We respect your privacy
Fin Support Australia Pty Ltd ABN 12 646 659 761 (FSA, We, Us) is committed to providing quality services to you. This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au
1. What personal information do we collect?
Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include but not limited to names, addresses, email addresses, phone numbers.
This Personal Information is obtained in many ways including by correspondence, telephone, email, via our website, from your website, from media and publications, from other publicly available sources, from cookies and from third parties.
We collect Personal Information for the primary purpose of providing our services to you. We may also use the Personal Information for secondary purposes closely related to the primary purpose, in circumstances where such use or disclosure is reasonable and required. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information, we will endeavour to explain to you why we are collecting the information and how we plan to use it, where reasonable and practicable to do so.
2. How do we collect personal information?
We collect personal information from you in a variety of ways, including when you interact with us electronically or in person and when you access our website www.finsupportaus.com.au. We may receive personal information from cookies and third parties. We are committed to ensuring the information we have is accurate and up to date. We update personal information when we are advised there has been a change and at other times as necessary.
3.Disclosure of personal information
Personal Information relating to you and your clients may be disclosed in a number of circumstances including the following:
- Third parties where you consent to the use or disclosure; and
- Where required or authorised by law.
We may disclose the personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy. Personal information is only supplied to a third party when it is required for the delivery of our services.
We may also use the personal information to protect the copyright, trademarks, legal rights, property or safety of FSA, finsupport.com.au, its customers or third parties.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
We can disclose the personal information to third parties in certain circumstances including:
(a) if you or Your Client agree to the disclosure;
(b) to employees, contractors and service providers, who assist us in operating our business and providing our services and those service providers of yours that you require us to work with;
(c) If you or Your Client would reasonably be expected to consent to information of that kind being passed to a third party;
(d) using it for the purposes we collected for which it was (e.g. to provide our services correspond to a query);
(e) where disclosure is required or permitted by law;
(f) to our related entities;
(g) if disclosure will prevent or lessen a serious and imminent threat to someone’s life or health
a.How we use personal information?
If we do not collect the personal information, we will not be able to provide the services or assistance requested.
If the personal information provided to us is incomplete or inaccurate, we may be unable to provide our services, or our services may be adversely affected.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used only:
- For the primary purpose for which it was obtained,
- For a secondary purpose that is directly related to the primary purpose,
- With your consent, or where required or authorised by law.
Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
4.Considerations when you send information to us
a) While necessary steps have been taken to protect your privacy and the privacy of Your Clients, including investing in specialist security software, no data transfer over the Internet is 100% secure.
(b) The following steps are advised If you or Your Clients provide personal information to us electronically.
(i) do not provide personal information by using a public computer;
(ii) never disclosing your username and password to another person; and
(iii) using encryption when emailing client information and or using file sharing services approved by FSA.
(c) Changing your passwords regularly and utilising characters and numbers and utilising password storage systems when sharing passwords.
(d) If we suspect that there is a data breach leading to the protection of personal information stored or held by us being compromised, we will implement a data breach response plan by:
(i) notifying you of the breach;
(ii) if necessary, notifying the relevant regulatory authorities of a suspected breach.
(iii) undertaking appropriate remedial action, depending on the type, amount and nature of the personal information that is at risk. In the implementation and carrying out of the data breach response plan, we will refer to the OAIC’s Data breach notification: a guide to handling personal information security breaches publication.
5.How information is stored
(a) Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
(b) When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.
6.How you can update, correct, or delete your personal information
(a) You and Your Clients have a right to request access to personal information which we hold about you and Your Clients and to ask us to correct it if you believe it is inaccurate or out of date.
(b) You and Your Clients may request the source of any information we collect from a third party. We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld.
(c) You or Your Clients may request access to your personal information or correct any inaccurate or out of date information by contacting our Privacy Officer on firstname.lastname@example.org.
(d) If there is a reason under the Privacy Act or other law for us not to provide you or Your Clients with information, we will give you or Your Clients a written notice of refusal setting out:
(i) the reasons for the refusal except to the extent it would be unreasonable to do so; and
(ii) the mechanisms available to you to complain about the refusal.
(e) you or Your Clients should also contact us immediately if:
(i) someone has gained access to you or Your Client’s personal information.
(ii) we have breached our privacy obligations or your or Your Client’s privacy rights in any way; or
7. Your authority and opting out
(b) We do not use personal information of Your Clients for marketing purposes.
(c) If at any time you no longer wish to receive any additional marketing material from us or do not want your information disclosed for direct marketing purposes, email email@example.com and we will remove your details from our marketing database.
(d) If you close your account or opt out, we will remove or de-identify personal information as soon as reasonably possible. We may, however, retain personal information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes.
8. Limitation of liability
(a) To the extent permissible by law and subject to our obligations under the Privacy Act, we will not be liable to you or to any third party for any loss or damage (including but not limited to consequential loss or loss of profits) or claim arising from our collection, disclosure, management and use of personal information in accordance with this policy.
(b) Where liability is not able to be excluded by law, to the extent allowed by law and without limiting your rights under Australian Consumer Law, our liability to you in any circumstances will be limited to re-performance of any services we have provided to you.
(c) Links on our website or websites we set up for you may take you outside our network. These links are provided in good faith. However, we are not responsible for third party sites and accept no responsibility for the content, accuracy, security or function of third-party sites.
(b) This Policy may change from time to time and is available on our website.
(d) We endeavour to ensure that any complaints about privacy breaches will be dealt with in a reasonable time frame.
(f) More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from the OAIC by:
(i) website – www.oaic.gov.au;
(ii) mail – GPO Box 5218 Sydney NSW 2001; or
(iii) email – firstname.lastname@example.org.