Your Privacy is important to us: we value your trust in managing your information and investments. This policy outlines how we collect and handle your personal information.
Lythgo Crew Wealth Management Pty Ltd (‘Lythgo Crew, we, us’) ABN 30 144 973 786 hold an Australian Financial Services licence number: 370951 authorising its financial planning, investment and credit services to its clients.
This policy is structured to reflect the information life cycle of data that includes:
- Use and disclosure
- Quality and security
- Contact details for the Privacy Officer
Australian Privacy Principles (APPs).
Lythgo Crew adoption of the Australian Privacy Principles (APPs) and the requirements of the Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (‘The Privacy Amendment Act’) formalises our commitment to ethical conduct and practice in regard to privacy. Lythgo Crew seeks to observe the privacy safeguards laid down by the Act when collecting, storing, using and disclosing personal and sensitive information. We also give individuals access and correction rights in relation to their personal information in compliance with the Act. If you are a client, please be assured that your personal information will only be used in the manner and for the purposes set out below.
Why we collect personal information
We collect information from you in order to provide you financial and/or credit services. In providing those services we are required to obtain personal information about you including (but not limited to):
- Personal details e.g. name, address, contact details (phone, email), date of birth, marital status, dependants, employment history, family commitments, health (for insurance and superannuation purposes), and social security eligibility.
- Financial circumstances e.g. assets and liabilities (now and future expectations), income, expenditure.
- Details of your investment preferences and aversion to, or tolerance of, risk.
- Business details including ABNs.
- Details of all investments, superannuation, insurance cover, investor numbers, credit card and bank account details.
- Personal goals, needs and objectives.
- Taxation information including your tax file number.
In addition, this information enables us to identify you and helps keep your information safe.
If you provide us with incomplete or inaccurate information we may not be able to provide you with the services you are seeking.
We may need to disclose your personal information to various third parties including service providers, product issuers or professional advisers.
Where we are required by law to pass on information to other organisations, we will disclose that information which is necessary to meet legal requirements. These organisations include government, law enforcement agencies and regulators, auditors, and any other service providers involved in our management of your finances in our normal course of business.
Duty of Confidentiality
We keep information about clients in the strictest confidence. All Lythgo Crew staff observe the obligations under the Australian Privacy Principles (APPs)
We reserve the right to review and amend this policy from time to time and to notify you by posting an updated version on our website.
Collecting information from you
Lythgo Crew collects personal information from its clients from people who make enquiries about our products via letter, email or telephone.
We will collect your personal information directly from you where this is reasonable and practical including name, address, date of birth, gender, Tax File Number (TFN). We may also collect contact information from you which is deemed necessary to manage your financial and/or credit services. We gather this information via data collection forms, applications or other forms that you complete, by recording the information you provide via phone calls, face-to-face interviews, email or the Internet or other forms of communication. We may collect personal information in a number of external ways directly from people authorised by you (such as employers, accountants and third party brokers) or from other external sources such as fund managers (superannuation or life insurance companies) and credit providers. We will also collect your personal information, as provided by you, if you make an enquiry about our services.
In all cases we endeavour to ensure that information collected is correct. If you are a client you will receive transaction confirmations, correspondence and advice statements from us. We ask that you check this information and contact us immediately should you become aware that your details require updating or alteration.
Online and Client Services
Lythgo Crew offer our website to make accessing information about our products and services easier.
Information regarding your account is accessible by you over the telephone where sufficient verification information is supplied, in accordance with our requirements and compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (‘AML’))
Why we need your personal information:
We will only collect, maintain and use personal information about you if it is necessary for us to adequately provide to you the services we have recommended. As such we will use information collected about you for a number of purposes:
- The provision of financial planning advice and/or credit service to you;
- In the preparation of the advice document containing our recommendations;
- To implement any recommendations and to provide ongoing review of needs, goals and objectives;
- To provide information to you and to ask you whether you are interested or satisfied with our products;
- Assist you in queries you may have;
- To administer your services with us;
- For market research and analysis;
- For product/services development;
- To meet regulatory obligations.
Sharing of Personal Information
Depending on the product or service concerned and particular restrictions on sensitive information, personal information may be shared with:
- Within specialist advice and transaction services within Lythgo Crew.
- Custodians, acting as external custodians that hold assets on behalf of our clients.
- Any other service providers and specialist advisers to Lythgo Crew who have been contracted to provide services to us.
- Auditors appointed by Lythgo Crew to ensure the integrity of our operations and policies.
- Any person authorised by you or to whom you have provided your consent (either expressly or implied), or persons acting on your behalf such as your trustee or guardian, provided you or a legal authority (e.g. under court orders) has instructed us in writing to do so.
We ensure our service providers are experienced and are also subject to the provisions of the Privacy Act. Under our contracts with them, they have a contractual obligation to abide by privacy law and to protect your information.
Your information may also be passed to third parties to assist in the administration of your services, for example to a Para planning services company contracted to us.
There are instances where we are legally obliged to pass on information about you. The following list of compulsory disclosures (i.e. disclosures we must make) provides you with examples but is not intended to be exhaustive or complete:
- In accordance with legislative requirements or authority (e.g. your tax file number and the taxable income of your account; deposits reportable under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth)(‘AML’));
- In accordance with the legislative requirements of the administration of managed investment schemes – reporting or assisting in the investigation of unlawful activity where there is a basis for suspecting such activity;
- To enforcement bodies with statutory authority (e.g. protection of public revenue (tax);
- Australian Taxation Office (ATO)
- In any criminal procedure with court authority;
- Laws relating to the confiscation of the proceeds of crime;
- Proceedings by any enforcement or administrative body in a court or tribunal.
We will not pass on your personal information to unrelated parties for their marketing purposes. We would seek your informed consent in the event this policy changes.
The quality of the information we collect
We endeavour to ensure that any information we collect, use or pass on is up-to-date and accurate. We request that you contact us in the event your details change.
The security of information about you
It is not appropriate for information about you to be de-identified or destroyed. In some cases, we have statutory requirements to retain our records for up to a period of seven years. Lythgo Crew takes precautions to prevent the misuse, loss and unauthorised access or modification or disclosure of your information. These include the use of verification data before information about investments is provided over the telephone or via the internet, restricted access to files, security checks on computer data, securing of data held on company networks, and a contractual requirement for service providers to use appropriate mechanisms to protect personal information. Information management is subject to an in-house compliance system with defined standards and monitoring.
Please note that we cannot guarantee the privacy of your information if you choose to correspond with us via email.
Information about our management of your information
This policy is available to any person who requests it. In addition, we would like to encourage you to contact our Privacy Officer (see below) if you have any individual concerns relating to the collection, use or security of information about you.
Access and/or correction of your information
Please contact us immediately should you become aware that any information we have about you is incorrect. In the event we dispute a correction you wish to make, we shall place your disputed information on the file, together with the unaltered statement of information, until such time as the matter can be resolved.
Unless there are exceptional circumstances around your files, we will provide you with copies of our current records about you. If you wish to see your information, we ask that you make a request in writing and allow us seven working days in which to forward it to you.
Circumstances in which access to your records might be denied or restricted could be as follows. Please note this list is not intended to be exhaustive:
- Providing access would have an unreasonable impact on the privacy of another individual;
- The information relates to existing or anticipated legal proceedings between you and us and would not be available by a process of discovery in those proceedings;
- Providing access would prejudice negotiations we have with you;
- Providing access would be unlawful or likely to prejudice an investigation into unlawful activity;
- The request is frivolous or vexatious.
Using the identifier of another organisation
We use identifier codes and records to identify you and maintain records holding information about you. Although we may have your Australian Business Number or Tax File Number, for instance, it would be used only for the purposes for identification with the relevant organisation as prescribed by that organisation.
Your ability to deal with us anonymously
You may contact us and seek to obtain any general information or assistance you wish without identifying yourself. However, for reasons of security, you will not be able to obtain information about your investments without identifying yourself first.
The use or disclosure of personal information for direct marketing purposes, except in specified circumstances is prohibited.
Subject to the operation of other direct marketing legislation, such as the Spam Act 2003.
Trans-border data flows
Lythgo Crew may store your information in cloud or other types of networked or electronic storage. We take all reasonable steps to ensure overseas recipients do not breach the Australian Privacy Principles. They are obliged to protect the privacy and security of your personal information and hold it only for the purpose for which it has been agreed.
Other sensitive information
Other sensitive information is information about you which is information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union or criminal record. Information in respect of your health is also sensitive information.
Generally, we would not collect such sensitive information about enquirers or clients.
However, clients may need to send information regarding their health, including copies of records, reports and opinions. We require your consent to have this information and we will request you provide this in writing at the time it is required, typically if you apply for insurance. We may also need to collect sensitive information as part of the AML requirements. We will only seek to collect from you the minimum amount of information that is required.
Gaining Access to your personal information
You can gain access to your personal information. In some cases we may be able to deal with your request over the telephone. For more complex requirements we will need to send you a form. Please contact us on the numbers below. We may monitor telephone calls for training and security purposes
Have you a comment or complaint about your privacy?
If we have breached any of our obligations in keeping your information, or you are uncomfortable about any of our information management practices that have come to your attention, please do not hesitate to contact our Privacy Officer. We expect our conduct to deliver standards and performance of the highest order and welcome your comments.
If you are not satisfied with our response or would like to know more about your privacy rights, you can contact the Office of the Australian Information Commissioner by calling 1300 363 992 or visiting the website at www.oaic.gov.au
Contact us: by calling +61 7 3137 1331 or by emailing: firstname.lastname@example.org
Or by writing to:
The Privacy Officer
Lythgo Crew Wealth Management
PO Box 111
New Farm QLD 4005
Making a privacy complaint: We aim to manage your information and service you to the highest standard possible, however issues may arise. Lythgo Crew has an internal compliant policy and supporting procedure that provides a standard method and measures to work to resolve the issue. If we fail to resolve the issue with you, you have the right to complain to the external complaints service contained in The Office of the Australian Information Commissioner at 1300 363 992, website: oaic.gov.au or email: email@example.com