1 WE ARE COMMITTED TO PROTECTING YOUR PRIVACY
This document outlines the Triple A / Preset Super policy on handling the personal information these it collects about individuals including customers, potential customers and shareholders.
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, we will normally explain why we need it, how it will be used and who we may share it with.
This policy answers the following questions about privacy at Triple A Super Pty Ltd and Preset Super Pty Ltd.
2 WHY DOES TRIPLE A / PRESET SUPER NEED YOUR PERSONAL INFORMATION?
Understanding and meeting our customers’ Self-managed Superannuation Fund needs over the course of the entities’ lifetime is a central part of our business. We do this by providing superior financial services, tailored specially to our Clients’ needs. To do this effectively, we need to collect certain personal information. In this Privacy Policy, personal information is any information that could identify you or be used to establish your identity under:
Triple A / Preset Super mainly collects, holds, uses and discloses customers’ personal information so we can establish, manage and provide these products and financial services. We may also use and disclose your information for purposes related to those mentioned above, such as arranging for services to be provided by third parties and enhancing our customer service and product options.
In addition, 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.
3 WHAT HAPPENS IF I DO NOT PROVIDE INFORMATION THAT HAS BEEN REQUESTED?
It’s your choice whether to provide your information. However, without certain information, we may be unable to fulfil your request for a specific service. Trustees would also not be able to operate the fund properly.
Furthermore, requirements under certain Australian laws require full disclosure of details associated with a new or existing superannuation fund. We only request information required to meet the obligations of administering a fund if it is not provided, we would not be able to accept an application for a new or existing fund to use our services.
4 WHAT TYPES OF PERSONAL INFORMATION DOES TRIPLE A / PRESET SUPER COLLECT?
We may ask for a range of personal information to assist us in providing you with relevant financial products and services. The information we may request includes (but is not limited to) name, address, date of birth, contact details of trustees and members of Self-Managed Super Funds together with bank account and investment information, assets and liabilities, account balances and tax and financial statements of the Funds themselves.
5 DOES TRIPLE A / PRESET SUPER COLLECT SENSITIVE INFORMATION?
We sometimes need to collect and use sensitive information, such as personal and SMSF Tax File Numbers.
The Australian Privacy Principles set out restrictions about the way sensitive information can be used.
Unless you give us your consent, or if we are required or permitted by law, we will only use or disclose sensitive information for the purposes for which it was provided.
We do not collect or disclose general sensitive personal information such information about a person’s race, religion or political affiliations.
6 HOW DOES TRIPLE A / PRESET SUPER COLLECT PERSONAL INFORMATION
Triple A / Preset Super will collect your personal information directly from you where this is reasonable and practical. We gather this information either through applications or other forms that you complete, or by recording the information you provide via phone calls, interviews and other forms of communication.
We may also collect personal information from external sources. The people or organisations who may provide us with information are:
When we are provided with personal information about an individual from a third party, we seek to ensure the individual is aware of certain matters, such as Triple A Super’s identity and our contact details.
7 CAN YOU REMAIN ANONYMOUS OR USE A PSEUDONYM WHEN DEALING WITH US?
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 information regarding our practices.
However in many cases it will be impracticable for us to assist you if you wish to remain anonymous or use a pseudonym or be able to meet the compulsory Government reporting obligations to operate an SMSF.
8 HOW DOES TRIPLE A / PRESET SUPER PROTECT YOUR PERSONAL INFORMATION?
Whether your personal information is gathered through face-to-face meetings or by interacting with us via telephone, mail, internet or other methods, 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 take a number of steps to protect personal information from misuse, loss, unauthorised access, modification or improper disclosure. These include instructing our staff and financial advisers who handle personal information to respect the confidentiality of customer information and the privacy of individuals.
9 WHO DOES TRIPLE A / PRESET SUPER SHARE YOUR INFORMATION WITH?
From time to time we may share your personal information with other entities both within and outside of Triple A Super. The entities that we might share your personal information with vary according to the product or service involved, but could include:
We do not sell, rent or lease our client lists to third parties, whether a Partner or otherwise for marketing purposes.
10 IS TRIPLE A / PRESET SUPER LIKELY TO DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
Some of the entities we share information with may be located in, or have operations in, other countries. For Example HMRC in the UK in relation to an SMSF with QROPS status.
We normally require any external organisations with whom we share your personal information to comply with the Australian Privacy Principles.
11 HOW DOES TRIPLE A / PRESET SUPER UPDATE PERSONAL INFORMATION?
We realise that your personal information changes frequently – people move house, change jobs and update other personal circumstances on an ongoing basis. In most cases you can alter your details over the telephone, in writing or by uploading documents via the Triple A / Preset Super secure returns portal.
If we believe the information we hold is incomplete or out of date, we may also seek to correct or complete our records by gathering data from other sources such as public records and your financial adviser or accountant as advised by you.
12 HOW IS YOUR PERSONAL INFORMATION SECURED?
There are inherent risks in transmitting information across the internet. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. However, we strive and take all reasonable steps to protect personal information from misuse, interference, loss and unauthorised access.
Security measures and procedures include security audits, penetration testing, password protections, encryption tools and other security software. Triple A / Preset Super uses Oracle as its in–house technology partner. They are recognised as a world leader in data security and practices.
You are responsible for ensuring that any user name and password that are issued to you are protected at all times from unauthorised access by third parties.
13 OUR COLLECTION AND USE OF PERSONAL INFORMATION VIA WEBSITE COOKIES AND ANALYTICS
We may also collect personal information to assist in the delivery of products and services through the use of cookies and website analytics.
A ‘cookie’ is a small text file that is placed on a computer’s hard drive by a web page server and stores information about the use of our webpage. Most web browsers are automatically set to accept cookies but if you do not wish to receive any cookies you may set your browser to refuse cookies. If you do not accept cookies, this may affect the operation of our website.
We use Google Analytics to collect anonymous information and data whenever you access and navigate through our websites. The types of anonymous information we collect include demographic data, the type of devise you use, what section of our website you accessed and the specific page you accessed. We collect this information for operational maintenance and statistical purposes to assist us in improving our websites. When you access our websites, your browser automatically sends certain information to Google which is included in our analytical reports.
For more information on how Google Analytics operates, see “How Google uses data when you use our partners’ sites or apps” (located at: www.google.com/policies/privacy/partners).
Through our email mailing platform we are also able to track if, and when, you open emails from us and your interactions with the content of our emails.
14 LINKS TO OTHER WEBSITES
We provide links to websites that are owned/operated by third parties. The linked websites are not under our control and we are not responsible for the conduct of third parties whose websites we provide links to. Before disclosing personal information on any other website, we advise you to examine the terms and conditions of those websites.
Our products and services may allow you to disclose financial data, including personal information, to and from third party applications which are not affiliated, sponsored or endorsed by us. We have no control over and are in no manner liable for the manner in which such third party applications handle personal information. We highly recommend your check the Privacy Policy of any such third party applications and ensure those organisations handle personal information in accordance with Australian privacy laws.
15 HOW LONG WILL TRIPLE A / PRESET SUPER KEEP INFORMATION?
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.
16 CHANGES TO OUR PRIVACY POLICY
As Australian and International laws on privacy are enhanced and modified, Triple A / Preset Super reserves the right to amend its Privacy Policy from time to time.
17 HOW CAN YOU CONTACT TRIPLE A /PRESET SUPER ABOUT PRIVACY?
You can contact us to:
18 HOW DO I FIND OUT ABOUT THE PERSONAL INFORMATION TRIPLE A / PRESET SUPER HOLDS ABOUT ME?
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 advise in writing what information you require.
Triple A / Preset Super is permitted to refuse access to personal information in certain situations. Examples include where:
Before providing the requested information we will give you an estimate of any potential costs associated with this, including expenses for locating, retrieving, reviewing and copying any of the material you need.
19 WHAT SHOULD I DO IF I HAVE A COMPLAINT?
To raise any concerns you might have in relation to privacy, please contact us via the contact channels listed above.
We take privacy-related complaints very seriously and consider all complaints carefully as part of our commitment to being open, honest and fair in dealing with your concerns. In most cases, we’ll contact you within five working days of receiving your complaint to let you know what actions we are taking regarding the matter.
20 HOW CAN I ESCALATE MY CONCERNS?
If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you can ask for your concerns to be escalated to the Triple A / Preset Super Privacy Officer.
Contact details are as follows:
Triple A / Preset Super Privacy Officer
PO Box 170
Canterbury VIC 3126
If you believe your complaint has not been satisfactorily managed you can also contact
The Office of the Australian Information Commissioner
Phone: 1300 363 992
Website: www.oaic.gov.au
Email: enquiries@oaic.gov.au