information disclosed to?
• What law requires collection?
• What are the consequences?

Primarily, your personal information is used in order to provide comprehensive and/or limited  financial planning  services to you.  We may also use the information that is related to the primary  purpose and it is reasonable for you to expect the information to be disclosed.

From time to time, we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you.

If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavour to meet your request within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.

If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.

When We Disclose Your Personal Information*

In line with  modern business practices common to many financial institutions and to meet your specific needs we may disclose your personal information to the organisations described below.

As a Principal Member of the Financial Planning Association of Australia and a Corporate Member of the AFA, we are required to meet a level of professional standards. From time to time, we may need to provide the Association with access to your personal information to ensure that we are meeting our compliance requirements.

The Corporations Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.

We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

For the purposes set out above, we may disclose your personal information to organisations outside Maddern Financial Advisers Pty Ltd.  The organisations to which we disclose information may include:

• superannuation fund trustees, insurance providers, fund managers and other product providers in order to manage or administer your product or service;
• compliance consultants to ensure that our representatives are meeting our compliance standards;
• paraplanning contractors or temporary staff to handle workloads during peak periods;
• mailing houses;
• your professional advisers, including your solicitor or accountant as authorised by you;
• information technology service providers to  maintain, review and  develop our business systems, procedures and infrastructure including testing or upgrading our computer systems;
• government and regulatory authorities and other organisations, as required or authorised by law, for example, to government or regulatory bodies for the purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue.
• another authorised representative of Maddern Financial Advisers Pty Ltd if necessary;
• a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer or all or part of the assets of our business.
• Product planning and development advisers
• Where you have given your consent including your legal advisers a new owner of our business that will require the transfer of your personal information.

In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Maddern Financial Advisers Pty Ltd.

Maddern Financial Advisers Pty Ltd  takes its obligations to protect your information seriously, this includes when we operate  throughout Australia and  overseas, as part of our operations some uses and disclosures  of your information  may occur outside your State or Territory and/or outside of Australia. In some circumstances we may need to obtain your consent before this occurs.

In the event of that we propose to sell the business, we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them.

How We Store and Secure Your Personal Information

We keep your personal information in your client file.  These files are accessible to authorised personnel only and are appropriately secured out of hours.

Your personal information may also be held on our computer database. All computer-based information is protected through the use of access passwords. Data is backed up regularly and stored securely off site. Other measures taken are:

• Confidentiality requirements for our employees
• Security measures for systems access
• Providing a discreet environment for confidential discussions

Personal information will be treated as confidential information and sensitive information will be treated highly confidential.

It is a legislative requirement that we keep all personal information and records for a period of 7 years.  Should you cease to be a client of ours,  we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information will be destroyed.

Ensure Your Personal Information Is Correct

Maddern Financial Advisers Pty Ltd  takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up -to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

• inform us of any errors in your personal information as soon as possible; and
• update us with any changes to your personal information as soon as possible.

Access to Your Personal Information

You have a right to access your personal information, subject to certain exceptions allowed by law.

We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information. Access to the requested personal information may include:

• providing you with copies;
• providing you with the opportunity for inspection; or
• providing you with a summary.

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

Some exceptions exist where we will not provide you with access to your personal information if:

• providing access would pose a serious threat to the life or health of a person;
• providing access would have an unreasonable impact on the privacy of others;
• the request for access is frivolous or vexatious;
• the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law;
• providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or

authorised by law or unless you have voluntarily consented to disclose this information to any third party.

Dealing with us anonymously

You can deal with us anonymously where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

Your sensitive information:

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or afflations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record.

This is subject to some exceptions including:

• the collection is required by law; and
• when the information is necessary for the establishment, exercise or defence of a legal claim.

Complaints Resolutions

Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 7 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

Our Website

Maddern Financial Advisers Pty Ltd website provides links to third party websites. The use of your information by these third party site is not within the control of Maddern Financial Advisers Pty Ltd and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy stands policies and procedures. You may register with us to receive newsletters and other information. By doing so, your name an e-mail address will be collected and stored on our database. We take care to ensure that the personal information you give us on our website is protected.

For example, our website has electronic security systems in place, including the use of firewalls and data encryption.

If you do not wish to receive any further information from us, or you wish to update your registration details, please e-mail your request to us. We will endeavour to meet your request within 5 working days.

Our Website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using out site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Spam Act

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s e-mail account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.

‘Electronic messaging’ cover e-mails, instant messaging, SMS and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone.

Maddern Financial Advisers Pty Ltd complies with the provisions of the Spam Act when sending commercial electronic messages.

Equally importantly, Maddern Financial Advisers Pty Ltd makes sure that our practices are in accordance with the National Privacy Principles in all activities where they deal with personal information. Personal information includes our clients contact details.

Internal Procedure for dealing with complaints

The three key steps Maddern Financial Advisers Pty Ltd follows:

• Consent –  Only commercial electronic messages are sent with the addressee’s consent –  either express or inferred consent.
• Identify – Electronic messages will include clear and accurate information about the person and the Maddern Financial Advisers Pty Ltd  that is responsible for sending the commercial electronic message.
• Unsubscribe  –  We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

Consented to such communications

Commercial messages will only be sent to you when you have given consent. This may be express consent  –  a direct indication that it is okay to send the message, or messages of that nature or inferred consent based on our business or other relationship with you and your conduct.

Comply with the law regarding viral messages

Maddern Financial Advisers Pty Ltd  ensures that Commercial Communications that include a Forwarding Facility contain a clear recommendation that the Recipient should only forward the Commercial Communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving Commercial Communications.

Comply with the age sensitive content of commercial communication

Where the content of a Commercial Communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, the  Maddern Financial Advisers Pty Ltd  takes reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event

Contact Details

Privacy Officer:   Dr. Dennis J. Maddern

Address:    Suite 238, 29 Milton Pde, Malvern Vic. 3144

Telephone :    (03) 9999 7200

Facsimile:    (03) 9822 7580

E-mail:  [email protected]