Modoras Wealth Management Privacy Statement
Respecting your privacy and the law
The privacy of your personal information has always been important to us at the Modoras Group (the ‘Group’). We are committed to respecting your right to privacy and protecting your personal information. We adhere to the Australian Privacy Principles and any applicable laws and codes affecting your personal information. Our staff are trained to respect your privacy in accordance with the law and our standards, policies and procedures.
Where the Group collects your personal information it will use or disclose that information in order to provide you with the services you have sought from the Group. It may also need to share the information with third parties, such as other financial product providers who will issue you with the financial products and services you acquire through the Group. It is also the Group’s policy to use the information within the Group’s companies to identify and make available to you other broadly related financial services. This enables the Group to have an integrated view of you, our clients.
You have the right to request us in writing that your personal information not be provided to other parties, however, that may mean that it is not possible to provide you with the products and services that you have requested. Where this is the case we will inform you in writing.
Members of the Group and a brief description of the services they provide, include:
- Modoras Pty Ltd ABN 86 068 034 908, Australian Financial Service Licence and Australian Credit Licence Number 233209 (Licensee)
- Modoras Accounting (UMG) Pty Ltd ABN 81 601 145 215 (accounting services)
- Modoras Accounting (Gold Coast) Pty Ltd ABN 62 601 145 199 (accounting services)
- Modoras Wealth Management (VIC) Pty Ltd ACN 145 368 869 (financial advising services)
- Modoras Accounting (VIC) Pty Ltd ACN 145 368 850 (accounting services)
- FinancialLine UMG Pty Ltd ABN 24 741 319 784 (financial advising services)
- FinancialLine Finance Pty Ltd ABN 11 644 724 780, Australian Credit Licence Number 392126 (credit services)
- FinancialLine Pty Ltd ABN 28 104 193 857 (technology services)
- Actocue Pty Ltd ABN 32 128 604 419, Australian Financial Service Licence Number 323729
- Enevita Pty Ltd ABN 40 128 973 464, Australian Financial Service Licence Number 321254 (Licensee)
- RJS Wealth Management Pty Ltd ABN 24 156 207 126 (financial advising services)
- RJS Sanderson & Associates Pty Ltd ABN 71 060 299 783 (accounting services)
- RJS Loan Solutions Pty Ltd ACN 123 033 116 (loan services)
- CPA Wealth Management Pty Ltd ABN 80 158 443 479 (financial advising services)
Collecting your personal information
The Group collects and holds your personal information for the purposes of:
- Providing you with the relevant product or service (including assessing your application and identifying you);
- Managing and administering the product or service we provide to you; and
- Protecting against fraud where it is a banking, finance, or insurance product or service.
Group companies may also collect your personal information for the purpose of letting you know about products or services from across the Group that might better serve your financial, e-commerce and lifestyle needs, promotions, or other opportunities in which you may be interested in.
We collect your personal information when you fill out a product or service application, an administrative form, or when you give us personal information over the telephone, or through a Group organisation’s website.
We may collect your personal information from third parties. For example, we may need (with your consent) to collect personal information from your employer, your representative (such as a legal adviser or accountant) or publicly available sources of information.
The type of personal information we collect and hold
Personal information or an opinion about an individual whose identity is apparent or can be ascertained from the information or opinion. Personal information relates to a natural living person and can include sensitive information. The types of personal information we ask for, collect and maintain will depend on which company within the Modoras Group of Companies you do business with and the type of product or service you choose.
We will generally ask you the following types of personal information:
- Name, address and contact details such as email address, phone numbers;
- Date of Birth;
- Gender; and
- Information about the products or services you require or use.
Depending on the type of product or service you require or choose, we may also ask you for other personal information about:
- Employment information;
- Marital status and family information or circumstances;
- Financial information such as your superannuation and other investment details;
- Business interests and trust structures;
- Your insurance, credit, financial and bankruptcy history;
- Tax file number;
- Past times, hobbies, family history;
- Details regarding any circumstances or assets you wish to insure; and
- Other personal information details which are needed depending on the type of financial product or service you require.
Your sensitive information
We will only collect sensitive information about you with your consent that reveals your:
- Racial or ethnic origin;
- Political opinions;
- Religious or philosophical beliefs or affiliations;
- Membership of a professional or trade association, membership of a trade union; and
- Details of health, disability, sexual orientation, or criminal record.
This type of sensitive information is only collected where required to provide you with the products, services or assistance you may require and the collection of this information is needed to provide these.
How will we collect your personal information
We collect your personal information:
- In person to person contact such as review meetings;
- By using written and electronic forms such as application forms and confidential financial and personal profile forms;
- Through contact over the phone, via the internet, including websites and social media; and
- From other companies and entities within our group of companies as listed above.
We will collect your personal information during the service cycle for the product or service we provide you, on an ad hoc basis or on a re-occurring basis where any or all of the above methods may be used to collect your information. For example, we will need to collect your personal information or reaffirm that the information we hold on you is up to date and correct when you acquire a new product or service from us or when we update or make a change to a product or service you hold, or when you need to make a claim or exercise a right under a product or service.
In addition to collecting your personal information directly from you, we can also collect it from publicly available sources of information and / or from other related persons or organisation including related and third parties.
Security of your information
We hold your personal information in:
- Our computer systems and electronic databases;
- Digital records; and
- In hard copy or paper files.
The Group takes all reasonable steps to protect your information from any misuse, interference, loss, or unauthorised access, modification or disclosure. We do this through:
- Stand by systems and system back ups to deal with any business interruptions;
- Limiting physical access to our offices and premises;
- Limiting physical and electronic access to your personal information and our systems;
- Requiring all third party providers to have acceptable security measures and privacy practices / policy in place which meet ours and the Australian Privacy Act requirements;
- Maintaining technical security product to protect your personal data; and
- Destroying or de identifying personal data and information pursuant to the law once such data is no longer required to be maintained by us.
In addition, Modoras maintains industry standards in relation to its technology and procedures with respects to management of information and its online services. Also, Modoras and its group of companies trains its employees and advisers in the group’s privacy obligations, applies privacy and confidential obligations under its employment agreements and provides authorised persons with user identifiers, passwords and other codes to control access to yours and the Group data and information.
Using and disclosing your personal information
Modern business practices often involve a firm outsourcing some of its function. In order for the Group to meet your specific needs it may need to disclose your personal information to the type of firms and organisations described below. Where your personal information is disclosed we will seek to ensure that the information is held, used or disclosed consistently with the Australian Privacy Principles and any State Legislation and other applicable privacy laws and codes.
The relevant organisations are those:
- Involved in providing, managing or administering your product or service such as third party suppliers, other Group organisations, external joint venture partners that conduct business with, printers, posting services, call centres, lenders, mortgage insurers and our advisers;
- Which are Group organisations who wish to tell you about their products or services that might better serve your financial, e-commerce and lifestyle needs, promotions, or other opportunities and their related service providers, except where you tell us not to;
- Who are external advisers and their service providers;
- Involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems;
- Involved in a transfer of all or part of the assets or business of a Group organisation;
- Involved in the payments system including financial institutions, merchants and payment organisations;
- Involved in product planning and development;
- Which are your representatives including your legal advisers and accountants;
- As required or authorised by law, for example, to government or regulatory bodies for purposes related to public health or safety, the prevention or detection of unlawful activities, or to protect public revenue;
- Financial Ombudsman Service, Superannuation Complaints Tribunal, Credit Ombudsman Service or any other dispute resolution or professional service body; and
- Where you have given your consent.
In addition, organisations offering
- Banking and finance products or services – other organisations to which personal information is usually disclosed are card producers, card schemes, credit and fraud reporting agencies, debt collection agencies, mortgage insurance companies, your guarantors, organisations involved in valuing, surveying, or registering a security property or which otherwise have an interest in such property, purchasers of debt portfolios, underwriters, re-insurers and other organisations involved in our normal business practices (such as securitisation).
- Financial planning or broking services or personal investment products – other organisations to which personal information is usually disclosed are superannuation and managed fund organisations and their advisers, organisations in which you invest and other organisations involved in our normal business practices (such as securitisation).
- Trustee or custodial services – other organisations to which personal information is usually disclosed are superannuation and managed fund organisations and their advisers and other organisations involved in our normal business practices.
- Life insurance products or general insurance products – other organisations to which personal information is usually disclosed are medical professionals, medical facilities, health authorities, assessors, underwriters, re-insurers, fraud detection agencies and other organisations involved in our normal business practices.
Your personal information may also be used in connection with such purposes.
Other use and disclosure
If your personal information is subject to Australian Privacy Principles, we only will use and disclose your personal information for a secondary purpose if it is related to the primary purpose for which we collected it and where you would reasonably expect us to use or disclose your information for that secondary purpose. In the case of sensitive information, we will only use this information for the secondary purposes if it is directly related to the purpose of collection or where we are required or authorised by law to disclose your personal information and sensitive information. For example, to a Court in response to a subpoena or to the Australian Taxation Office, Centrelink or to the Australian Transaction Reports and Analysis Centre (AUSTRAC).
Use and disclosure of personal information for marketing
The Group is able to assist you in providing a large range of financial services, products and advice. An important part of our service to you is marketing, by being able to keep you up to date with new products and services which we think may be of benefit and interest to you.
In bringing this information to you, we use a large range of communication tools including mail, telephone, email and other internet based tools as well as direct and group presentations. Third party marketing service providers may combine the personal information we disclosed to them with information they already hold about you, to provide you with more relevant advertising about the products and services we can provide you.
Keeping your personal information accurate and up-to-date
We aim to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. We will take reasonable steps to make sure this is the case. This way we can provide you with better service. If you believe your personal information is not accurate, complete or up to date, please contact us.
Protecting your personal information
We store information in different ways including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, loss unauthorised access, modification or disclosure.
Your privacy on the Internet
We take care to ensure that the personal information you give us on our websites is protected.
For example, our websites have electronic security systems in place, including the use of firewalls and data encryption. Depending on the Group Company with which you deal, user identifiers, passwords or other access codes may also be used to control access to your personal information.
Please refer to the website of those Group companies with which you transact electronically for more information on our website specific privacy and security procedures.
Links to other sites
You may be able to access external websites by clicking on links we have provided. Those 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 standards, policies and procedures.
Overseas Service Providers and disclosure
Companies within our Group will, when necessary, disclose personal information to organisations and persons overseas. Instances when we will do this include:
- When we are authorised or required by an Australian law or a court/tribunal to do so;
- When we have engaged an overseas service provider to deliver services central to our financial service business operations.
Your personal information will only be disclosed to the extent it is necessary to perform our functions or activities.
These external service providers to whom your data may be provided are for our Group’s client service management system and the service providers for this are located in Indonesia. This external overseas service provider provides computer system, computer code support and service to the group. Also, our internal document management system is supported by a service provider located both within Australia and overseas in the Philippines.
When you visit our website details may be recorded about your visit, such as time and date, your server address, pages accessed, time spent and type of browser. This information is used in an anonymous form for statistical purposes and as such cannot identify you individually.
Gaining access to your personal information
You can gain access to the underlying personal information and data the Group holds in relation to you. This is subject to some exceptions allowed by law. Factors affecting a right to access include:
- Access would pose a serious threat to the life or health of any individual;
- Access would have an unreasonable impact on the privacy of others;
- A frivolous or vexatious request;
- The information relates to a commercially sensitive decision making process;
- Access would be unlawful;
- Access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you;
- Legal dispute resolution proceedings; and
- Where a third party has given us health information about you in confidence and denying access is required or authorised by or under law.
We will give you reasons if we deny access. Please contact us to get a form requesting access. In some cases, we may be able to deal with your request over the telephone or via email.
Our response to your request could take up to 30 days from the receipt of your request. If we require further time we will write to you and advise you of the reason for the further time required. If such request incurs a fee, we will advise you of this.
Correction of personal information
You also have the right to request that we correct any inaccurate, out of date, incomplete, irrelevant or misleading personal information we may hold. We will take such steps that are reasonable to make any correction required. If we refuse to change or correct your personal information we will provide reasons for the refusal in writing to you. If we refuse to correct or change any personal information, you have a right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take any steps that are reasonable to associate that statement with all the records containing that relevant information.
Using Government identifiers
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.
Dealing with us anonymously or through the use of pseudonyms
You have the option of not identifying yourself and dealing with us anonymously or through the use of a pseudonym, where it is lawful and practicable to do so. For example, if you inquire about our home loan interest rates there is no need to provide your personal details.
Resolving your privacy issues
If you have any issues or a complaint that you wish to raise with the Group about the way in which we collect, use, hold or disclose your personal information or about a privacy related issue please use our complaint process so that we can help.
You are always welcome to speak directly to our staff and they will do their best to resolve your issue. Alternatively, you can email your issue to firstname.lastname@example.org, write to us directly or contact us by phone. If investigation is required we will keep you advised of progress.
If our staff are unable to resolve the matter it will be escalated to an appropriate Senior Manager of the Group.
If we are unable to resolve your issue or complaint immediately a response will usually be provided to you within 5 business days. At Modoras we aim to resolve all client complaints the same day where possible. Where this cannot be accomplished we will endeavour to resolve the client complaint within 45 days. However, this may not always be practicable.
If Modoras is unable to resolve the compliant we will advise you in writing.
If you are not satisfied with the outcome you may be able to access the services of an external dispute resolution scheme, we have provided contact details of these below:
- Office of the Australian Information Commissioner (OAIC)
Complaints must be in writing.
Phone 1300 363 992
Director of Compliance
Office of the Australian Information CommissionerGPO Box 5218
Sydney NSW 2001
- Credit and Investment Ombudsman Service
The Credit and Investment Ombudsman Service is an external dispute services available to individuals whose complaints comes under their terms of references. A Credit and Investment Ombudsman officer will be able to advise if they can be of assistance.Phone 1800 138 422
Credit and Investment Ombudsman Service
PO Box A252, Sydney South NSW 1235
Facsimile (02) 9273 8445
If you seek any further information from the Modoras Group about this policy, please contact our Privacy Officer reference point below:
Registered Address: Level 3, 50 – 56 Sanders Street, Upper Mt Gravatt QLD 4122
Postal Address: PO Box 6530, Upper Mt Gravatt QLD 4122
Telephone: (07) 3219 2555
Facsimile: (07) 3219 4432