The most important thing is...
If you are not happy with anything that you let us know
Email firstname.lastname@example.org (our CEO) or email@example.com (our COO and Head of Advice)
If (and we will work hard so this doesn't happen) you are still not happy there is an official process whereby you can make an official complaint to us and we have to work with our licensee (The FinancialLink Group) to solve it.
If that doesn't work we will put you in touch with FOS (the Financial Ombudsman).
Also very important is:
The Financial Service Guide and...
1. In this disclaimer:
" Website" means the Fin15 web address and its contents which is owned by Fin15.
2. It is a condition of use of this website that users of the website agree to the following terms and conditions:
(a) While all reasonable attempts have been made to ensure the accuracy, currency and reliability of the content of this site, all information in this website is provided "as is" .
(b) There is no guarantee as to the completeness, accuracy, timeliness of the results obtained from the use of the information in this website. No warranty of any kind is given, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose.
(c) Fin15 does not accept any responsibility or liability for any loss, damage, cost or expenses you might incur as a result of the use of, or reliance upon the materials which appear on this website or any linked sites.
(d) You should be aware that the providers of linked sites will often have their own protocols and standards in relation to their sites and the information which appears on them. We urge you to familiarise yourself with such protocols and standards. Fin15 is not endorsing any provider of products or services by facilitating access to these sites from its web pages, nor does it accept responsibility for the quality of goods and services provided by third parties accessed through this website.
(e) To the maximum extent permitted by law, Fin15 disclaims any liability to you or anyone else for any decision made or action taken in reliance on the information in this website or for any consequential, special or similar damages, even if advised of the possibility of such damages.
(f) Information obtained from this website should not be used as a substitute for consultation with competent professional advisers. Before making any decision or taking any action, you should consult professional advisers with expertise in your area of interest.
(g) Fin15 can modify the terms and conditions contained in this website disclaimer at any time and you agree to continue to be bound by these. We will give you notice of changes by publishing revised terms and conditions on this website - we will not separately notify you of these changes.
We respect the importance of your privacy. This Policy outlines how Fin15 manages the personal information it holds about you, our customer.
It is Fin15’s policy to respect the confidentiality of information and the privacy of individuals. Fin15 is bound by the Australian Privacy Principles contained in the Commonwealth Privacy Act (1988) as amended via the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
Keeping records about individuals is necessary and important. The information Fin15 receives from its clients is personal and confidential. Without this information, however, it would be difficult to assess a customer’s needs. Both the general and common law impose confidentiality obligations on organisations such as Fin15 which in some respects are similar to those which exist with solicitor/client relationships. Fin15 supports these principles and has processes in place to respect them.
The legislation contains principles that include the following:
- Personal information must only be collected for a purpose which is lawful, and which directly relates to a function or activity of the collector;
- The collection of that personal information must be necessary for, or directly related to that purpose;
- The collector must tell the individual concerned of the purpose for which the information is being collected;
- If the collector intends to pass the information to another party, the person providing the information must be told this.
- Any information collected should be relevant, up-to-date where appropriate, and complete; and
- Once collected, the personal information must be protected by appropriate safeguards against loss, and also against unauthorised access, use, modification or disclosure to unauthorised or inappropriate persons, and other misuse.
Fin15 support and abides by the following thirteen Australian Privacy Principles (APP) outlined in the Act.
PART 1: CONSIDERATION OF PERSONAL INFORMATION PRIVACY
APP 1: Open and transparent management of personal information
Fin15 have practices, procedures and systems to comply with the APP including a complaint process to deal with any complaints by individuals about Fin15’s compliance with the APP.
APP 2: Anonymity and pseudonymity
You have the option of not identifying yourself or you may use a pseudonym where it is not required when entering transactions with Fin15 wherever it is lawful and practicable.
In most circumstances, however, it would not be practicable to not identify yourself when receiving financial advice or transacting other business with Fin15.
PART 2: COLLECTION OF PERSONAL INFORMATION
APP 3: Collecting of solicited personal information
Fin15 is committed to safeguarding your personal privacy. We recognise that you have a right to control how your personal information is collected and used. We know that providing personal information is an act of trust and we take that seriously. Unless you directly give us consent to do otherwise, Fin15 will only collect and use your personal information contained within the Confidential Client Data Questionnaire and file notes for the purpose of providing you with the financial services discussed and communicated directly with you.
As Fin15 offers a variety of products and services, a number of them may be of interest to you. Any personal information we collect may be used to gauge your suitability for only the products or services that have been discussed with you. We will acquire your explicit permission before we use any personal information to gauge your suitability for any of our other products and services.
Fin15 will not collect or monitor any personal information about you without your consent. The only personal information we collect is what you tell us about yourself.
APP 4: Dealing with unsolicited personal information
Where Fin15 receives information that has not been solicited in accordance with APP 3 above or could have been solicited in accordance with APP 3, Fin15 will ensure the information is destroyed or de-identified.
APP 5: Notification of the collection of personal information
Fin15 provides identification and contact details through its various disclosure documents. Fin15 will also explain to you the purpose for collecting the information, the consequences if information is not collected, other entities requiring the information, your accessibility to your personal information, the complaints process and whether your information will be disclosed to overseas recipients.
PART 3: DEALING WITH PERSONAL INFORMATION
APP 6: Use and disclosure of personal information
We intend to use your information for the following purposes only:
- To fulfil our obligation under any contract and/or any other contract between you and Fin15;
- To provide you with information about our products, services and/or special offers unless you explicitly request us not too;
- To ask you for your opinion or comments about our products and/or services. You may answer at your discretion; and
- To track general traffic patterns showing the usage of certain services that we offer, without identifying the usage patterns of any particular individual.
As Fin15 recognises the trust that you place in us when you give us your personal information, we will not use or disclose any information about you for other purposes without your consent, except for in exceptional cases as required by laws or where it is necessary to protect the rights or property of Fin15, or any member of the public, or to lessen a serious threat to a person’s health or safety.
APP 7: Direct Marketing
Fin15 will not use your personal information for direct marketing purposes without your Consent.
We may contact you by mail, telephone or at your email address, which you provide us in order to:
- Provide you with information which may be of interest about updates, new Fin15 products and other matters which may interest you; and
- To send you a newsletter.
You can opt-out of any direct marketing.
If you are receiving communications from Fin15 and do not wish to receive this information any longer, you may remove your name from our list by emailing us at firstname.lastname@example.org.
APP 8: Cross-border disclosure
Fin15 will only transfer personal information about you to someone who is in a foreign country if:
(a) We reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that is substantially similar to the National Privacy Principles; or
(b) You consent to the transfer; or
(c) The transfer is necessary for the conclusion or performance of a contract between you and the organisation, or for the implementation of pre-contractual measures taken in response to your request.
Your personal information will then only be transferred if we believe it to be for the benefit of you, or if it is impracticable to obtain the consent from you for that transfer and if so if we believe that you would be likely to give consent.
We will take reasonable steps at all times to ensure that the information, which has been transferred, will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.
APP 9: Adoption, use or disclosure of Government identifiers
Fin15 does not use as a client identifier any number, code or other form of identifier used by any agency or other external entity (eg: your tax file number if collected). Similarly, we will not disclose any identifier assigned to an individual by an agency unless it is necessary for us to fulfil our obligations to that agency.
PART 4: INTEGRITY OF PERSONAL INFORMATION
APP 10: Quality of personal information
Fin15 will take all reasonable steps to ensure that your personal information is used and or disclosed in an accurate, complete and up-to-date manner. Naturally, this information will only be as accurate as our clients provide it to us.
APP 11: Security of personal information
Fin15 will also endeavour to take all reasonable steps to keep secure any information that we hold about you and to protect it from misuse and loss and form unauthorised access, modification or disclosure. Our employees and data processors are obliged to respect the confidentiality of any personal information held by Fin15. We will take reasonable steps to destroy or permanently de-identify your personal information if it is no longer needed for any purpose for which the information was originally intended.
Fin15 provides links to certain industry related websites outside the Fin15 site. These linked sites are not under the control of Fin15, and we are not responsible for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the Terms and Conditions of those websites.
As we cannot guarantee the security of communications over the Internet, we are not able to give absolute assurance that, if your personal information is provided to Fin15 via this medium, it will be secure at all times. Fin15 will not be held responsible for events arising from unauthorised access to your personal information.
PART 5: ACCESS TO, AND CORRECTION OF, PERSONAL INFORMATION
APP 12: Access to personal information
If at any time you want to know what information we hold about you, you are welcome to request your personal information by contacting us.
Under extreme circumstances, we may not be able to provide you with access to your personal information. Where this is the case, we will write provide in writing, the reasons for this decision.
APP 13: Correction of personal information
If you want to change and correct personal information that is inaccurate or out of date, please let us know. To have personal information deleted, please let us know in the same manner, and we will take reasonable steps to delete your personal information unless we need to keep it for legal reasons.
What if you have a complaint?
To make a complaint, please forward it in an email to:
The Privacy Officer, Fin15
If you are not satisfied with our response to your complaint, you can phone the Commonwealth Privacy Commissioner’s hotline on 1300 363 992.