Our Commitment

Market Partners is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you. The Privacy Amendment (Enhancing Privacy Protection) Act sets out a number of Australian Privacy Principles (APPs). Our aim is to both support and ensure that we comply with these principles. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

Market Partners believe that this Privacy Policy discloses how the personal information you provide to us and our representatives, is collected, used, held, disclosed and disseminated.

Market Partners is required to meet particular legislative and regulatory requirements. In order to provide comprehensive investment & financial planning advice to you, we are required to collect certain personal information from you for the purposes of:

• Providing you with the relevant product or service.
• Managing and administering the product or service.
• Protecting against fraud.

We encourage you to check our website regularly for any updates to our Privacy Policy.

Your Personal Information

As a financial services organisation, we are subject to certain legislative and regulatory requirements which necessitate us to obtain personal information about you, including s961B of the Corporations Act. Detailed below is some of the information you are required to provide:

• Your name, date of birth, tax file number, current addresses, telephone/mobile/fax numbers, e-mail address
• Information regarding your dependents and family commitments
• Your occupation, employment history, details family commitments, social security eligibility, health information or other information the organisation considers necessary
• Your financial needs and objectives
• Your assets and liabilities (current and future), income, expenses
• Your superannuation and insurance details
• Your social security entitlements
• Your risk profile details

How we collect Personal Information

Market Partners collects personal information in a number of ways, including:

• Directly from you, when you attend a face-to face interview.
• Directly from you, when you provide information through a data collection form.
• Directly from you, when you provide information by phone.
• Directly from you via an email or the internet.
• Directly from fund managers, superannuation funds, life insurance companies and other product issuers once authorisation has been provided by you.

You have a right to refuse us authorisation to collect information from a third party.

How we use your Personal Information

The information in this document details how we comply with the Privacy Act, including:

• What is the purpose?
• Who is my information disclosed to?
• What law requires collection?
• What are the consequences?

Primarily, your personal information is used in order to provide comprehensive and/or limited financial planning services to you. We may also use the information that is related to the primary purpose, and it is reasonable for you to expect the information to be disclosed.

From time to time we may provide you with direct marketing material. This will include articles and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any further, you may contact us with this request. We will endeavor to meet your request within two weeks. We maintain a register for those individuals not wanting direct marketing material.

If you provide inaccurate or incomplete information, we may not be able to provide you with the products or services you are seeking.

When we disclose your Personal Information

In line with modern business practices common to many financial institutions, and to meet your specific needs, we may disclose your personal information to the organisations described below. The Corporation’s Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you. We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. For the purposes set out above, we may disclose your personal information to organisations outside Market Partners. The organisations to which we disclose information may include:

• Market Partners Licensees including;  Market Matters Pty Ltd & PGW Financial Services Pty Ltd
• Superannuation fund trustees, insurance providers, fund managers and other product providers in order to manage or administer your product or service.
• Compliance consultants to ensure that our representatives are meeting our compliance standards.
• Your professional advisers, including your solicitor or accountant as authorised by you.
• Information technology service providers to maintain, review and develop our business systems, procedures and infrastructure including testing or upgrading our computer systems.
• Government and regulatory authorities and other organizations, as required or authorised by law, for example, to government or regulatory bodies for the purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue.

In addition, our employees and the out- sourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Market Partners.

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your Tax File Number, Medicare Number or Pension Card Number, we do not use or disclose this information other than when required or authorised by law, or unless you have voluntarily consented to disclose this information to any third party.

Notifying Data Breach Scheme

We may be required to make mandatory disclosures of any data breach we experience in accordance with the Notifiable Data Breach Scheme (Australia) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth). If we are required to make a mandatory disclosure under the data breach act and that data breach relates to your information, we will notify you as soon as practicable in the manner required by the Scheme.

Dealing with us anonymously

You can deal with Market Partners anonymously or by using a pseudonym where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

Your sensitive information

Without your consent, we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record. This is subject to some exceptions including:

• When the collection is required by law.
• When the information is necessary for the establishment, exercise or defense of a legal claim

Comply with the Age Sensitive Content of Commercial Communication

Where the content of a commercial communication seeks to promote or inspire interaction with a product, service or event that is age sensitive, Market Partners will take reasonable steps to ensure that such content is sent to recipients who are legally entitled to use or participate in the product service or event.

Our Website

Market Partners website provides links to third-party websites. The use of your information by these third-party sites is not within the control of Market Partners and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy stands, policies and procedures.

You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database. We take care to ensure that the personal information you give us on our website is protected. For example, our website has electronic security systems in place, including the use of firewalls and data encryption. If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us.

We will endeavor to meet your request within five working days. Our website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site – they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Spam Act

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’. Market Partners don't usually collect unsolicited personal information. Where Market Partners receive unsolicited personal information, Market Partners will determine whether or not it would have been permissible to collect that personal information if it had been solicited. If Market Partners determine that collection would not have been permissible, to the extent permitted by law, Market Partners will destroy or deidentify that personal information as soon as practicable.’ ‘Electronic messaging’ covers emails, instant messaging, SMS, and other mobile phone messaging, but not cover normal voice-to-voice communication by telephone. Market Partners Financial Services Pty Ltd and Market Partners Private Pty Ltd complies with the provisions of the Spam Act when sending commercial electronic messages. Equally importantly, Market Partners make sure that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information. Personal information includes our clients’ contact details

Internal procedure for dealing with complaints

The three key steps Market Partners follow:

• Consent – Only commercial electronic messages are sent with the addressee’s consent, either express or inferred con- sent.
• Identify – Electronic messages will include clear and accurate information about the person and the Market Partners representative that is responsible for sending the commercial electronic message.
• Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic messages, and deal with ‘unsubscribe requests’ promptly

Consent to communications

Commercial messages will only be sent to you when you have given consent. This may be express consent – a direct indication that it is okay to send the message, or messages of that nature or inferred consent based on our business or other relationship with you and your conduct.

Comply with the law regarding viral messages

Market Partners ensures that commercial communications that include a forwarding facility contain a clear recommendation that the recipient should only forward the commercial communication to persons with whom they have a relationship, where that relationship means that person could be said to have consented to receiving commercial communications.

Complaints Resolutions

Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 7 days. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Privacy Commissioner.

Updates to our privacy policy

Market Partners will review and update this privacy policy as needed. Please check back regularly for any updates.

If you have any questions regarding our privacy policy, you can reach us here:

• Suite 4, Level 11, 54 Miller Street, North Sydney, NSW 2060
• Email: portfolio@marketpartners.com.au