Last updated October 2018
- Personal information we collect
Generally, we only collect personal information that is reasonably necessary for, or directly related to, one of more of the functions and activities of our business. For example, we may request that you provide your personal information when you invest in our financial products, instruct us to provide services, acquire products or interact with us, e.g., via our website. There may be other occasions when we collect personal information about you or from other sources, such as from our related entities, publicly maintained records or from information services providers. We may also share personal information about you with our related entities.
The types of personal information we collect may include:
- Names, occupation, contact and address details.
- Information in identification documents (e.g., passport or driver’s licence number).
- Information about shareholders, beneficiaries and beneficial owners.
- Tax file number (TFN), Australian Company Number (ACN) and Australian Business Number (ABN).
- Date and place of birth.
- Profession, occupation or job title.
- Bank account details.
We do not collect or hold sensitive information, such as racial or ethnic origins, religious affiliation or political opinions.
- Collection and use of personal information
3.1 How we collect personal information
Generally we will collect your personal information directly from you, e.g., when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a form (such as an application form to invest in a financial product), questionnaire or survey or when you use our websites or our social media.
Sometimes it may be necessary for us to collect your personal information from a third party. For example, we may collect your personal information from a publicly available record, an information service provider or from your personal representative or agent. We may also collect personal information about you from your use of our websites and information you provide to us through the registration process on our websites.
3.2 Providing personal information about someone else
3.3 Holding personal information
In the event you cease to be a client of DAP, personal information we hold about you will be maintained for at least as long as we are required to comply with legislative document retention requirements. After that time, we may destroy your personal information or put it beyond use, e.g., de-identify the personal information so it cannot be used to identify you.
3.4 Purpose for collecting, holding, using and disclosing personal information
DAP collects, holds and uses personal information for a number of purposes including:
- To provide services.
- To respond to requests or queries.
- To provide you with information about our products or services.
- To operate our business and any company, managed investment scheme, trust or syndicate, including entering details on a register of members and performing compliance reviews or audits.
- To maintain contact and keep you informed of our services, updates, industry developments and events.
- To verify your identity, including under anti-money laundering laws.
- For administrative purposes, including processing applications, distributions and payment transactions.
- For recruitment purposes and matters relating to the employment of our personnel, providing internal services or benefits to our staff.
- When engaging service providers, contractors or suppliers relating to the operation of our business.
- To manage any conflict of interest.
- For seeking your feedback or to conduct surveys.
- To meet any legal or regulatory obligations, e.g., providing the Australian Taxation Office with tax file numbers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including DAP’s business) or entering into an alliance, joint venture or referral arrangement.
- To perform internal statistical analysis, including of our databases and websites.
- For any other business related purposes.
If you do not provide us with the personal information we have requested, we may not be able to complete or fulfil the purpose for which such information was collected, including providing you with the services or products we were engaged to perform or provide.
The types of third parties to whom we may disclose your personal information include:
- Your financial advisers or other professional advisers.
- Any third party service provider which we may engage to provide due diligence, compliance, custody, administration, technology, auditing, mailing, printing or other service.
- Information service providers we engage to verify the identify of our clients.
- Government authorities such as the Australian Taxation Office or the Australian Securities and Investments Commission where required to by law or where reasonably requested.
- Our professional advisers, including experts, legal and accounting firms, auditors, consultants and other advisers.
- As part of an actual (or proposed) acquisition, disposition, merger or de-merger of a business (including DAP’s business) or to enter into an alliance, joint venture or referral arrangement.
- Our related bodies corporate or any other company within the DAP group.
We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you.
- Information storage and security
We take security measures to ensure that the personal information we hold is protected from misuse, loss and unauthorised access, modification or disclosure, including physical security measures (e.g., security passes or keys to enter our offices and storage of files in lockable cabinets) and technology security measures (e.g., restriction of access, firewalls and passwords).
We store personal information in our computer databases. We do not utilise third party storage providers (such as internet or ‘cloud’ based storage) and do not store data or personal information outside of Australia.
- Privacy on our websites
5.1 Automatic collection of personal information
Cookies and other technologies may be used by us on our website and through email to automatically collect certain types of information. The collection of this information can be used to by us to customise your online experience, market products and services to you, improve the performance, usability and effectiveness of our online presence and to measure the effectiveness of our marketing activities.
5.2 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It is not linked to personally identifiable information. We may use IP addresses to analyse trends, administer the website, track user’s movement, and gather broad demographic information.
A ‘cookie’ is a small text file that is placed on your computer or internet-enabled device whenever you visit our websites. This allows the website to remember your computer or device and serves a number of purposes.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our websites and geographic origin of visitor trends, and not to identify individual visitors.
5.4 Location-based tools
We may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
5.5 Social media features
Our website may host blogs, forums, crowd-sourcing and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any DAP social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
5.6 Links to third party websites
5.7 Your choices
You have several choices regarding your use of DAP’s websites. In general, you are not required to provide personal information when you visit our websites. However, if you apply to receive information about our services, events and updates, wish to acquire products or services or apply for a job, provision of certain personal information will generally be required.
We understand the importance of protecting children’s privacy, especially in an online environment. In particular, our website is not intentionally designed for or directed at children under the age of 18. It is our policy to never knowingly collect or maintain information about anyone under the age of 18, except as part of a specific engagement to provide services or products that necessitates such personal information being collected.
- Accessing your personal information
You can request access to your personal information, subject to some limited exceptions permitted or required by law. Such requests must be made in writing to our Privacy Officer. If we decline your request for access, we will provide a written explanation to you for the refusal.
Upon confirmation of your identity, we may provide you with access to information by either providing you with copies of the information requested or allowing you to inspect the information. We may charge reasonable costs for providing you access to your personal information.
We will not provide you with 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.
- Correcting your personal information
If you believe that any personal information DAP has collected about you is inaccurate, not up-to-date, incomplete, irrelevant or misleading, you may request correction. To do so, please contact our Privacy Officer and we will take reasonable steps to correct it in accordance with the requirements of the Privacy Act.
If you wish to make a complaint about our handling of your personal information, you can contact our Privacy Officer. You may be asked to set out the details of your complaint in writing.
We will endeavour to reply to you within 30 days of receipt of the complaint and, where appropriate, will advise you of the general reasons for the outcome of the complaint. In some circumstances, our Privacy Officer may decline to investigate the complaint, e.g., if the complaint relates to an act or practice that is not an interference of the privacy of the person making the complaint. If you are not satisfied with the outcome of your complaint, you can refer your complaint to the Office of the Australian Information Commissioner (telephone 1300 363 992).
- More information on privacy
We are required to comply with the Privacy Act, which contains the Australian Privacy Principles. A summary of the Australia Privacy Principles, a copy of the Privacy Act and additional information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.
- Our contact details
David Allen Properties
Attention: Privacy Officer
Manly Boardroom, Level 1
28 South Steyne, Manly NSW 2095
PO Box 329
Manly NSW 1655