About this policy
We recognise that your privacy is important to you. This policy has been prepared to provide you with information on the collection, storage, use and disclosure of your personal information by us. When referring to personal information, we mean information that identifies an individual or from which an individual’s identity can reasonably be ascertained.
Collection of personal information
Generally, we will only collect personal information from you that is reasonably necessary for, or directly related to, one of more of the functions and activities of our business. For example, we may request that you provide your personal information when you instruct us to provide services, submit an application to invest or provide information to us via our website. There may be other occasions when we collect personal information from you or other sources, such as a publicly maintained record or from an information services provider. We may also share personal information about you with our related entities.
Information we hold about you may include things such as your name, date of birth, telephone numbers, email address, bank account details, investment information, tax file number, Government related identifiers (e.g., drivers licence or passport number) as well as any other information that may be required under Australian anti-money laundering legislation for identification and other purposes. In some circumstances, we may also hold other personal information you provide to us.
We do not collect or hold sensitive information, such as health information, racial or ethnic origins, religious affiliation or political opinions.
Personal information held by us is not organised by Government related identifiers. Government related identifiers are only used by us to verify the identity of our clients in connection with our business, e.g., as part of our requirements under Australian anti-money laundering legislation.
Use and disclosure of personal information
We will not use or disclose your personal information for any purpose other than:
- Where you have consented to such disclosure
- Where required or authorised by law.
- Providing you with access to our website.
- Facilitating our internal business operations, including improving our products, services or communication methods.
- Providing you with information about our products or services that may be of interest to you.
- To undertake market research and surveys.
- Administering and processing any applications you submit to us.
- Advising the Australian Taxation Office and other governmental authorities of your tax file number.
- To operate or manage investments, trusts or managed investment schemes, including entering your details on a register of members or making deposits of distributions to your nominated bank account.
- For accounting, billing and other internal administrative purposes.
- To identify your identity.
- To comply with our legal requirements under any applicable laws, including the anti-money laundering legislation.
- For the purposes for which it was provided for or for a related secondary purpose (or, in the case of sensitive information, a directly related secondary purpose) where you would reasonably expect us to use or disclose the information.
Under no circumstances will Warrington sell or receive payment for only disclosing your personal information to another party. However, if Warrington sells its business, then your personal details will be provided to the new owners and managers of the business.
As a general rule, we will not disclose your personal information to an overseas recipient without your consent, unless the disclosure is required by law. If disclosure to an overseas recipient is required, then we will take reasonable steps to ensure the recipient complies with the National Privacy Principles.
Disclosure of personal information
The types of organisations to which we may disclose the personal information you provide us with include:
- Your financial advisers or other professional advisers.
- Any third party service provider which we may engage to provide due diligence, compliance, custody, administration, technology, auditing, mailing, printing or other services.
- Government authorities such as the Australian Taxation Office or the Australian Securities and Investments Commission where required to by law or where reasonably requested.
- Our professional advisers, including legal and accounting firms, auditors, consultants and other advisers.
- Our related bodies corporate or any other company within the Warrington group.
Information storage and security
We will take reasonable steps to ensure that the personal information we hold is protected from misuse, loss and unauthorised access, modification or disclosure. We store personal information in our computer databases and we may also utilise the services of third party storage providers, which store data in the United States, North America, Asia, European Union or any other country in which the provider or its affiliates, subsidiaries or service providers maintain facilities.
Various security measures are in place to safeguard personal information, including restricted staff
access, password restricted access, internet based security tools (e.g., firewalls, virus protection programs), an information technology disaster recovery plan; and we perform regular back-ups and secure off site storage of date. Where we utilise third party storage providers, then we must take reasonable steps to ensure they use adequate security technologies and procedures.
In the event you cease to be a client of Warrington, personal information we hold about you will be maintained for at least as long as we are required to comply with legislative document retention requirements. After that time, we may destroy your personal information or put it beyond use, e.g., de-identify the personal information so we cannot use the information.
Accessing your personal information
You may request access to your personal information at any time. Upon confirmation of your identity, we will provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information.
We will not provide you with access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.
The National Privacy Principles place other restrictions on accessing your personal information. Restrictions include the following:
- Giving access would have an unreasonable impact on the privacy; or would pose a serious and imminent threat to the health or safety of any individual or to the public.
- The request for access is frivolous or vexatious.
- The information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings.
- Giving access would reveal commercially sensitive information or our intentions which may prejudice any negotiations with you.
- Giving access would be unlawful or would be likely to prejudice a criminal investigation.
- Denying access is required or authorised by or under law or a court/tribunal order.
- Giving access would be likely to prejudice enforcement related activities by or on behalf of an enforcement body.
If we decline your request for access, we will provide a written explanation to you for the refusal.
Correcting your personal information
We will take reasonable steps to ensure that the personal information we collect is accurate, up to date and complete. If you provide evidence to us that the personal information we hold about you is inaccurate, incomplete or out of date, then we will take all reasonable steps to correct it.
Complaints about privacy
We are committed to providing you with a fair and responsible system for handling complaints. If at any time you have any complaints in relation to privacy, please contact our Privacy Officer and provide details of your complain in writing. We will try to resolve any concerns you may have to your satisfaction within a reasonable time (usually 30 days). If you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner (telephone 1300 363 992) who may investigate your complaint further.
More information on privacy
We are required to comply with the Privacy Act 1998 (Cth) and the National Privacy Principles. A summary of the National Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
Our contact details
Warrington Management Pty Ltd
ABN 52 132 925 038
Warrington Capital Pty Ltd
ABN 39 157 880 745
AFS licence 420784
Telephone: +61 8 6143 4577
Facsimile: +61 8 9321 5290
Address: 22 Delhi Street, West Perth WA 6005
Post: PO Box 1055, West Perth WA 6872
Any questions or complaints may be directed to our Privacy Officer.