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Privacy & Data

Praemium's Privacy Statement

This Privacy Statement sets out the key points about how Praemium Limited, ABN 74 098 405 826 and its related entities (“Praemium, we, us, our”) may collect, use and manage personal information.

The Praemium Privacy Policy (Policy) is aligned with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). Further information can be found in our Privacy Policy.

Introduction

Praemium provides financial services, online portfolio administration and Customer Relationship Management (CRM) services to our customers, who are individuals and intermediaries such as financial advisers, accountants, stockbrokers and investment or superannuation administrators.

The Praemium services and products include:

VMA: a non-custodial investment service portfolio administration
SMA: a managed investment scheme
SuperSMA: Praemium acts as the sponsor of a superannuation fund
WealthCraft: a software application providing CRM and financial planning tools.

Praemium may collect, hold, use and disclose personal information in operating this website and in providing its products and services to you.

Collection of personal information

Personal Information

Personal information is information or an opinion about you from which you can be reasonably identified. Some of the personal information that Praemium may collect or hold about you from Advisers who use the services includes:

Name, residential address, email address and your other contact details
Dates of birth
Client ID
Gender
Source of funds, beneficiaries/control structures and politically exposed persons’ details
Details of investments and investment transactions
Bank account number
Other details or notes that an Adviser may record with respect to giving financial product advice or administering your investment portfolio
Other details an Adviser may collect to manage your financial affairs, such as risk profiling or financial goals
Tax File Number (TFN), an individual’s tax residency status, an ABN

If we do not collect this personal information, Praemium may not be able to provide you with some or all of our products and services or information regarding these products and services.

We may collect or hold information about you that is publicly available, for example, data on the ASIC database.

Sensitive Information

Praemium will not collect or disclose information that is classified as “sensitive information” for example, information about your health or criminal record under the Privacy Act unless:

Your prior consent has been received by us
It is necessary to collect the sensitive information for one or more of Praemium’s functions; or
It is required by or authorised under an Australian law or a court/tribunal order.

Government related identifiers (GRI)

Praemium may collect or hold GRIs to provide its products and services to customers and investors. These include:

Tax file numbers
Driver licence numbers; and
Australian passport numbers.

Praemium is permitted to use or disclose a GRI for an individual if we believe that it is reasonably necessary for one or more enforcement-related activities conducted by, or on behalf of, a Government body such as ASIC, AUSTRAC or the Australian Federal Police.

Information collected from this website

Praemium collects information through its websites to tailor and improve the website. This information is collected through the identification of cookies (a small string of information that a website transfers to your browser for identification purposes) that are stored on your device when you access and interact with our website.

The information collected is non-personal and includes:

The date and time of visits
Pages viewed
The type of operating system
The location of the server
The address of any referring web site; and
Whether information has been downloaded.

You may disable cookies through your internet browser should you wish to opt out. However, please note if you disable the cookies feature, you may not be able to access all the functionality of our website.

Why do we collect and hold this information?

Praemium collects or holds information in order to provide our services to you, or to enable your adviser to perform various functions and services on your behalf. We are also required by law to conduct customer due diligence checks under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) (“AML/CTF Act”). Praemium cannot provide services to you, or your adviser unless this information is collected.

Dealing with personal information

Using your personal information

Personal information is required to enable us to provide our products and services, including for these purposes:

To verify your identification
To assess or process your application for a product or service
To perform administrative and operational tasks
Providing you with products and services, and any updates to these
To consider any complaints you may raise
To manage risks, and prevent or investigate suspected or actual fraud misconduct or unlawful activity; and
To comply with laws such as the Corporations Act 2001 (Cth), AML/CTF Act, Australian taxation law and the Privacy Act.

We may disclose personal information we collect with other entities within the Praemium group and with third parties for the purposes of:

Meeting our Australian Financial Services (AFS) licence requirements
Collecting overdue payments
Providing information to any third-party service providers we engage
Providing marketing material; and
External complaint resolution schemes.

Sharing of personal information overseas

For data backup purposes, your data may be hosted and stored in facilities that may be located overseas.

We may disclose your information to related overseas entities for the purpose of providing internal support for our service and product offerings.

In addition, the disclosure is required or permitted by law. For example, the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) requires Praemium to collect and provide information about foreign investors who have investments in our SMA. This is lodged with the Australian Tax Office which may ultimately pass over to the US Government’s Internal Revenue Service or the relevant foreign tax authorities.

Keeping personal information secure

Personal information that is collected by Praemium may be stored electronically, or in hard copy form. It may be held directly by Praemium, or by a service provider which Praemium has engaged to provide services.

Praemium has implemented processes and systems to ensure personal information is protected from misuse, interference, loss or unauthorised access by ensuring:

All transmitted data is encrypted on secure networks.
Firewalls, intrusion detection systems and anti-malware/anti-virus tools.
Physical security measures are in place, including cameras and smartcards.
Staff training, policies and procedures (including clean desk).
We only keep information as long as we are legally bound to and use secure destruction processes.
We destroy or de-identify any unsolicited information.
Database access is controlled, and third-party agreements reflect privacy obligations.
Internal access to client records and databases is restricted based on an employee’s roles and responsibilities.
Authorisation processes are in place for changes in access
Client records in hard copy format are secured and archived where appropriate.

Note however that Praemium cannot be responsible for user access that an Adviser may permit or manage.

In the event you believe your privacy has been compromised, please contact your Adviser first. However, if you believe your privacy has been compromised by an action undertaken by Praemium, you can contact our Client Services Team at any time by contacting [email protected] or on 1800 571 881.

Accessing your personal data

In most cases, individuals who have provided personal information to Praemium are entitled to access that information or request their information be updated at any time.

Praemium will respond to your request for access to the personal information within a reasonable period after the request is made. We reserve the right to charge a reasonable fee to cover our costs. There are a few exemptions, including cases where legal proceedings are taking place, or providing access may be unlawful, or if providing access would pose a threat to other people’s privacy.

Keeping your information up to date

Praemium relies on the accuracy of the personal information provided to us by you. We aim to ensure that it is accurate, up-to-date and complete. We have created appropriate system access for your Adviser to keep your personal information accurate and up to date. For non-SMA products, your Adviser may also grant you access to update your data. If any of your details change you can also contact our Client Services Team.

Data Breach Response

Should any unforeseeable event occur which results in the loss, or unauthorised access or disclosure of your personal information, Praemium has processes and mechanisms in place to contain any breach, determine any impact and comply with any applicable notification laws. In the event that it is likely to result in serious harm to you, we will investigate the matter and notify you and the Office of the Australian Information Commissioner pursuant to our obligations under the Privacy Act.

Retention of personal information

In most cases personal information will be retained for seven years after the cessation of Praemium’s dealings with a person. In cases where Praemium is no longer required to maintain records, personal or sensitive information held by Praemium will be de-identified or securely destroyed.

Making a privacy complaint

Should you wish to make a complaint please contact us on the details below:

Praemium Customer Service

Email: [email protected]
Tel: 1800 571 881

Praemium Complaints Handling Officer

Email: [email protected]
Address: PO Box 322 Collins Street West, Melbourne, 8007

For information on Praemium’s complaint handling procedure which is published on our website at www.praemium.com/guide-to-making-a-complaint.

If you feel that your complaint about how your personal information is/was handled by us is not satisfactorily resolved, you may wish to contact the Office of the Australian Information Commissioner.

Online: www.oaic.gov.au

Phone: 1300 363 992

Email: [email protected]

Post: GPO Box 5218, Sydney NSW 2000

Data Disclaimers & Copyright

Third-Party Data Provider Disclaimers and Copyright Notices

This Service incorporates information sourced from Third-Party Data Providers. Set out below are disclaimer and copyright notices of Third-Party Data Providers that apply to their information. Not all end users of this Service will have access to information or data provided by all of the Third-Party Data Providers listed below.

All Third Party Data Providers have exclusive proprietary rights in their respective information and data.

Third-Party Data is provided by third parties beyond our control and we do not take responsibility for its content or for any delays, interruptions or errors in it.

General

The data is provided to end users of the Service on an "as is" basis. The Technology Owner, the Licensor, the Third-Party Data Providers and any other third party involved in or related to the making or compiling of any of the data make no representations or warranties of any kind, either express or implied, with respect to the data (or the results to be obtained by the use thereof) including, without limiting the generality of the foregoing, any and all warranties of originality, accuracy, timeliness, completeness, non-infringement, merchantability and fitness for any particular purpose.

Each user of the Service assumes the entire risk of any use the end user may make of the data. In no event shall the Technology Owner, the Licensor, the Third-Party Data Providers and any other third party involved in or related to the making or compiling of any of the data, be liable to the end user, or any other person, for any direct or indirect damages, including, without limitation, any lost profits, lost savings or other incidental or consequential damages arising out of this agreement or the inability of the customer to use the data, regardless of the form of action, even if licensee, any of its information providers, or any other third party involved in or related to the making or compiling of any of the data has been advised of or otherwise might have anticipated the possibility of such damages.

You shall not use or permit anyone to use the data for any unlawful or unauthorised purpose. You are not authorised or permitted to provide the data to any person or firm for reuse or retransmission without the prior written approval of the source of the data.

Access to the data is subject to termination in the event that any agreement between the Licensor and a provider of information or software distributed through the data is terminated in accordance with its terms. Set out below are specific disclaimers, limitations and copyright notices relating to specific Third Party Data Providers.

ASX Limited / ASX Operations Pty Ltd

Some of the material incorporated in the Service is copyright and is reproduced under licence by ASX Limited ACN 008 624 691 or its related companies. ASX Limited, its related companies and their officers employees are not associated with, and should not be construed as endorsing, promoting or expressing any opinion about, nor bear any liability for any loss arising in connection with the Licensor or the contents of the Service (or the contents of any other website to which one can link from the Service) or any of the Licensor's products or services.

ASX Limited, its related companies, their officers and employees shall not be liable in any way for any loss or damage, howsoever arising (whether in negligence or otherwise) and of or in connection with the contents of and/or any omission from this communication except where a liability is made non-excludable by legislation.

The ASX Logo, "All Ordinaries ASX®' and 'ASX®' are registered trademarks of ASX Operations Pty Limited.

Aspect Huntley

If you are a 'retail client' (as that term is defined in the Corporations Act 2001) and you access information provided by Aspect Huntley you are hereby informed that information regarding Huntley's Investment Information Limited ABN 95 090 665 544 / AFSL 240892 (the providers of the Aspect Huntley Information) can be found on its website: www.aspecthuntley.com.au.

You acknowledge and agree that the information compiled and owned or licensed by Huntley's Investment Information Limited incorporated into the reports provided by it (the "Aspect Huntley Products") do not constitute the provision of 'personal advice' as that term is defined in the Corporations Act 2001 and the Corporation's regulations and that to the extent that is deemed to be 'general advice' under the same provisions, you acknowledge that (a) the information has been prepared without taking into account the objectives, financial situation or needs of any individual; (b) before making any investment decision, an individual should consider the appropriateness of the advice to their circumstances, and obtain specific financial, legal and taxation advice; and (c) all potential investors should obtain a Product Disclosure Statement (PDS) relating to the relevant investment product and consider the PDS before making any decision to invest.

You acknowledge and agree that all information, documents, software, materials, records, data or databases, ratings, concepts, inventions, conclusions, formulations designs, processes, frameworks, diagrams, thinking structures, protocols, models, branding, know-how and analyses which relate to or are derived from the business activities of Huntley's Investment Information Limited or the Aspect Huntley Products

Huntley's Investment Information Limited will not be liable to any person for any loss, damage, cost, expense or other claim (including consequential damages and loss of profits) in relation to Products including, without limitation: (a) any use or reliance on the Aspect Huntley Products by the person (including the form and content of errors in and/or omissions from any information contained in a product); (b) any delay, interruption or other failure in the provision of a product; or (c) any change in the form or content of the products.

Dow Jones

Data that is provided by Dow Jones & Company, Inc ("Dow Jones") is provided "as is". Neither the Licensor, Dow Jones or any third party shall be liable to you or any third party for any loss or damage, direct, indirect or consequential arising from (a) any inaccuracy or incompleteness in, or delays, interruptions, errors or omissions in the delivery of the data or any other information supplied to you through our Services; (b) any decision made or action taken by you or any third party in reliance upon the data. Nor shall we, Dow Jones or any third party be liable for loss of business revenues, lost profits or any punitive, indirect, consequential, special or similar damages whatsoever, whether in contract, tort or otherwise, even if advised of the possibility of such damages incurred by you or any third party.

You may only use the data and information provided by Dow Jones for your own personal and non-commercial purposes while accessing our Services. You may not copy, distribute or redistribute the data, including by caching, framing or similar means or sell, resell, re-transmit or otherwise make the data retrieved from our services available in any manner to any third party. You may not store the data for the purposes of creating a historical database or historical data product. You may not use any of the data in connection with the issuance, trading, marketing or promotion of investment products (e.g., derivatives, structured products, investment funds, investment portfolios, etc. where the price, return and/or performance of the investment product is based on or related to the data) without a separate written agreement with Dow Jones.

NASDAQ
You acknowledge and agree that the NASDAQ Companies have (a) proprietary rights in the information and data that originates on, derives from or relates to markets that are regulated, operated or administered by one or more of the NASDAQ Companies, in the information and data that relates to individuals and entities that are regulated by one or more of the NASDAQ Companies, and in the information and data that relates to activities that are regulated or operated by one or more of the NASDAQ Companies; (b) compilation or other rights in information and data gathered from other sources. All information provided by any NASDAQ Company, including without limitation any and all intellectual property rights inherent therein or appurtenant thereto, shall, as between the parties, be and remain the sole and exclusive property of NASDAQ. You shall not, by act or omission, diminish or impair in any manner the acquisition, maintenance, and full enjoyment by NASDAQ, its licensees, transferees and assignees, of the proprietary rights of NASDAQ in that information.

Nikkei
You acknowledge and agree that any and all intellectual property rights and any other rights in and to the Nikkei Indices are solely owned by Nikkei Inc ("Nikkei") and distributed by Nikkei Digital Media, Inc ("NDM"). "© Nikkei Inc."

You must not make any deletion, addition, alternation or any other changes to and from the content or format of the Nikkei Indices.

The Licensor, Nikkei and/or NDM do not warrant the accuracy and completeness of the Nikkei Indices.

The Licensor, Nikkei and/or NDM shall not be liable to you for any decision made or action taken by you in reliance upon the Nikkei Indices. You shall indemnify and hold harmless the Licensor, Nikkei and NDM from and against any damages or troubles arising out of your usage of the Nikkei Indices

Reuters

Reuters content is the intellectual property Reuters. Any copying, republication or redistribution of Reuters content, including by caching, framing or similar means, is expressly prohibited without the prior written consent of Reuters. Reuters is not liable for any errors or delays in content, or for any actions taken in reliance on any content. Data is provided for information purposes only and is not intended for trading purposes. The RIC or Reuters Instrument Code set has been developed and maintained by Reuters and is the intellectual property of Reuters. Reuters and Reuters sphere logo are trademarks or registered trademarks of the Reuters group of companies around the world. For additional information on other Reuters services, please visit the Reuters public website and www.reuters.com.

Standard & Poor's (for GICS)
The Global Industry Classification Standard (GICS) was developed by and is the exclusive property of Morgan Stanley Capital International Inc. and Standard & Poor's. GICS is a service mark of MSCI and S&P and has been licensed for use by the Technology Provider for incorporation in the Service.

Standard and Poor's Australia Index Alert
Select data is provided by Standard and Poor's a division of The McGraw-Hill Company, Inc. Copyright 2007, all rights reserved. Either the Licensor, Standard and Poor's, their affiliates or third-party licensors have exclusive proprietary rights in the data, any information and software received. Such data is for your internal use only.

Copyright ©2007, Standard and Poor's, a division of the McGraw-Hill Companies, Inc. Standard & Poor's including its subsidiary corporations ("S&P") is a division of The McGraw-Hill Companies Inc. Reproduction of S&P Australia Index Alert in any form is prohibited except with the prior written permission of S&P. Because of the possibility of human or mechanical error by S&P's sources, S&P or others, S&P does not guarantee the accuracy, adequacy, completeness or availability of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. S&P GIVES NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO ANY WARRANTIES OR MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall S&P be liable for any indirect, special or consequential damages in connection with subscriber's or others' use of S&P Australia Index Alert 2007.

Hang Seng
The information referred to in this section is provided by Hang Seng Indexes Company Limited. Neither Hang Seng Indexes Company Limited nor any of its holding companies and subsidiaries nor the Licensor provides any warranties of any kind in relation to such Information (including, without limitation, that the Information is fit for a particular purpose) or accepts any responsibilities for its accuracy, completeness and/or consistency, or for any loss or damage whatsoever and howsoever suffered or incurred by any party. With the use of or the access to the Information referred to in this section, the subscriber or any party irrevocably and unconditionally accepts and agrees to be bound by this disclaimer.

Glossary
In these disclaimers and notices, a reference to:

the "Licensor" is a reference to Præmium Australia Pty Ltd ACN 117 611 784 which provides the Service either alone or with another provider named in the end user licence agreement between the end users of the Service and the Service Providers.
The "Technology Provider" is a reference to Praemium Limited ACN 098 405 826, the owner of the proprietary technology used by the Licensor to deliver the Service;
The "Service" is a reference to VMA, and/or any of the components of the VMA Service, including but not limited to VMA Adviser, and/or VMA whether or not distributed under the VMA brand or any other name or branding;
"Data" means any data which is accessed through the use of the Service; and
"Third Party Data" means Data that is supplied by a person other than the Licensor, including, but not limited to ASX Limited, ASX Operations Pty Ltd, Aspect Huntley, Dow Jones, NASDAQ, Nikkei, Reuters, Standard & Poors, and Hang Seng.