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.
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 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
- 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.
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.
Phone: 1300 363 992
Email: [email protected]
Post: GPO Box 5218, Sydney NSW 2000
Data Disclaimers & Copyright
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