Open Corporation and its subsidiaries (the “Company”) are committed to maintaining and protecting the privacy of the personal information we collect. We are guided by the Privacy Act 1988 (the “Act”) and its Principles. The Act affords an individual the right to know what information is held by the Company. How we use the information we collect and how an individual can access the information we hold and if they believe it is incorrect how to request its correction.
How we collect personal information from you
We collect personal information in a number of ways, including:
- By email
- Over the telephone
- Through written correspondence (such as letters, faxes and emails)
- On hard copy forms (including event registration forms, network registration forms, competition entries,and surveys)
- In person
- Through our website (for example: if you make an online enquiry or request a copy of our product disclosure statement or if you participate in a webinar)
- At expos, seminars and functions (for example, if you fill out an assessment form or leave us your business card)
- Expressions of Interest
- From third parties, including:
– Through an authorized representative such as financial advisors, lawyers, accountants, trustees; direct marketing database providers;
– The ATO or ASIC (for example, through correspondence in relation to managed investments)
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it is necessary to do so. Instances of when we may need to do so where:
- We cannot get hold of you and we rely on publicly available information to update your contact details
- We need information from a financial adviser about an application you make through us
- At your request, we exchange information with your legal or financial advisers or other authorized representatives.
When the law authorizes or requires us to collect information
We may collect information about you because we are required or authorized by law to collect it. There are laws that affect financial service providers, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Anti-Money Laundering laws.
How we use your information
- Giving you information about a financial product or service;
- Considering whether you are eligible for a financial product or service; processing your application and providing you with a financial product or service
- Administering the financial product or service we provide you, which includes answering your requests and complaints, varying financial products and services and managing our relevant product portfolios;
- Identifying you or verifying your authority to act on behalf of another client
- Telling you about other financial products or services that may be of interest to you, or running competitions and other promotions (this can be via email, telephone, SMS, mail, or any other electronic means including via social networking forums), unless you tell us not to
- Assisting in arrangements with other organisations (such as joint venture partners) in relation to a product or service we make available to you
- Allowing us to run our businesses and perform administrative and operational tasks, such as:
– Training staff
– Developing and marketing financial products and services
– Risk management;
– Systems development and testing, including our websites and other online channels
– Undertaking planning, research and statistical analysis
– Determining whether a beneficiary will be paid a benefit
– Preventing or investigating any fraud or crime, or any suspected fraud or crime
– As required by law, regulation or codes binding us; and
– For any purpose for which you have given your consent
– You can let us know at any time if you no longer wish to receive direct marketing offers from Open Corporation. We will process your request as soon as practicable
What happens if you do not provide us with your information?
Open Corporation’s policy is to provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.
In some cases however, if you don’t provide us with your personal information when requested, we may not be able to respond to your request or provide you with the product or service that you are seeking. For example, you must identify yourself to become an Investor in Open Corporations Managed Investment Scheme
If you do not provide your information to us, we may not be able to:
- Provide you with the financial product or service you want;
- Manage or administer your financial product or service;
- Verify your identity or protect against fraud; or
- Let you know about other financial products or services from Open Corporation that might be appropriate to meet your financial and lifestyle needs.
The steps we take to secure the personal information we hold include security such as encryption, firewalls, anti-virus software and login and password protection, secure office access, personnel security and training and workplace policies.
When you visit our website, details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
Sharing with open corporation
We may share your personal information with other Open Corporation related entities. This may depend on the financial product or service you have applied for and the Open corporation entity you are dealing with.
Sharing at your request
We may need to share your personal information with:
- Your authorised representative or any person acting on your behalf (e.g. financial advisers, lawyer, accountants, executors, administrators, trustees, or auditor); and
Sharing with third parties
We may disclose your personal information to third parties outside of the Open Corporation, including:
- Those involved in providing, managing or administering your financial product or service
- Authorized representatives who may promote financial products or services on our behalf
- Real estate agents
- Our auditors or lawyers and other external advisers
- Fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature)
- Government or regulatory bodies (including the Australian Tax Office and Austrac) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities)
- Rating agencies to the extent necessary to allow the rating agency to rate particular investments
- Organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems
- Our joint venture partners that provide financial services such as investment management for us; * organisations that assist with our product planning, research and development
- Other organisations involved in our normal business practices, including our agents and contractors; and where you have given your consent
Sharing outside of Australia
We may disclose your personal information overseas. However, if we do disclose this information outside Australia, we will do so on the basis that the information will be used only for the purposes set out in this document and in accordance with applicable laws.
We may store your information in the cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be held. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Accessing and correcting information
Individuals have a right to request access to the personal information that Open Corporation holds about them and to request its correction.
If you have an inquiry or complaint about our information handling practices please contact us by calling 1300 649 564 or alternatively write to:
Open Corporation Privacy Officer PO Box 5266
Brandon Park, Vic 3150
It is our intention to resolve any complaint as quickly as possible and to your satisfaction.
If you are unhappy with the response provided by us, you may refer your complaint to the Office of the Australian Information Commissioner www.oaic.gov.au
Where you have consented to receiving direct marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time in the following way:
- Send a letter to Open Corporations Privacy Officer at:
Open Corporation, PO Box 5266 Brandon Park, VIC 3150, or send an email to: firstname.lastname@example.org;
- Advise us if you receive a marketing call that you no longer wish to receive these calls
- Use the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMS’s) to opt out of receiving those messages