CROWN WEALTH GROUP – PRIVACY POLICY

Your Privacy is important to us

This document outlines our policy on how Crown Wealth Group and our Authorised Representatives manage personal information we hold. It is Crown’s policy to respect the confidentiality of information and the privacy of individuals. Crown is bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This statement will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Any information we hold will be governed by the most current Crown Privacy Policy.

The purposes for which Crown collects personal information

We collect and hold information about you that is both relevant and necessary in order for us to provide you with financial services. The types of information we hold depend on the services provided and unless informed otherwise, the personal information we hold is mainly used for establishing and managing the financial products or services for you and reviewing your ongoing needs.

Collecting personal information also allows us to meet legal obligations we might have including those under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), the Corporations Act 2001 (Cth) and the U.S. Foreign Account Tax Compliance Act 2010.

What kind of personal information do we ask for?

Because of the nature of the products and services provided, as well as Australian and international government regulations and taxation laws, we may ask for a range of personal information.

The type of personal information we collect may include (but is not limited to) name, address, date of birth, contact details, income, assets and liabilities, account balances, tax and financial statements, employment details and citizenship status.

We sometimes need to collect and use sensitive information, such as when completing insurance applications or when making a claim. The APPs set out restrictions about the way sensitive information can be used. Unless you give us 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.

Will my personal information be used for Direct Marketing?

We will not use your personal information for direct marketing purposes unless:

• we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and

• we have provided you with a simple means to ‘opt-out’ from receiving direct marketing; and

• we have not received such a request from you. We will not use any sensitive information collected from you for direct marketing purposes.

  How do we collect information?

  Crown may collect your personal information in a number of ways including:

  • where reasonable and practicable, we obtain personal information directly from you (including via phone, email or in an application form) and from maintaining records of information provided in the course of ongoing financial planning advice;

  • from third parties such as credit reporting agencies or client representatives. We may also obtain information from other sources such as lawyers or accountants if they have been authorised by you. When we are provided with personal information about a third party, we will require that third party to be informed of certain matters, such as Crown’s identity and our contact details;

  • from publicly available sources of information.
    What happens if you choose not to provide the information that has been

    requested?

    If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service. It may also affect our ability to properly analyse your personal circumstances.

    Can you remain anonymous or use a pseudonym when dealing with us?

    In most cases it will be impracticable for us to assist you if you wish to remain anonymous or to use a pseudonym when dealing with us. For example, we may be unable to provide the specific product or service you want. It may also affect our ability to properly analyse your personal circumstances so our recommendations may not be completely appropriate or suitable for you.

Who may we disclose personal information to?

Depending on the product or service concerned, personal information may be disclosed to:

• Authorised Representatives and those who are authorised by Crown to review your needs and circumstances from time to time;

• Service providers and specialist advisers to Crown who have been contracted to provide Crown with administrative, financial, insurance, research or other services;

• Other insurers and credit providers

• Courts, tribunals and other dispute resolution bodies in the course of a

  dispute;

• Regulatory Authorities (such as ATO, APRA, ASIC)

• Anyone authorised by you or to whom you have provided your consent (either expressly or impliedly), including but not limited to other financial services providers that we may need to deal with on your behalf;

• Anyone authorised by law to obtain information about you;

• Other financial services institutions in order to detect, investigate or prevent actual or potential fraud in connection with the products or services we provide to you.

  Management of personal information

  Crown trains its employees and Authorised Representatives who handle personal information to respect the confidentiality of customer information and the privacy of individuals. Crown regards breaches of your privacy very seriously and may take disciplinary action.

  Storage of personal information

  Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium.

  We hold personal information in a combination of secure computer storage facilities, paper-based files as well as in other formats. We take steps to protect personal information we hold from misuse, loss, unauthorised access, modification or improper disclosure. We may need to maintain records for a significant period of time. We will retain a copy of any recommendations made to you for seven years. However, once we consider information is no longer needed, we will de-identify the information or securely destroy the records.

How do we keep personal information accurate and up-to-date?

Crown and its Authorised Representatives endeavour to ensure that the personal information it holds is accurate and up-to-date. We realise that this information changes frequently with changes of address and other personal circumstances. We ask that you keep us informed of any changes by notifying us. We can generally update your customer information over the telephone, mail or via email and will seek to correct your information once notified within 14 days.

Overseas disclosures

For the purposes of advice documentation creation, audit and administrative tasks, Crown or its Authorised Representatives may transmit personal information to service providers located in The Philippines.

Your right to request what personal information about you is held by us

Under the Privacy Act, you generally have the right to access any personal information that Crown holds about you, unless a particular exception applies, such as where:

• giving access would have an unreasonable impact on the privacy of other individuals;

• giving access would be unlawful, or where denying access is required or authorised by an Australian law or a court order;

• both of the following apply:
  - we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our 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;
  - giving access is likely to interfere with law enforcement activities;

  - it would pose a serious and imminent threat to the life or health or any individual; or

  - the request is frivolous or vexatious.

  To make a request, you will need to specify in writing the information you require and provide documentation verifying your identity. We will acknowledge your request within 14 days and will respond promptly to your request. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material that you have requested. If the information sought is extensive, we will advise you of the likely cost in advance and can help to refine your request if required.

How do you make a complaint concerning your privacy?

You can make a complaint at any time by contacting your Authorised Representative who will seek to resolve your complaint within 3 working days. If you feel your complaint has not been satisfactorily addressed in the first instance, you can ask for your concerns to be escalated to Crown Wealth Group Pty Ltd or you may contact us in one of the following ways:

• By post: Crown Wealth Group - Level 1, 58 Pitt Street, Sydney 2000

• By email: [email protected]

• By telephone: 1300 722 174

  In most cases we will contact you within 5 working days of receiving your complaint to advise you what actions we intend to take regarding the matter.

  If you still have concerns, further assistance may be available from: The Financial Ombudsman Service on 1300 780 808 or the Office of the Australian Information Commissioner on 1300 363 992.