Avanteos Privacy Policy

At Avanteos the privacy of your personal information is important to us. We collect personal information to make and maintain an investment, on behalf of you. In some circumstances the law may also require us to collect personal information.

The Privacy Act 1988 (Cth) defines personal information as information or an opinion about an individual whose identity is apparent or can reasonably be ascertained. It includes your name, age and contact details as well as your financial information.

The following statement outlines our general information handling practices, and is generally reflected in our offer documents.

Background

Privacy Act 1988 (Cth)
The Privacy Act 1988 (Cth) (implementing the National Privacy Principles) includes provisions that regulate the way private sector organisations collect, use, disclose, keep secure and provide access to personal information.

Avanteos is bound to protect your personal information in accordance with the National Privacy Principles to the extent required by the Privacy Act 1988 (Cth).

This document
This document gives information on how we protect the personal information we hold about you.

The aim of the Avanteos privacy policy is to inform you that the personal information you provide to Avanteos will be dealt with in accordance with this policy. We acknowledge that circumstances may change and our policy will be reassessed accordingly.

How is my personal information dealt with?

Your personal information may be used by us to administer, monitor and evaluate products and services, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. We may also be allowed or obliged to disclose information by law and to report on prudential or risk management matters to regulators and our related bodies. We may also be required by a Government Agency to produce information and records, for example, pursuant to taxation or social security laws.

Telephone calls received may be monitored for quality assurance purposes.

In the course of doing business we outsource certain tasks to third party suppliers. In these circumstances we may disclose your personal information to third parties including mailing houses, information technology support and email suppliers. From time to time we also seek expert help to improve our systems, products and services. These third parties are bound by confidentiality arrangements when handling your personal information.

Your personal information is also made available to your licensed financial adviser/planner and the Promoter/Sponsor of the product you are invested in. As part of your application, you authorise for this information to be made available. The Avanteos group is a subsidiary of the Commonwealth Bank of Australia, and in applicable circumstances, personal information may be provided to other members of the Commonwealth Bank Group.

We aim to ensure that the personal information we retain about you is accurate, complete and up-to-date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking.

If you have any questions or would like further information on our privacy and information handling practices, please contact us by calling our Privacy Officer on 1800 113 116, or emailing us at privacyofficer@avanteos.com.au.

Collection of personal information

What is 'personal information'?
Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Why we collect information
Personal information is collected so that we may:

• administer our customer relationships;
• make and maintain investments for an investor via the Avanteos platform.

We may also use personal information for other purposes such as:

• monitoring and evaluating products and services;
• gathering and aggregating information for statistical prudential, actuarial and research purposes;
• assisting customers with queries; and
• taking measures to detect and prevent frauds.

What we collect
Avanteos collects personal information on investors via application forms, other Avanteos forms, phone, fax, email and online.

Personal information collected from investors includes:

• name
• contact details
• Tax File Number, exemption reason or country of residence
• bank account information
• investment information
• employment information
• health and lifestyle information (if you are applying for insurance)

What if you provide incomplete or inaccurate information?
We may not be able to provide you with the products or services you are seeking.

Obtaining your consent
The main purpose for Avanteos collecting your information is to make and maintain investments made by you under the Avanteos platform.

We obtain your consent when you join the service. This is through the acceptance of the declarations and agreements outlined in the Product Disclosure Document or the Investor Directed Portfolio Guide (IDPS) Investor Guide and application form, provided to you by your financial adviser.

Personal Information Quality

We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. Please contact us by calling our Privacy Officer on 1800 113 116, or emailing us at privacyofficer@avanteos.com.au, if any of the details you have provided change. Please also contact us or your financial adviser/planner if you believe that the information we have about you is not accurate, complete or up-to-date.

Personal information security

We are committed to keeping secure the personal information you provide to us. We take all reasonable precautions to protect the personal information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.

We have a range of physical and technology policies in place to provide a robust security environment. We ensure the on-going adequacy of these measures by regularly reviewing them.

Our security measures include, but are not limited to:

• restricting access to our computer systems and physical records to authorised persons and preventing users from accessing information they have no need to access;
• requiring employees to use unique passwords to gain access to systems;
  employing firewalls and virus scanning tools to prevent unauthorised persons and viruses from entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing;
• providing secure storage for physical records; and
• detecting and preventing unauthorised access to buildings by employing physical and electronic means such as alarms, cameras and guards as required.

Where information we hold is identified as no longer needed for any purpose we take reasonable steps to effectively and securely destroy it.

Online services

Collection of information via website activity
For statistical purposes we collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website.

We may also collect your personal information via your use of our website. Generally, the information that we collect is what you give us when you complete a form or otherwise make an enquiry via the website.

Cookies
A 'cookie' is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer.

To evaluate the effectiveness of our website, we may use third parties to collect statistical data. No personal data is collected on these occasions.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our websites.

Links to other websites
Our website may contain links to non-Avanteos and -Symetry Portfolio Service websites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.

Changes to our privacy and information handing practices

Avanteos may make changes to the privacy and information handling practices from time to time for any reason. We will publish those changes on our website and, if there are important changes or a lot of minor changes, by updating this document.

Access to personal information
You can request us to provide you with access to the personal information we hold about you.

In most cases, your personal information is accessible to you via:

• written request
• fax request
• phone request
• email request

Please also contact us or your financial adviser/planner if you believe that the information we have about you is not accurate, complete or up-to-date.

Jointly held information
Where we hold your personal information in conjunction with that of another individual or individuals, (e.g. where you jointly conduct an account), we will allow each individual access to their own personal information and to the joint information (e.g. account balances and transaction details) but not to the personal information of the other individual(s).

You may also have consolidated reporting set up, which enables investments you hold in multiple products to be consolidated on reports. It is also possible to include investments held by other members of your family, family trusts and businesses in the one report. This will mean that the other individuals may have access to your personal information. If your object to other members within the same client file having access to your personal information please contact us.

Responding to an access request
We will respond to your access request as soon as possible. There is no charge for access to your personal information.

Contact us about our privacy and information handling practices

If you have any questions or would like further information about our privacy and information handling practices, please contact us by:

• calling our Privacy Officer on 1800 113 116, or
• emailing us at privacyofficer@avanteos.com.au

If you have any concerns or complaints about our privacy and information handling practices, please contact us as above. We will acknowledge your concern promptly, investigate the concern, and reply to you, advising of any decision and informing you of any remedies available, including possible appeal through dispute resolution bodies.