AAM Investment Group

Introduction

This IP Holdings Privacy Policy applies when you sign up for, access, or use our services (including the IP Holdings Online Investment Platform, the iPlatforms Online Investment Platform and the white labelled client specific websites which include iPlatforms.com.au in the url) or sign up to receive information from us regarding our current or future services (collectively the ‘IP Holdings Service’) and in relation to personal information we may otherwise collect during the course of our business as set out in this Privacy Policy.

If this Privacy Policy appears on a white labelled client specific website which includes iPlatforms.com.au in the url, we have partnered with a third party whose privacy policy may also be relevant to you (see below, if applicable, reference to Badged Platforms).

This privacy policy (‘the ‘Privacy Policy’) applies to iPartners Holdings Pty Ltd (ABN 62 646 618 206) ('IP Holdings') and its related bodies corporate, (‘IP Holdings’, ‘we’, ‘us’ or ‘our’), and details how we collect, manage and use personal information, including personal information collected by us through our websites at ipartners.com.au, ipartners.iplatforms.com.au and at our white labelled client specific websites which include iplatforms.com.au in the url (the ‘Websites’).

Throughout this Privacy Policy, we use the term “personal information” to describe information that is associated with a specific person and can be used to reasonably identify that person. Personal information does not include information that has been made anonymous and cannot reasonably identify a specific person.

IP Holdings is committed to respecting the privacy of your personal information and complying with the Privacy Act 1988 (Cth) (‘Privacy Act’). We appreciate that individuals are concerned about the security of their personal information and we are committed to protecting any personal information we hold.

IP Holdings may amend this Privacy Policy at any time. The updated version will be available by following the ‘Privacy Policy’ link on the Website. The revised version will be effective from the time we post it on the Website. From time to time, IP Holdings may highlight major changes to the Privacy Policy on its homepage or by contacting you directly, but we recommend you check the Privacy Policy regularly for changes.

Collecting personal information

IP Holdings will be fair and open about the way we collect information about you and what we intend to do with the information.

When you visit our Websites or use the IP Holdings Service, we may collect information sent to us by your computer, mobile phone or other access device. The information sent to us may include data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit our Websites or use the IP Holdings Service, we may also collect information about your transactions and your activities. Details on our collection of personal information through the use of cookies and analytical services is set out below.

In addition, if you register your interest in, sign up for or use the IP Holdings Service, we may collect the following types of information:

Contact information, such as your name, address, phone number, email and other similar information.
Financial information, such as the full bank account numbers and/or credit or debit card numbers that you use in connection with the IP Holdings Service.
Detailed personal information such as your date of birth, drivers licence number or other identification information or documents.

We may obtain information about you from third parties, including credit reporting bodies and identity verification services, third party referees you authorize us to contact, and publicly or commercially available sources for the purposes of complying with relevant legislation (EG: anti-money laundering laws).

We may collect your personal information if you apply for employment with us either directly or through a recruitment or employment agency.

We may also collect the personal information of our suppliers and service providers staff during the course of our business activities. This information may include your name, contact details and position. We will collect this information directly from you, or from the applicable supplier or service provider.

In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with our Website or the IP Holdings Service. For example, we may evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

Using personal information

IP Holdings collects, holds and handles information about you necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by an Australian law or court or tribunal order.

We may use personal information we collect about you for a number of purposes including, but not limited, to:

provide you with information regarding the IP Holdings Service, our future services and developments;
provide the IP Holdings Service and customer support;
process transactions and send notices about your transactions;
resolve disputes, collect money, and troubleshoot problems;
investigate and prevent potentially prohibited or illegal activities;
enforce the terms of our agreements with you;
customise, measure, and improve the IP Holdings Service and the content, layout, and operation of our Websites;
onboard you, port your information or data or otherwise make your data or information available on any one or more of the Websites, whether or not you have signed up or accessed or used our IP Holdings Service directly, through an adviser or otherwise through a third party provider;
deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
contact you via telephone, text (SMS) or email messaging;
compare information for accuracy and verify it with third parties;
confirm your identity for the purposes of the Anti-Money Laundering and Counter-Terrorism Act and assess applications and your suitability for IP Holdings Services;
to consider you for a position at IP Holdings for which you have applied;
to acquire goods or services from you or from your employer;
for the purpose of performing data analytics including to improve our services;
for other purposes to which you have consented; and
as required or permitted by relevant laws and regulations.

You agree that we may use your personal information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.

If all or some of your personal information is not collected or cannot be verified, we may be unable to provide you with the IP Holdings Service, engage with you, or do business with you.

How we share personal information with other parties

We may share your personal information with:

Our service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, and technology services;

Third party referees nominated by you;
Third parties that we may partner with to jointly create and offer a product, or who offer a product or service that may be of interest to you;
Credit reporting bodies and collection agencies to report account information, as permitted by law. To request a credit report, we will provide information to the credit reporting body that identifies you;
Companies that we plan to merge with or be acquired by or who may invest in us;
Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to IP Holdings or one of its affiliates; when we need to do so to comply with law or credit card rules; or when we believe, in our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate suspected violations of our User Agreement; and
Other third parties with your consent or direction to do so.

Please note that these third parties may be in other countries where the laws on processing personal information may be less stringent than in Australia. When we disclose your personal information overseas, we will take reasonable measures to ensure that your information is held, managed and accessed in accordance with the standards that apply in Australia, including the Australian Privacy Principles.

We will only share your personal information with third parties as described in this Privacy Policy or as otherwise notified to you at the time of collection or with your consent.

Consent

We may require your consent to use and/or disclose your personal information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to IP Holdings collecting, using and/or disclosing your personal information for such other purposes, this may affect IP Holdings’ ability to deliver and improve our products and services, or to engage or do business with you.

Marketing and privacy

IP Holdings sends marketing materials to its customers, and other people who have provided IP Holdings with personal information, from time to time about products and services offered by IP Holdings, its related entities and affiliates.

If you do not wish to receive marketing materials from IP Holdings, its related entities or its affiliates, please complete the opt-out instructions included on the marketing, or contact us on:

Email: service@iplatforms.com.au 

Phone +61 433 661 308 

Mail: PO Box R1914
Royal Exchange, NSW, 1225

IP Holdings will note your request and respect your wish not to receive any marketing materials.

If you choose not to receive any marketing materials from IP Holdings, you may miss out on special product and service offerings and opportunities.

Cookies and third-party analytical services

We use cookies and track IP addresses via our websites so we can improve our services provided by our Websites and enhance your user experience.

When you access our Websites or use the IP Holdings Service, we (including our related entities and companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively ‘Cookies’). We use Cookies to ascertain which IP Holdings web pages are visited and how often, to make our websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in.

For example, Cookies allow us to save your password so you do not have to re-enter it every time you visit our site.

Most web browsers automatically accept Cookies. You can find information specific to your browser under the “help” menu. You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our Websites and IP Holdings Services.

Protecting personal information

IP Holdings will keep your personal information secure by taking reasonable steps to protect it from misuse, loss and unauthorised access, modification and disclosure.

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls. Only properly authorised people who have a need to access personal information to perform their job will be able to see or use that information. IP Holdings stores personal information in transmission logs and archive systems for a period IP Holdings considers reasonable depending on the primary purpose for which that information was collected.

Accessing and requesting correction of personal information

We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under privacy law, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your personal information we will tell you why.

If you wish to obtain access to and/or correct your personal information held by IP Holdings, please contact IP Holdings on:

Email: service@iplatforms.com.au[MA1]

Phone +61 433 661 308

Mail: PO Box R1914
Royal Exchange, NSW, 1225

Unless we do not agree to your request for access to personal information, in most cases IP Holdings will provide you with access as soon as reasonably possible of receipt of your request. If you request corrections to your personal information and IP Holdings agrees with your request, these changes will be made as soon as practicable. If IP Holdings does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you are dissatisfied with our refusal to provide you with access to, or correct, your personal information you may also complain to the Office of the Australian Information Commissioner ('OAIC') at www.oaic.gov.au.

Resolving your concerns

If you have a complaint regarding IP Holdings’ management of your personal information, please prepare your complaint in writing and email it to us at service@ipartners.com.au 

IP Holdings will provide written acknowledgement of your complaint within 7 days of receipt. We will investigate and advise you of the steps we have taken to resolve your complaint within 30 days of receipt of your complaint. You may also make a compliant directly to the OIAC at www. oaic.gov.au.

Badged Platforms

As noted earlier in this Privacy Policy, we may hold your personal information because we have partnered with a third party to jointly create and offer a product. Where your personal information is associated with your activities on a Badged Platform, we will share your information with the third-party client whose branding appears on the Badged Platform and third parties with whom either of us partner to create or offer products on the Badged Platform.

That is the case here and AAM Investment Group has asked us to provide you with access to their privacy policy below so that you can see how AAM (as opposed to IP Holdings) will handle that information.

Privacy Policy

Our approach to privacy

AAM recognises the importance of the privacy of individuals who have dealings with AAM. We are bound by the Privacy Act 1988 (Privacy Act), the Australian Privacy Principles contained in the Privacy Act, and other applicable laws, such as the Spam Act 2007 (Cth).

What does "personal information" mean?

Personal information is defined in the Privacy Act to mean 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 recorded in material form or not.

What information do we collect and why do we collect it?

Personal information that AAM may hold includes the following:

Name, address and contact details
Date of birth
Employment, income, bank account and financial details
Details of the products and services provided to an individual by AAM.

AAM will collect personal information about you to process an application, administer an investment, provide services related to an investment (including research and administrative tasks related to the management of your investment) and comply with statutory laws and regulations.

We may also use the information about you to:

identify other products which may be of interest to you and provide you with information about those products;
maintain an ongoing relationship with you • conduct market research, or • conduct surveys on investor satisfaction.

You can ask not to receive marketing materials from us.

The Privacy Act protects your sensitive information — such as information about your religion, ethnicity, health, or biometrics. We will not collect your sensitive information.

How we collect personal information?

AAM collects personal information directly from an individual where reasonable and practical. Typically, this will be collected through our Information Memorandum or other application forms, emails, meetings, or telephone calls with you.

AAM may also collect personal information from other sources including:

other entities who provide services to AAM related to the products and services provided to an individual by AAM
publicly available sources of information
an individual's representative (including spouse, accountant, financial advisor, or

other professional advisor).

We will tell you within a reasonable time if we have collected information about you from a third party.

If you access our website, we may collect additional personal information about you in the form of your IP address and domain name. Our website uses cookies. The main purpose of cookies is to identify users and to prepare customized web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve your more effectively.

Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you with the services or assistance you are seeking.

Do we disclose your personal information to anyone?

We may disclose your personal information to our related entities and to third parties who assist us with our business (for instance your financial planner, the custodian, the registry, auditors, regulatory bodies and external contractors who provide data backup and restoration).

The law also permits us to use or disclose personal information for other purposes in certain circumstances.

How do we keep your information and ensure it is accurate?

We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorized access, modification, or disclosure, including appropriate electronic and physical security measures. Access to and the use of personal information is appropriately limited to prevent misuse or unlawful disclosure of the information.

Your personal information will be stored in Australia and is not likely to be disclosed overseas. In the unlikely event of overseas disclosure, we will take reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles in relation to your personal information.

How do we protect your information and ensure it is accurate?

We take reasonable steps to ensure that the personal information we retain is accurate, complete, up- to-date and not misleading. To assist us with this, please notify us if any of your details have changed.

Can you access and correct the personal information we hold about you?

You can ask us to provide you with access to the personal information that we hold about you by contacting us as set out below. We will respond to your request within a reasonable time. If we do not agree to give you access, we will provide you with reasons in writing and notify you of your mechanisms to make a complaint. We may charge you a reasonable fee to access your personal information (but there will be no fee to make a request).

You can ask us to correct the personal information we will comply unless we are permitted by law not to. If we do not agree with your request, we will provide written reasons, including details about the mechanisms you must take to make a complaint. You can also ask us to include a note on your file that you have requested a correction and can ask us to inform third parties to whom we have disclosed your personal information that it needs to be updated.

Who should you contact if you have any questions regarding our Privacy Statement?

If you believe that we have not protected your personal information as set out in this Privacy Policy or in relation to a breach of the APPs or a registered privacy code that binds us, you may lodge a complaint with us by phone or email. You may use the Complaint Form available on our website or upon request (although please note use of the Complaint Form is not compulsory). We will deal with your complaint within a reasonable time and will provide a formal response to your complaint.

Telephone: Email: Write to:

61 7 3153 8830 compliance@aamig.com.au The Privacy
Officer AAMIG
GPO Box 352
BRISBANE Q 4001

What if you are not satisfied with our response?

If you are not satisfied with the result of your complaint to AAM, you can refer your complaint to the Office of the Australian Information Commissioner (OAIC). Their details are available at www.oaic.gov.au.