Smooth Retirement informs employees, contractors and relevant third parties about this Policy and all changes. All employees are trained to respect your privacy in accordance with this Policy.
We value your trust and are committed to ensuring that your personal information is secure, and your privacy is protected.
This policy explains the steps we take to comply with the Privacy Act 1988 (Cth), Australian Privacy Principles and General Data Protection Regulation. It contains information about:
- What information we collect about you
- How we collect personal information
- What we do with your personal information
- Who we disclose personal information to
- How we protect your personal information
- How to keep your personal information accurate and up-to date
- How you can access your personal information
- Who to contact if you have any questions about this Policy or wish to make a complaint
Personal Information is information or an opinion relating to an individual, whether true or not and whether recorded in a material form or not, which can reasonably be used to identify that individual.
Collecting your personal information
We are subject to certain legislative and regulatory requirements under the National Consumer Credit Protection Act 2009, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the Corporations Act 2001. This requires us to obtain personal information about you including (but not limited to):
- Your full name
- Date of birth
- Email address
- Residential address & post code
- Postal address
- Your goals and aspirations
- Employment income
- Government benefit income
- Gifts you have made (or intend to make)
- Estimated home value
- Information about your regular income and lump sum requirements
- Your reason/s for wanting to release equity in your home
- Superannuation value net of tax and any associated insurance cover
- The value of your lifestyle assets – i.e. vehicles, home contents
- The value of your financial assets – cash, shares, managed funds, other
- Your liabilities – the balance, interest rate, repayments and exit penalties
- Your payment information for service fees (if applicable)
- Other information relevant to our Smooth Retirement solution or required by law
We will also collect information relating to the use of the website such as:
- The date and time you visited the website
- The number of pages you viewed
- Your navigation patterns
- The country from which you accessed the website
We may collect sensitive information from you. Sensitive information (for example) includes information relating to your health. We will only collect sensitive information that is reasonably necessary for us to provide you with our advice and services.
Working with Smooth Retirement
If you apply for employment with us, we will collect information about your work history and ask your referees about you. If you apply to become a Smooth Retirement Representative, we will collect information to enable us to assess whether you meet accepted industry standards.
How your personal information is collected
We collect personal information directly from you whenever we can. We may also collect your personal information if you make an enquiry by emailing or phoning us or sending us correspondence by post.
Sometimes we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if we have your consent and it is reasonably necessary to do so, for example, where:
- We collect information from third parties about an existing loan
- We exchange information with your professional advisers such as a financial planner or legal representative
If you do not provide us with your personal information or it is not complete or accurate, the advice you receive may not be appropriate.
Unsolicited personal information
We don’t usually collect unsolicited personal information. Where we receive unsolicited personal information that is not relevant, we will destroy or de-identify that personal information as soon as practicable.
Dealing with us anonymously
You can deal with us anonymously where it is lawful and practicable to do so. For example, if you wish to make general inquiries about mortgage brokers or financial advisers near to your location.
How we use your personal information
It is only through the collection of your personal information that we can understand you (and your needs) and provide you with advice and services that are appropriate for you. We will use your personal information for the primary purpose of:
- Assessing whether an equity release product is not unsuitable for you
- Providing you with retirement planning advice and guidance and financial projections as part of our service to you
- Assisting you to apply for a reverse mortgage or an increase in your credit limit
- Collecting payment information in order to process your service fees
- Establishing and verifying your identity
- Ensuring compliance with relevant laws, regulations and legal obligations
- Telling you about other service providers, with whom we have arrangements, that supply goods or services that may be of interest to you
- Direct marketing
- Managing our relationship with you
- For any other purpose for which you have given your consent
We may also use and disclose your personal information for a secondary purpose which relates to a primary purpose above, or in other circumstances authorised by the Privacy Act.
Sensitive information collected will only be used and disclosed for the purpose for which it was provided (or a direct secondary related purpose), unless you agree otherwise, or an exemption applies under the Privacy Act.
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
We will retain the information we collect from you for a period of 7 years, as required by law.
If you apply to become a representative or apply for employment with us, we will collect information about you to assist us to decide whether to appoint you.
Disclosing your personal information
In order to provide you with our advice and services we will need to disclose your personal information to third parties. The organisations that we are likely to disclose information about you to include:
- Anyone who represents you such as lawyers
- Persons that referred you to us (if applicable)
- Companies that provide information and infrastructure systems to us
- Agents, contractors, insurers, professional advisers and external service providers
- Government and regulatory authorities and other organisations, as required or authorised by law such as under the Anti-Money or Laundering and Counter Terrorism Financing Act 2006 or in accordance with a subpoena or summons issued by a court
- Associated businesses that may want to market products to you
- Organisations involved in a transfer or sale of our assets or business
- Anyone, where you have provided us consent
We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.
Where your personal information is disclosed, we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles.
Keeping your personal information accurate and up-to-date
You can contact us to update your personal information using our contact details in the ‘Contact Us’ section of this Policy. We aim to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe your personal information is not accurate, complete or up to date please contact us as soon as possible. Where the information is inaccurate, we will take reasonable steps to correct it (free of charge) within 30 days.
Protecting your personal information
The security of your personal information is important to us and we take reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure. Some of the ways we do this are:
- Your personal information is stored encrypted in our IT database and on webservers/cloud storage located in Australia or overseas
- We store all data electronically and do not retain any hardcopy files
- Use of firewalls
- Employees are prohibited from updating and editing personal information without your permission
- Print reporting of data containing personal information is prohibited
- Deleting, de-identifying or destroying personal information when records are no longer required
- We have confidentiality agreements with our employees, contractors and external service providers;
- Physical security of our premises
Gaining access to your personal information
You can gain access to your personal information (subject to some exceptions allowed by law) by contacting the Privacy Officer. We will need to verify your identity first however we will never use a government identifier to verify your identity. We will provide you access within 30 days if it is reasonable and practicable to do so, but in some circumstances, it may take longer (for example, if we need to contact other entities to properly investigate your request).
We may refuse to provide you with access, such as where the information relates to existing or anticipated legal proceedings, if the request is vexatious or if the information is commercially sensitive. If access is refused, we will give you a notice explaining our decision, to the extent practicable, and your options to make a complaint.
We do not usually charge you for access to your personal information. However, if the request is complex, we may charge you the marginal cost of providing the access, such as staff costs of locating and collating information or copying costs. If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.
Links to Other Sites
We may use technology such beacons, tags, scripts and tracking pixels to collect, store and use anonymous data about how you use our website / mobile technology. This includes your server address, the date and time of your visit, the pages and links accessed, the type of browser used and other information about your browsing activities. This data is used to increase functionality and can also enable us to display information and content that is tailored to our understanding of your interests. This information alone cannot be used to discover your identity.
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about products and services that we believe may be of interest to you. We will not do this if you tell us not to. Such marketing activities may be via email, telephone, mail, or any other electronic means, including targeted advertising through our website.
We may also market our services to you through third party channels (such as social networking sites), or via other companies who assist us to market our services. We may use de-identified data to disclose to online advertisers that allow us to place communications in the media most relevant to you.
With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses. You can ask us not to do this at any time.
Yes, You Can Opt-Out
You have the right to request us not to disclose or use your personal information for the purposes of direct marketing, or for the purpose of facilitating direct marketing by other organisations.
We will process your request as soon as practicable. You may also request that we provide you with the source of their information. If such a request is made, we must notify you of the source of the information free of charge within a reasonable period.
You can let us know at any time if you no longer wish to receive direct marketing offers (see ‘Contact Us’).
Notifying you of certain data breaches
A data breach occurs when personal information held by us is lost or subjected to unauthorised access or disclosure. If we suspect or know of a data breach, we will take immediate steps to limit any further access or distribution of the affected personal information or the possible compromise of other information.
When we have reasonable grounds to believe that a data breach is likely to result in serious harm – for example identity theft, significant financial loss or threats to physical safety we will notify individuals at likely risk as soon as practicable and make recommendations about the steps they should take in response to the data breach. We will also notify the Office of the Australian Information Commissioner.
Notifications will be made using our usual method of communicating with you such as email and physical mail. We may also publish a statement on the front page of our website.
Resolving your privacy concerns
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us. We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
Our Privacy Officer will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing within 30 days of the determination of our Privacy Officer. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner by:
Phone: 1300 363 992
Mail: Director of Complaints, Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001
You may also lodge a complaint with the Australian Financial Complaints Authority (AFCA):
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority GPO Box 3 Melbourne VIC 3001
If your complaint relates to how we handled your access and correction requests, you may take your complaint directly to AFCA or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
Scott Phillips, Privacy Officer
Level 1, 99 St Georges Terrace, Perth WA 6000