Background

At Philo Capital Advisers Pty Ltd (PCA) we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Policy describes our current policies and procedures in relation to the collection, handling, use and disclosure of personal information. It also explains how you can complain about a breach of the privacy laws, and how you can access and correct personal information PCA holds about you.

Where PCA is providing services to you, we will hold personal information about you, either because you have become a client of PCA or because you have given PCA information through our website or via email. PCA respects your rights to privacy concerning your personal information, and takes all steps to ensure it is managed in line with legal requirements.

Why Is Personal Information Collected?

PCA uses personal information you provide only for purposes consistent with the reason you provided it, or for a related purpose — for example, to provide MDA Services where you have entered into a Managed Discretionary Account Contract with PCA; to contact you regarding PCA services (you can opt out of these communications at any time); to comply with legal obligations such as identifying you as a client; and to administer your account. If you do not provide us with the information we ask for, we may not be able to provide you with some or all of our services.

How We Collect

Most information is collected when you become a client of one of the financial services PCA makes available, often a managed discretionary account. PCA may also collect personal information through contact with you, via our website, and through your adviser. PCA will collect personal information from you only by lawful and fair means, and not in an unreasonably intrusive way. By asking us to assist with the provision of our services, you consent to the collection and use of the information you provide for the purposes described in this policy.

What Information Does PCA Collect and How Do We Use It?

The kinds of personal information we may collect include your name, gender and date of birth; contact details including mail and email addresses and phone numbers; bank account details; superannuation account details; investment platform account details; tax file number; the name and location of your adviser; the investment program your adviser has recommended to you; transaction and valuation information related to your managed account portfolio; access and use details for this website; and other information you or your adviser might provide to us.

When we provide managed account services, we ask for the information needed to identify you on the relevant platform and to ensure we can uniquely identify you where more than one client shares the same name. We also need to know who your adviser is so we can communicate with them as required. We may provide some of this information to your platform provider to match accounts and ensure accurate and timely transaction and valuation information, which we use to manage your portfolio and support quality control. We also use your information to manage our ongoing relationship with you, and internally to help us improve our services and resolve any problems.

Disclosure of Personal Information

We will not disclose personal information we hold about you unless this policy allows it or you have given express or implied consent; it is to joint account holders or companies within our group; it is to those who help our business to run; it is in the public interest; we consider that the law requires disclosure or a regulator requests it (for example the Australian Taxation Office, Centrelink, the Child Support Agency, courts, ASIC or AUSTRAC); we consider someone relevant to you needs the information, such as your financial adviser; or it is needed to administer your account.

Security and Website Use

PCA is committed to keeping your personal information secure, with physical access and technology policies and procedures designed to provide a robust security environment. No personal data is stored on our website. Where we secure your personal information in transit and on receipt, we use industry standard SSL 128 bit encryption; however the internet is not a secure environment and we cannot guarantee the security of information exchanged electronically.

Our internet server logs information provided by your browser, such as browser and operating system type, your Internet Service Provider and domain, the address of any referring website, and your computer's IP address. We may use cookies to gather statistics on website activity to help us improve the site; you can configure your browser to accept or reject cookies, though rejecting all cookies may limit your ability to use some or all of our website. We may also monitor or record telephone calls for training, record or security purposes, and will tell you at the time if we do so.

Access to Your Personal Information

In most circumstances you have the right to access the personal information we hold about you. The law permits us to refuse access in certain circumstances, such as where access would pose a serious threat to health or safety, have an unreasonable impact on the privacy of others, relate to a commercially sensitive process, or otherwise be unlawful. Please contact our Privacy Officer using the details below if you wish to access, update or correct your personal information. If our records are wrong or out of date, please let us know and we will correct them free of charge.

Complaints

If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy, you can contact our Privacy Officer at any time using the details below. We will consider your complaint through our internal complaints resolution process and aim to respond with a decision within 30 days. If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner, including via their Privacy Hotline on 1300 363 992, at www.privacy.gov.au, or by writing to GPO Box 5218, Sydney NSW 1042.

Changes to This Policy

We may make changes to our information handling and privacy policies and practices, and to this Privacy Policy. We will publish important changes on our website and update this policy as necessary.

Privacy Officer

Attention: the Privacy Officer, Philo Group, Level 14, 60 Margaret Street, Sydney NSW 2000. Tel: 02 8006 4604, or send a message via our Contact Us page.