Privacy Policy

Port Jackson Family Office (Licence) Pty Ltd

Our Commitment 
Port Jackson Family Office (Licence) Pty Ltd (Port Jackson) is committed to providing professional services and respecting the privacy of your personal information. We are bound by the Australian Privacy Principles and the Privacy Act 1988 (Cth).

This policy explains how Port Jackson will collect, store, verify, use and disclose the information we hold about you and the conditions under which your information may be accessed.

Collection of Personal Information
Port Jackson collects and maintains personal information that is necessary to enable us to deliver our services or products or otherwise for our primary business functions and/or activities.

In the normal course of our business we only collect information about you when you provide it to us or it is provided to us under your authority. We will collect personal information directly from you when you apply for a product or a service which we are obliged to do by law prior to providing you with a product or service. On occasions we may collect personal information about you from third parties, for example credit reporting agencies, share registries or regulatory authorities. Information that we collect will be limited to that required to provide you with our services.

What type of information does Port Jackson hold?
The type of information we collect and hold about you varies depending on the type of product or service you require.

The personal information we hold about you may include:

• Identification information such as your name, postal or email address, telephone numbers and date of birth;
• Details of your financial needs and objectives;
• Details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover and superannuation;
• Details of your investment preferences and aversion or tolerance to risk;
• Information about your employment details and history, employment circumstances, family commitments; and
• Any other relevant information that you provide to us to enable us to provide suitable recommendations.

Failure to provide the personal information referred to above may expose you to higher risks in respect of the recommendations made to you and may affect the adequacy or appropriateness of advice we give to you.

We will only collect, maintain and use your personal information to adequately provide services requested by you including:

• The review of your financial position, risk management and objectives;
• The preparation of financial recommendations; and
• The provision of financial planning advice.

In most circumstances, the information that we hold about you has been provided to us by you or under your authority. If we have received information that is not required to provide services to you, we will either advise you that we hold this information or destroy it.

Other purposes for which we may need to collect and use your personal information will include:

• To comply with legislative and regulatory requirements (including the AML/CTF Act 2006 (Cth);
• To enable us to perform administrative operations such as accounting, record keeping, and archival retrieval;
• To enable us to contact you when conducting marketing and to invite you to events that may be of interest; and
• To advise you of new services and/or products (unless you ask us not to contact you with this type of information).

We may take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation or we may verify with an employer that employment and remuneration information provided in an application for credit is accurate.

You may choose not to provide us with your personal information. In this case we would not be able to provide any services to you. Under the AML/CTF laws we must be able to identify our clients and verify that identity.

How does Port Jackson use this information?
We use this information to assess your risk tolerance and determine strategies and recommendations consistent with your financial needs, objectives and personal circumstances in order to be able to offer you products and services.

The information you provide to us about your health may be used to assess your risk tolerance and appropriate investment recommendations or to determine the suitability and correct pricing of risk products.

We may also use the information to send you material about other products or services. You can opt out of receiving this type of material at any time by contacting us using the contact details below.

Will Port Jackson disclose your personal information?
Port Jackson may share information with organisations that assist us to administer your investments or provide you with products and services. This includes our internal and external service providers such as administrators, fund managers and insurance companies. The organisations receiving this information are not permitted to use your information for any purpose other than for the specific purpose it was provided.

There are circumstances under which Port Jackson may disclose your personal information such as:

• Where the disclosure is required by law (for example, to the Australian Taxation Office, AUSTRAC or Centrelink); or
• Where the disclosure is authorised by law (such as where disclosure is necessary in the public interest or to protect the interests of Port Jackson).

We will also disclose your personal information to a third party if you provide your consent for us to do so.

Port Jackson works with a wide range of professional service providers in administering our clients affairs both within and outside Australia. Where you have approved a working relationship with an overseas professional (such as a lawyer, accountant, bank or property/investment management firm), we may provide your details to these providers and they may then hold your personal information. We will abide by our Privacy Policy when providing these services.

Port Jackson utilises Dropbox, a cloud server based in the United States, for sharing files both with our clients and with other specialists with whom we work to provide services to our clients. We have researched Dropbox and understand files shared via this provider are encrypted, providing adequate security to this information.

Who we may communicate with
Depending on the product or service you have, the entities we exchange your information with include, but are not limited to:

a) brokers and agents who refer your business to us;

b) affiliated product and service providers and external product and service providers for whom we act as agent (so that they may provide you with the product or service you seek, or in which you have expressed an interest);

c) auditors we appoint to ensure the integrity of our operations;

d) any person acting on your behalf, including your solicitor, settlement agent, accountant, executor, administrator, trustee, guardian or attorney;

e) your referee (to confirm details about you);

f) if required or authorised to do so, regulatory bodies and government agencies;

g) credit reporting agencies;

h) insurers, including proposed insurers and insurance reference agencies (where we are considering whether to accept a proposal of insurance from you and, if so, on what terms);

I) medical practitioners (to verify or clarify, if necessary, any health information you may provide);

j) other financial institutions and organisations at their request if you seek credit from them (so that they may assess whether to offer you credit);

k) investors, advisers, trustees and ratings agencies where credit facilities and receivables are pooled and sold (securitised);

l) other organisations who, in conjunction with us, provide products and services (so that they may provide their products and services to you); and

m) professional associations or organisations with whom we conduct an affinity relationship (to verify your membership of those associations or organisations).

Our user or disclosure of personal information may not be limited to the examples above.

How does Port Jackson handle a request for access to personal information?
Under the Australian Privacy Principles you are generally entitled to access the information we hold about you. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. We will endeavour to provide information requested within a reasonable time period. A reasonable time period will be no longer than 30 days after the request is received.

Port Jackson will respond to these requests in the same format as the request is received. For example, an email request will be responded to via email. A telephone request will be responded to over the phone.

Sometimes we will ask that you put your request in writing, for example, where you want copies of material or access to older information or files which are not current or it is necessary for us to retain record of your request.

You may also be required to identify yourself to our satisfaction.

There are certain conditions under which we may refuse you access to your personal information, such as when your request may unreasonably impact upon another person’s right to privacy. If we are entitled under the Australian Privacy Principles to refuse to give you access, we will advise you of the reasons for taking such a course of action.

We will not charge a fee for the provision of your personal information however we may charge a fee for any administration incurred in providing it to you. If a fee is applicable, we will disclose this to you prior to providing you with the information.

Storage and Security
We will at all times seek to ensure that the personal information collected and held by us is protected from misuse, loss, unauthorised access, modification or disclosure. At all times your personal information is treated as confidential and any sensitive information is treated as highly confidential. Your personal information is generally held in your client file which may be in hardcopy or electronic.

In the event you cease to be a client of Port Jackson, any personal information which we hold about you will be maintained in a secure offsite storage facility for a period of seven years in order to comply with legislative and professional requirements, following which time the information will be destroyed. Port Jackson will ensure that any documents that are destroyed are done so in a secure manner.

Email Communication
Port Jackson will use your email address that you have provided to contact you when necessary or to provide you with information you have requested.

We will also use your email address to alert you to marketing initiatives, newsletters, or events that may interest you.

If at any time you decide you do not wish to receive such marketing information you have the right to request not to be sent any further such material. You may do this by advising your adviser or by sending us an email with “Unsubscribe” in the subject line using the contact details below.

Please allow two weeks for this instruction to take effect.

Website
Port Jackson’s compliance with the Australian Privacy Principles also applies to your access to our website. Our privacy policy may be accessed from the website and other information is also posted here for your convenience.

Our website uses cookies which allow us to identify your browser while you are using our site. Whilst cookies do not identify you, they allow us to track usage patterns. If you do not wish us to utilise cookies, you can instruct your web browser to refuse them.

What if some of the information Port Jackson holds is wrong?
We want our records to be accurate, complete and up to date and we rely on the accuracy of the information to provide you with appropriate recommendations. Please advise us in writing of any changes or updates to your personal information. We will respond to any requests for correction within a reasonable time of receipt of the request. A reasonable time period will be no longer than 30 days after the request being received.

If we refuse to correct the Personal Information as requested by you, we will give you a written notice setting out the reasons for the refusal. Such reason will set out the grounds for refusal, the mechanisms available to complain and any other relevant matter.

If we refuse to correct the Personal Information as requested by you, you can request we associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.

Notifiable Data Breaches
The Privacy Act includes a Notifiable Data Breaches (‘NDB’) scheme which requires us to notify you and the Office of the Privacy Commissioner of certain data breaches that are likely to result in serious harm to affected individuals and provide recommendations of steps you can take to limit the impacts of the breach.

If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the Privacy Commissioner as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.

How do I make enquiries or complain about a breach of privacy?
If you wish to complain about any breach or potential breach of this privacy policy or the Australian Privacy Principles, you should contact us and direct your complaint to the Privacy Officer.

Attn: Privacy Officer
Port Jackson Family Office (Licence) Pty Ltd
PO Box R1696 Royal Exchange NSW 1225
Telephone: 02 8090 4515
Email: [email protected]
Website: www.pjfo.com.au

After a complaint has been received, we will send you a written notice of acknowledgement setting out the process within 7 days. The complaint will be investigated, and the decision will be sent to you within 30 days unless you have agreed to a longer time. If a complaint cannot be resolved within the agreed time frame or a decision could not be made within 30 days of receipt, a notification will be sent to you setting out the reasons and specifying a new date when you can expect a decision or resolution. We will use our best endeavours to resolve any complaint to your satisfaction; however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further

Office of the Australian Information Commissioner

Address: GPO Box 5218, Sydney NSW 2001

Phone: 1300 363 992

Email: [email protected]

Website: oaic.gov.au

Changes to this Privacy Policy
We reserve the right to review and amend this Privacy Policy from time to time but will advise you of any material changes.

Appendix – Disclosure to other countries
When required, personal information may be disclosed to third parties in jurisdictions including: Australia; Hong Kong; Singapore; Switzerland; United Kingdom; United States of America.