Privacy Policy

Privacy Policy

Version 9 201503

Members of our Group

• Infocus Securities Australia Pty Ltd ABN 47 097 797 049
  (Holds an Australian Financial Service License and an Australian Credit License No 236523)
• PATRON Financial Services Pty Ltd ABN 13 122 381 908 atf the PATRON Financial Trust ABN 32 307 788 137 trading as PATRON Financial Advice (PATRON)
  (Holds an Australian Financial Services Licence Number 307379)
• Alpha Fund Managers Pty Ltd ABN 37 124 085 883
  (Investment Manager for the Alpha Fund Series)
• Commission Refunders Pty Ltd ABN 35 151 902 457
  (Provides commission collection services)
• Portfoliofocus Pty Ltd ABN 49 098 278 589
  (Marketing and promotional services)
• Portfolio Administration and Reporting Pty Ltd ABN 85 145 006 757
  (Marketing and promotional services)
• Platformplus Pty Ltd ABN 46 103 551 533
  (CRM and Service Management software)

Collection of your Information

• Your contact details including names, address, phone and email address;
• details of your financial needs and objectives and what hardship means to you;
• personal details including your date of birth, associated entities, visa and residency status, private healthcare and smoking status;
• your occupation, marital status, financial dependants and identification details such as copies of birth certificate or drivers licenses or other documentation;
• details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover, general insurance, superannuation and taxation;
• details of your investment preferences, past experience and aversion or tolerance to risk;
• details of any professional advisers you engage with;
• estate planning details;
• information about your employer, your employment history including future, family commitments including dependents and social security eligibility;
• your tax file number;
• personal and family medical history and /or lifestyle pursuits; and
• your agreement to grant access to a spouse or partner’s information.

• preparation and provision of initial financial advice;
• preparation and provision of ongoing financial advice;
• placement of financial products including purchase, variation or redemption of investments;
• provision of a financial service, such as actioning share buy/sell instructions;
• provision of a financial service, such as purchase, variation or cancellation of insurance products;
• set up and administration of a Self-Managed Super Fund;
• providing assistance with ancillary services such as Centrelink;
• providing assistance with the coordination of other providers or experts such as solicitors, accountants etc;
• providing credit assistance such as assisting to establish, terminate or vary a loan contract; and
• providing credit services by sourcing and recommending appropriate loan arrangements.

Use and disclosure

• the purposes for which it was provided or secondary related purposes in circumstances where you would reasonably expect such use or disclosure; or
• where you have consented to such disclosure; or
• where the Australian Privacy Principles authorise use or disclosure where required or authorised under law, in circumstances relating to public health and safety and in connection with certain operations by or on behalf of an enforcement body.

• other entities who refer your business to us;
• affiliated product and service providers as well as external service providers such as superannuation fund trustees, insurance providers, and product issuers for whom we act as agent (so that they may provide you with the product or service that you seek or in which you have an express interest);
• auditors we appoint to ensure the integrity of our operations;
• suppliers from whom we order goods and services on your behalf (so that those goods and services can be provided to you);
• other persons acting on your behalf including your accountant, solicitor, executor, administrator, trustee, guardian or attorney;
• if required or authorised to do so, regulatory bodies and government agencies;
• medical assessment services where you have sought insurance for the purposes of underwriting your policy;
• other organisations who in conjunction with us provide their products and services (so that they may provide their products and services to you); and
• other Australian Financial Services Licensees or Authorised Representatives or their agents for the purpose of due diligence on one of our associated entities were they were to decide to sell all or part of their business. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer and your information will not be exchanged if you object to the transfer.

• your personal information may be accessed by our Group staff, representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;
• from time to time, information may be loaded to the cloud for storage or access through programs such as Dropbox etc; and
• it is possible that product and services providers we recommend may outsource functions using overseas contractors or companies that process these services using offshore resources. Where this is a concern to you, we suggest that you carefully read their privacy policy to determine the extent to which they send information overseas.

Accessing and correcting your information

• providing access would pose a serious threat to the life or health of a person or the health and safety of the public;
• providing access would have an unreasonable impact on the privacy of others;
• the request for access is frivolous or vexatious;
• the information related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful;
• denying access is required or authorised by or under law;
• Infocus has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to its functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
• providing access is likely to prejudice actions being conducted by an enforcement agency; or
• providing access would reveal evaluative information generated within Infocus in conjunction with a commercially sensitive decision making process.

• educating our authorised representatives and staff as to their obligations with regard to your personal information;
• all hard copy files are stored in lockable cabinets/rooms;
• access to our premises is controlled by only allowing authorised personnel to access those locations where personal information is stored;
• all computer-based information is protected through the use of access passwords on each computer and screen saver passwords;
• client data is backed up each evening and stored securely off site;
• encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; and
• providing secure storage for physical records.

• Gather all the supporting documents about the matter of the complaint. Think about the questions you want answered and decide what you want us to do.
• Contact the relevant group member where your situation will be reviewed and if possible resolved straight away.
• If at this stage the matter has not been resolved to your satisfaction, please contact the Professional Standards team using the contact points listed above. We will provide you with the contact details of the person who will investigate your complaint, answer your questions and do all they can to regain your confidence. We aim to resolve complaints within a few days, however some are more complex than others. We promise to provide our response within a maximum of 45 days.