(ABN: 70 603 580 927)
AFSL No. 473466
Version 1.0 May 2015
Mercury Private Pty Ltd and its related companies (Mercury Private Tax and Accounting Pty Ltd and Mercury Private Operating Company Pty Ltd) (‘Mercury Private’, ‘we’, ‘us’, ‘our’) understands that protection and confidentiality of its clients’ personal information is important. We honour our obligation to respect and protect the privacy of the personal information of individuals with whom we deal and to be open and transparent in how we manage your personal information.
Mercury Private Pty Ltd holds an Australian Financial Services Licence (‘AFSL’) No. 473466, and is subject to Corporations Act 2001 (Cth) and its related regulations. Mercury Private is bound by the Privacy Act 1988 (Cth), as amended from time to time (Privacy Act) and the Australian Privacy Principles (APPs) for the handling of personal information.
- the kinds of personal information that Mercury Private collects and holds;
- how Mercury Private collects and holds personal information;
- the purposes for which Mercury Private collects, holds, uses and discloses personal information;
- how you may access the personal information that Mercury Private holds about you and seek correction of that information; and
- how you may complain about a breach of the APPs and how the complaint will be dealt with.
Your Personal Information and Sensitive Information
‘Personal information’ is any information that identifies an individual or can be linked to an individual.
Mercury Private collects personal information in order to provide you with financial advice, services and process your investment decisions efficiently. We will only collect that information which is reasonably necessary to allows us to provide the services that you require of us.
We do not collect sensitive information about you without your consent such as racial or ethnic origin, political opinions, membership of political, professional or trade associations, religious beliefs, sexual preferences, criminal record, health or disability information.
Any personal or sensitive information that we collect from you will only be used for the purpose for which it was collected subject to the exceptions if it is required by law or is necessary in handling a legal claim.
Collection of Information
We normally collect personal information directly from you but if you have consented, or would reasonably expect us to, we may collect personal information from a third party as well. The Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) and its related regulations (‘AML-CTF Laws’) may also require us to collect additional personal information to identify and verify you.
The types of personal information that we collect will depend on the nature of your dealings with us.
We only collect personal information about you which is reasonably necessary to:
- set up, manage and administer financial products and financial services on your behalf;
- assess your financial product and service needs;
- determine your requirements and provide the appropriate financial product or service to meet your needs;
- provide financial product advice and financial services to you; and
- perform securities transactions for you.
We may also use personal information to send you research reports and information on related services we provide, which may be of benefit to you.
We generally hold personal information relating to:
- the products and services we provide or have provided to you;
- your name, gender, date of birth, bank account details, investment details and tax file number;
- investment experience, objectives and risk profile;
- your financial interests and your financial position; and
- your contact details such as residential and postal addresses, telephone and mobile numbers and email address.
While we are required under certain circumstances to collect government identifiers such as your tax file number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.
We do not collect personal information about you if you only browse our website. However, we will be aware of your identity when you log into our website.
Mercury Private collects statistical information on website activity, such as the number of users who visit the website, the date and time of visits, the number of pages viewed and how users navigate through the websites and other anonymous information. Information on visits to the website is automatically collected. To collect this information we may use session cookies. These cookies are used as a security measure to identify you before allowing you access to your confidential account information. We collect this information for the purposes of our own analysis.
How We Collect That Information
Mercury Private may collect personal information in the following ways:
- from our Client Service Agreement;
- from an application form for a financial product or service, or a related form required for administering or managing the product or service we are providing;
- by telephone, email or facsimile;
- when you meet with us;
- in correspondence;
- completed questionnaires; and
- when you provide a change of details eg. address or banking details.
Mercury Private will only collect personal information that is necessary for us to properly provide our services to you. In most cases we will collect information directly from you. Sometimes personal information may be collected about you from other sources, including but not limited to share registries, other financial institutions including stockbrokers and fund managers, insurance companies and credit reporting agencies.
Uses of Information
Any personal information we collect from you may be made available to, or used by your adviser, employees of Mercury Private or any entity carrying out functions on behalf of Mercury Private for the purposes related to the provision of financial services. This may include:
- making investment recommendations;
- reviewing your investment recommendations; or
- to verify your identity and for customer due diligence purposes.
Personal information provided by you will be held in the strictest confidence by us. We do not give information about you to anyone else unless one of the following applies:
- it is necessary in order to provide you with our financial services;
- you have consented; or
- it is required by law.
The types of organisations to whom we typically disclose your personal information includes information technology providers (for the purpose of maintenance of our IT systems) and related service providers, a settlement and clearing organisation, product issuers, insurance companies, stockbrokers, organisations undertaking compliance reviews of our company or other due diligence undertaken on us or our representatives.
If we have to transfer personal information outside Australia, we will comply with trans-border data flow standards under the Privacy Act, for example, by taking reasonable steps to protect the information being held, used or disclosed by the recipient and is not in breach of the APPs.
Should you wish to authorise the disclosure of your personal information to other parties, eg. your Accountant, please notify us in writing.
We may use personal information collected from you to advise you about other financial products and services, or survey your opinions on products or services. You may elect not to receive such information by contacting your advisers, in which case, we will record that you do not want to receive such material.
If you choose to not provide information about your identity and your personal information, or information that is incomplete or inaccurate, it may:
- mean that we cannot provide you with financial services;
- result in you paying more tax than may otherwise apply; or
- result in the provision of a financial service that is not appropriate to your circumstances, needs and objectives.
You may request access to the personal information that we hold about you and ask us to correct personal information we hold, which we will respond to your request in a reasonable timeframe. We are bound by the APPs and reserve the right to charge a fee for supplying the information. If it is not possible for us to give you access we will endeavour to provide an explanation.
Maintenance of accurate records
We take all reasonable steps to ensure that all information we hold is as accurate as is possible, up-to-date and complete. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete. We will take reasonable steps to correct personal information to ensure that it is correct, up-to-date, complete, relevant and not misleading if we believe that it needs to be corrected or you request it be corrected.
To protect your personal information online, Mercury Private uses secure technology methods. For example, our website has electronic security systems in place, including the use of firewalls and data encryption. User identifiers, passwords and other access codes may also be used to control access to your personal information.
However, you should be aware that the internet is not a totally secure environment. Mercury Private cannot guarantee the security of information you provide to us or we provide to you via the internet.
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to review those websites to ascertain their privacy standards, policies and procedures.
Mercury Private Pty Ltd
PO Box R203, Royal Exchange, NSW, 1225
We will review and assess your issue and provide feedback to you as quickly as possible. If you remain unsatisfied with our handling of the issue you have raised you may refer your complaint to the Privacy Commissioner.
For more information on privacy matters in general you can visit the Privacy Commissioner’s website at www.privacy.gov.au.