Introduction
This policy document applies to Strathmore Investment Management, collectively referred to as “us”, “we” or “our”.
We understand the importance of privacy to our customers and as such are committed to protecting your privacy and personal information. As an organisation that collects and manages personal information, we are required to comply with the Privacy Act 1998 and the Australian Privacy Principals (APPs).
In our privacy policy, “personal information” has the same meaning as in the Privacy Acts; (namely, information about an identifiable individual).
This privacy policy has been created to set out how we will handle and manage the personal information we collect and/or hold about you. From time to time this policy may be updated, with or without notice to you. Our most up-to-date version of this policy will always be available on our website. If unable to access the internet, a hard copy of this policy can be provided to you free of charge by contacting us on the details below:
The Privacy Officer
Strathmore Investment Management
PO Box R1653
Royal Exchange
NSW, 1225
What personal information we collect
Personal information is collected by us when you either enquire about our service or when you use our products and/or services. The types of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
How we collect your personal information
Personal information will be collected directly and indirectly. Personal information obtained directly from you will mostly be collected: when filling out an application form, speaking to your adviser, emailing us or via our website.
In some instances, we may collect indirect information about you from third parties such as banks and financial institutions, financial advisers, or your employer.
We will not collect any information that you have not voluntarily provided to us or that we do not believe has been authorised for release to us by a third party.
Any unsolicited information about you, provided to us by you or any third parties will be purged from our systems.
If you refuse to provide us with personal information, we may not be able to offer you our products and services or deal with you any further.
Why we collect your personal information
Quite simply, we collect and retain your personal information as reasonably necessary to carry out our business, identify you and provide you with our services. The collection of much of this information is to ensure we meet our legal and regulatory requirements. Your personal information may be used to; open and maintain an account, communicate with you on products and services you may use, or to send you information on other products and services.
We will only collect information about you that enables us to perform our business functions and activities. We assume that you consent to the collection of your personal information as set out in this policy. If you do not consent to this you are free to leave this site or if you wish to withdraw your consent you can do this by contacting the Privacy Officer via the contact details listed in this document.
How your information is kept secure
We are committed to the secure storage and use of your personal information. All information is stored on a third-party server which is regularly maintained by our IT contractors. Our IT systems have the appropriate safeguards in place to protect your information. Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). Access to personal information stored on our systems is strictly limited to personnel, such as your adviser, who have been authorised to access it. We take reasonable steps to protect your personal information from misuse, interference, and loss and from unauthorised access, modification, or disclosure.
Information that we no longer deem necessary or is not legally required for us to retain is destroyed. We review our client files on a regular basis to identify any such information.
Direct marketing
We may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, we may still contact you in relation to its ongoing relationship with you.
Disclosure
Domestic
During the normal course of business, it may be necessary to share your personal information with third parties within Australia. These entities may have a direct or indirect relationship with us relating to our business functions. Some examples could include:
We may also be required to disclose your information by law. An example of this could be to the Australian Taxation Office (ATO), Australian Securities and Investments Commission (ASIC) or to a law enforcement agency.
Overseas
From time to time we may need to transfer your personal information to third parties outside Australia. If the third party is not subject to or does not comply with equivalent privacy laws, we will seek your consent prior to doing so, unless where the APP does not require us to do so.
Third parties that we may disclose your information to a service provider that performs certain functions of its business overseas. Another could be if you have an international portfolio that is held by an overseas custodian.
Rights and choices
Accessing your information
At any time, you may contact us to submit a subject access request for the information we hold about you. In some circumstances, there may be a legal or administrative reason why we cannot approve your request. If we are unable to approve your subject access request, you will be provided with the reasons why. Subject access requests can only be made for personal information you have provided us and will not include any of our record-keeping that has been created by us.
Whilst we will not charge you for making a subject access request for your personal information, we may charge you a fee to compensate us having to collate and make the information available.
All requests must be made to the Privacy Officer whose details have been provided earlier in this document.
Correcting your information
You have the right to rectify (i.e. correct) your personal data should you believe it is inaccurate, misleading, or incomplete. Once we verify the information, we will ensure it is corrected. If we deem your information to be inaccurate, we may refuse your request to amend it. In this unlikely event we will advise you of our decision and our complaints policy.
To avoid any incorrect or out of date information, we ask that you advise us of any change in circumstance which may render your information incorrect or inaccurate. This may be a change of address, telephone number or surname.
All requests must be made to the Privacy Officer whose details have been provided earlier in this document.
Where we receive information about others from you
If you provide us with personal information about someone else, you must ensure that you have their consent to do so (including their consent for contacting them), so that, without us taking any further steps required by applicable data protection or privacy laws, we may collect, use and disclose such information for the purposes we have described in this policy.
This means you must take reasonable steps when providing personal information so that the individual concerned is aware of and/or consents to this policy, including that:
Using our website
You should be aware that there are risks associated with sharing information over the internet.
When you visit our website your web browser may send requests to our server for web pages and/or other content. These requests are recorded and provide us with information such as your IP address, Internet Service Provider, and geographic location. We use this information purely to assess the performance of our website. This information is not used to try and identify you.
Any provision of data or collection of data on any external website that you may visit using the hyperlinks on this website is not covered by this privacy policy.
Cookies
We may use cookies when you are on the Website. Cookies are small blocks of text stored on your device. They allow us to recognise you (or rather, your internet browser) as you move around our site, and if you return to our site later. Cookies cannot read your hard drive or command your computer to perform any action.
Cookies may be used for security to help us identify you, to provide you with personalised features and for tracking traffic on our site. Any information we collect and share with third parties through cookies is aggregated and therefore anonymous (when shared with third parties, it does not include personal information which is likely to identify you).
You can prevent new cookies from being installed and delete existing cookies. The procedure depends on which browser you are using. For information on how to remove cookies check your internet browser. You may be unable to access certain pages on our Website or use Direct Broking unless you accept cookies.
How to make a complaint
If you have a complaint about how we have handled your personal information you should inform us in writing, as required by the Privacy Act. All complaints should be addressed to the Privacy Officer whose details have been provided earlier in this document. We suggest you retain a copy of the complaint and all correspondence in relation to the complaint.
Once the Privacy Officer receives your complaint you will receive a written response within thirty (30) days. We are committed to resolving disputes through our complaints handling process.
If you make a complaint and are not satisfied with the outcome, you have the right to contact the Office of the Australian Information Commissioner (OAIC).