At CreationWealth we know that with effective strategy and guidance, you can live a life with greater freedom. This principle guides our work and our approach to the collection and protection of your personal information. This Policy outlines how we collect, handle, store and use your personal information as well as how you can access your own information or report a complaint. Our Policy is in accordance with the Privacy Act 1988 (Cth) and we are committed to providing you with a quality service and handling your private information fairly and lawfully.
About us
Finans Pty Ltd (ACN 636 425 066 | ABN 41 636 425 066) trades as CreationWealth
CreationWealth is a Corporate Authorised Representative of Advocate Advisory Pty Ltd (ABN: 14 150 153 503) | Australian Financial Services Licence 405576
What personal information do we collect?
Due to the nature of the professional services we provide in-house, the types of information we may collect and share internally includes, but is not limited to:
- Information about your identity, such as names and contact/address details
- Financial and credit information
- Photographic information such as your identity documentation
- Tax file numbers and prior tax returns
- Visa, work permit or foreign investor status
- Details of investment, superannuation and insurance plans
- Salary and employment history
- Trust, company and any other business and family structure documents
Depending on your engagement with CreationWealth, different types of information would need to be collected. However, where possible we will only collect the personal information required to provide our services to our clients or as required by our professional obligations. We will not collect sensitive information unless it is for the primary purpose of the service we are providing and only with your direct consent, unless otherwise required by law.
Where reasonable and possible, we collect personal information directly from the individual to whom the personal information relates and with their consent. The information is collected through our client questionnaires, telephone conversations, email correspondence and face to face meetings with our staff.
Due to CreationWealth’s obligations as an AFS Licensee of Advocate Advisory, our document retention policy is to keep all records about current and past clients for at least 10 years, all SMSF records must be kept for a minimum of ten years and all marketing or other communications with non-clients are kept for 7 years. Our legal department retains physical files for 7 years before destroying them responsibly. However, certain information that is considered sensitive may be retained indeterminately such as a Will or Power of Attorney. As retention will depend on the service provided, we recommend directly asking our office how long your file will be retained if this is a concern.
You always have the option of not identifying yourself or of using a pseudonym. However, we do not recommend this as it will greatly limit our ability to tailor our services and your CreationWealth experience.
How do we use your information?
We endeavour to only use personal information for the primary purpose of rendering the services for which it was collected. The information will not be used or disclosed externally for any other purpose without your consent.
If within your course of business with us we aid in the application of credit and mortgage services, we may need to obtain a credit report. The Privacy Act limits the information we can give to credit bodies in the process of obtaining a credit report. Any credit information obtained will be treated as private personal information and will be subject to our stringent standards outlined in this policy. We recommend discussing with your mortgage broker what information will be shared and what this could mean for you.
We may also send you regular updates or newsletters by email or by post. We will always give you the option of electing not to receive these communications and offers and you can unsubscribe at any time by notifying us that you wish to do so. You can notify us by email or phone.
While we do not share, sell or otherwise disclose your personal information with third parties, please be aware we may be obliged to disclose information if required to do so by law.
How do we store your information?
Finans Pty Ltd trading as CreationWealth and Advocate Advisory Pty Ltd retains personal information in hard copy and electronic formats. We have stringent security measures in place relating to both the physical and technological information we retain.
For example, we have a safe custody vault for legal documents, our offices are restricted access areas with only employees able to enter and we have a sophisticated filing systems and locked cabinets. Further, we have installed a firewall system on our computers, our software systems are password protected and access to electronic files are restricted to employees directly involved in your matter.
How you can access your personal information?
You may ask us for a copy of your personal information by email or by visiting our offices. Similarly, you can request to update or correct your personal information at any time.
We generally will not charge you to access or update your personal information. We may only charge if large expenses are incurred in providing your information. In that circumstance, the fee will be a reasonable estimate such as an hourly rate and photocopying expenses. Our fees would be discussed and agreed upon before the work would commence.
We will only deny you access to your personal information if we reasonably foresee it adversely impacting on the privacy of another, compromising our professional obligations or it is considered commercially sensitive. We will inform you if this is the case and explain our decision.
How can you lodge a complaint about our Privacy Policy?
If you believe your privacy has been breaches or if you wish to make a complaint to Advocate Advisory regarding how we handle your personal information you can direct your concerns to our Privacy Protection Team by sending your complaint in writing to:
Privacy Officer
Advocate Advisory Pty Ltd
PO Box 6167
Wantirna LPO Vic 3152
We will take steps to address your concerns within 30 days of receipt of the complaint. We will work collaboratively with you to investigate and resolve the complaint. If you are not satisfied with the resolution of your complaint you may refer your concerns to the Office of the Australian Information Commissioner, they can be contacted through their website www.oaic.gov.au or by calling 1300 363 992.
How do we handle data breaches?
We have implemented a data breach response plan to assist us to contain and respond to suspected unauthorised access to and use of personal information.
Our data breach response plan sets out the process for our staff to identify a data breach, appoints a team to handle the breach and outlines the notification process of affected parties and the Australian Information Commissioner. It also outlines the post-breach review and assessment procedures.
International information sharing
Finans Pty Ltd trading as CreationWealth and Advocate Advisory Pty Ltd will not share your information with third parties internationally.
If you engage in the services provided by Finans Pty Ltd trading as CreationWealth, you accept and consent to your information potentially being shared with Financial product providers, government agencies, service providers (including offshore providers) engaged to provide financial planning related services including but not limited to paraplanning, compliance, administration and financial services software.
Information is only shared with your consent and we are satisfied that the processing team uphold a privacy standard that equals ours. Additionally, the email and software providers (such as Outlook) we use may engage in overseas data storage and again we only use trusted and well-respected providers which would maintain stringent privacy standards.
This Privacy Policy was prepared in April 2020 and Finans Pty Ltd and Advocate Advisory Pty Ltd reserves the right to update, modify or remove the Policy as we reasonably see fit. Any changes will be published on our website.