PRIVACY ACT 1988 (THE ACT)
What is this policy about?
This policy has been created to provide a clear understanding of how Seed Partnerships collects, uses, stores, discloses and protects personal information in all of its activities and capacities.
Under the Act, ‘personal information’ is defined as any “information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not”
Seed Partnerships commitment to privacy
Seed Partnerships aims to take all reasonable steps to protect the privacy of the personal information it collects. Maintaining the privacy of our clients is very important to us and we recognise clients will want to know how we deal with the personal information we collect about them. This policy sets out our approach to protecting the privacy of all our clients and contacts in accordance with the law. We are happy to answer questions at any time. Contact details for our Compliance Director are listed at the end of this document.
What type of personal information do we collect and hold?
We will only collect information that we believe to be relevant and required to provide our service to our clients (where appropriate) and to the conduct of our business.
Due to the nature of our business and services we provide we are unable to offer our services to clients on an anonymous basis or under a pseudonym.
How do we collect personal information?
In the general conduct of our business we may be required to collect, hold and use personal information. We will generally collect such personal information from you directly in person, through telephone conversations, written correspondence, through our website when you log in, or through an authorised third party. Where required we may also obtain personal information from third parties including public registers, regulatory authorities and/ or credit reporting providers.
Why do we need personal information?
We need a certain amount of personal information regarding our business or corporate contacts in order to conduct our business effectively and efficiently. We will use client information and to provide better customer services and products.
Do we give personal information to any other person or organisation?
Seed Partnerships do not provide personal information to any other person or organisation locally or internationally. All Seed Partnerships companies and our staff with permitted access to client information are specifically required to observe our confidentiality obligations.
We may be required, from time to time, to disclose client information to Governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority. We will not disclose client information to any external organisation unless we have client consent or are required by law or have previously informed the client.
Security of personal information
Internet Site Privacy
Seed Partnerships internet site may use technology to monitor traffic through the site, but this is done without collecting personal information.
This information is used where relevant in servicing our clients and in the conduct of our business in general and is not disclosed.
Accessing your personal information
Privacy laws give a right of access to the personal information we hold, subject to exceptions allowed by law. Seed Partnerships will provide access to personal information to the individual who is the subject of the information. Clients and contacts can ask to inspect and copy this information, and ask us to update or correct it by contacting the Privacy Officer.
Any complaints about the information we have collected and/ or how we have handled, used or disclosed such information should be directed to our Privacy Officer who will contact you within 5 business days after receiving your complaint to discuss the complaint and work with you towards a resolution.
If resolution is not achieved in the first instance, we will take steps to conduct a thorough investigation of the matter. Investigation of complaints may take up to 21 days, (longer for complex matters) requiring you to provide us with as much detailed information and supporting documentation as possible, in relation to the matter. Once we have finalised our investigation we will organise to meet with you to discuss findings and proposed resolution.
If we cannot reach a satisfactory resolution within 45 days, you can raise your concerns with the
Financial Ombudsman Service (FOS).
GPO Box 3
Melbourne VIC 3001
T: 1800 335 405
F: (03) 9613 6399
Seed Partnerships is a member of FOS (Member number 39201).
You should note that FOS may at its discretion decide not to deal with a complaint made by a person who is not a retail client. This means that complaints by wholesale clients are not automatically excluded. FOS will deal with a complaint by a wholesale client until and unless a decision is made under Rule 14.2. There are some monetary limits for FOS complaints. The current limits can be obtained from the FOS website.
The Australian Securities & Investments Commission (ASIC) also has a free call Infoline on 1300 300 630 which you may use to obtain information about your rights.
Seed Partnerships may update this Policy from time to time to ensure that it reflects current regulatory and statutory obligations. A current and updated version of this policy will be posted on our website and a copy may be obtained by request from our Privacy Officer
Privacy Officer Contact Details
Level 10, 135 Macquarie Street
Sydney NSW 2000