PRIVACY POLICY

Pathway to Wealth Pty Ltd is bound by, and committed to supporting, the National Privacy Principles (NPP) set out in the Privacy Amendment (Private Sector) Act 2001. The following should give you a greater understanding on how we collect and use client information.

Why we collect information
We collect information for a number of reasons including:

• To deliver financial planning products and or services to you
• To provide business coaching services to you
• To complete other transactions with you or on your behalf
• To better understand your requirements and preferences
• Improve our service
• To update our records
• Provide offers that are of greater interest or benefit to you

At or before the time we collect personal information from you we will take reasonable steps to let you know why we are collecting that personal information, who else we might disclose that personal information to and what may happen if you do not provide personal information to us.

What we collect
We are subject to certain legislative and regulatory requirements that necessitate us obtaining and holding detailed information that personally identifies you and/or contains information or an opinion about you. In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:

• employment details and employment history
• details of your financial needs and objectives
• details of your investment preferences and aversion or tolerance to risk
• details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, etc
• information about your employment history, employment circumstances, family structure, commitments and social security eligibility
• any other relevant information including medical history and/or reports required for the purposes of risk insurance
• any other relevant information for the purpose of providing financial planning advice.

Data quality

Pursuant to the Corporations Act and Rules of Professional Conduct of the Financial Planning Association of Australia, we are required to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. If you elect not to provide us with the personal information you may be exposed to higher risks in respect of the recommendations made to you and this may affect the adequacy or appropriateness of advice given to you.

Data Security

We take reasonable steps to protect the information we retain from misuse, loss and from unauthorised access, modification or disclosure. We will not retain any of your information for any longer than it is required by us, except to satisfy legal requirements. We will destroy or de-identify your personal information when it is no longer required.

Openness

We may use and disclose personal information for the purposes for which it was provided or secondary purposes in circumstances where you would reasonably expect such use or disclosure.

We may disclose personal information to third parties or external contractors carrying out functions and duties for and on behalf of Pathway to Wealth Pty Ltd. In these circumstances, Pathway to Wealth Pty Ltd will ensure that these third parties undertake to protect your privacy.

The information we collect from you may also be disclosed to third parties if the disclosure is required by or permitted by law, or pursuant to the Rules of Professional Conduct of the Financial Planning Association of Australia. In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.

Access and Correction

You may access the personal information we retain and request corrections. This right of access is subject to some exceptions allowed by law.

We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result.

We will endeavour to ensure that at all times the personal information about you that we hold is up to date and accurate. The accuracy of the personal information is dependant to a large degree on the information you provide and you should advise us if there are any errors in your personal information.

Identifiers

In some circumstances we are required to collect government identifiers, for example, your Tax File Number. We will not use or disclose this information other than when required to do so by law or, when consented to by you.

Anonymity

You may deal with us anonymously where it is lawful, practicable and reasonable to do so.

Sensitive Information

Without your consent, for example where information is provided by you for insurance and or risk purposes, we will not collect sensitive information about you. Exceptions to this include where the information is required by law, or for the establishment, exercise or defence of a legal claim.

Privacy Complaints

If you wish to complain about any breach or potential breach of this privacy policy or the National Privacy Principles, you should contact us by any of the methods contained in this policy statement. It is our intention to use our best endeavours to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

If you receive marketing offers from Pathway to Wealth Pty Ltd and do not wish to receive them in the future, please call our office on (07) 5455 3183 or email This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

A copy of the Pathway to Wealth Pty Ltd Privacy Policy is available from the Pathway to Wealth Pty Ltd website at www.pathwaytowealth.com.au or you can request a copy by calling our team on (07) 5455 3183.

Updates to this policy

From time to time and in line with customer expectations and legislative changes, our privacy policies and procedures will be reviewed and, if appropriate, updated