Ulton Privacy Policy

ULTON PRIVACY POLICY

In this Privacy Policy, ‘Ulton’, ‘we’, ‘us’ and ‘our’ refers to the partnership carrying on business under the name Ulton and includes any entity owned or controlled by the Ulton Group.

At Ulton, we recognise the importance of protecting and maintaining your personal information. We appreciate that you may have concerns about your privacy and about the security, accuracy and confidentiality of personal information. Ulton is committed to providing you with the highest quality professional service whilst also protecting your privacy. Ulton abides by the Australian Privacy Principles established under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Privacy Act 1988.

1. Open and transparent management of personal information

Ulton manages personal information in an open and transparent way by complying with the Australian Privacy Principles. We will remain open with you about what sort of personal information we hold, how we collect it, and for what purposes we use and disclose this information.

The Ulton Privacy Policy is available on our website or may be obtained by contacting the Privacy Officer. If you have any queries or complaints about Ulton’s compliance with the Australian Privacy Principles, please contact the Privacy Officer using the ‘How to Contact Us’ information shown below. 

If you believe that Ulton has breached the Australian Privacy Principles, please contact the Privacy Officer in writing. We will respond to you within 30 days. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner.

2. Anonymity and pseudonymity

When engaging with Ulton, you have the option of not identifying yourself or you may use a pseudonym. At times this may not be practicable because we need personal information to provide services to you and if you do not provide the information requested, we may be limited in our dealings with you. If it is important to you, and your identification is not required by us, you may request that we deal with you anonymously or by using a pseudonym.

3. Collection of solicited personal information

Our ability to provide you with a comprehensive service is dependent on us obtaining certain personal information. We will endeavour to only solicit or collect personal information that is reasonably necessary or, or directly related to, the provision of our services. This might include but not limited to:
  • name and contact details
  • date of birth and gender
  • bank account details
  • employment details and employment history
  • details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, investments, insurance cover and superannuation
  • documentation used for identification and verification purposes
Some personal information is considered to be ‘sensitive information’. It may be necessary in some instances for Ulton to collect sensitive information about you, for example, your Tax File Number, professional or political memberships, religious beliefs, relationship status, trade or professional associations and health information.

Ulton will collect information that is reasonably necessary for the primary purpose of providing a professional service to you and also for complying with our legal obligations. If this information is considered sensitive, then unless the law provides otherwise, Ulton will also require your consent, which is defined in (section 6.1) as 'Expressed Consent or Implied Consent" to the collection of this sensitive information. We will only collect sensitive information if it is necessary to provide our services to you.

Ulton will collect personal information only by lawful and fair means. In most instances, we will collect personal information from you unless it is unreasonable and impracticable to do so.

4. Dealing with unsolicited personal information

If Ulton receives unsolicited personal information that we know could have been collected from you, we will afford it the same privacy protection as if we had solicited this personal information. If the information is not reasonably necessary for one or more of Ulton’s functions or activities we will determine whether the information could have been collected under APP3 (collection of solicited personal information). If it could not have been collected under APP 3, we will destroy or de-identify the personal information as soon as practicable, unless it is contained in a "Commonwealth record” or it is unlawful or unreasonable to do so.

5. Notification of the collection of personal information

Ulton will endeavour to collect personal information directly from you, however, at times Ulton may need to collect personal information from a third party and when this occurs we will take reasonable steps either to inform you or to ensure you are aware of these matters. We will also be clear about the purpose of the collection, who we might disclose this information to, whether the personal information is required under an Australian law or a court/tribunal order and the main consequences of not collecting this information.

We will also inform you if Ulton is likely to disclose the personal information to overseas recipients, including the countries in which the recipients are located.

6. Use or disclosure of personal information

Ulton will not use or disclose personal information collected by us for any purpose other than the primary purpose for which it is collected, unless you would reasonably expect us to use or disclose the information for a secondary purpose or your consent has been obtained to use the information for additional purposes. Exceptions to this include, but are not limited to where disclosure is:
  • required by superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial plan and recommendations made by us
  • required by law or for inspection to ensure compliance with mandatory professional standards
  • to assist other professional advisers within the Ulton Group to provide you with a comprehensive service
  • to keep you informed about Ulton services and developments and those of relevant businesses and joint initiative partners
  • record your marketing and communication preferences reasonably necessary to assist a law enforcement agency
  • external service providers for the purposes of audit, peer reviews, legal advice, consultancy, outsourced administration, issuing statements or handling mail
  • required by reporting entities for the purpose of complying with the Anti-Money Laundering and Counter-terrorism Financing legislation
  • permitted under the Australian Privacy Principles

7. Direct marketing

Ulton may use or disclose the personal information we hold about you for the purpose of direct marketing, such as articles that may be of interest to you. If there is a reasonable expectation that your personal information will be used for this purpose and you have not opted out of receiving direct marketing communications from us, or where you have provided your consent.

Ulton will not directly market to you using information that is considered sensitive unless you have provided consent.

APP 7.2 provides that an organisation may use or disclose personal information (other than sensitive information) about an individual for the purpose of direct marketing if:
  • the organisation collected the personal information from the individual
  • the individual would reasonably expect the organisation to use or disclose the personal information for that purpose
  • the organisation provides a simple way for the individual to request not to receive direct marketing communications from the organisation (also known as ‘opting out’), and
  • the individual has not made such a request to the organisation.
If you wish to opt out of all marketing communications, or wish to modify your communications preferences, please notify the privacy officer whose details are listed below.

8. Cross-border disclosure of personal information

Ulton may transfer or store your personal information outside Australia. If we engage with, or are required to send personal information to an overseas entity to fulfill the purpose for which the personal information was collected (or a related or ancillary purpose), we may seek your consent with regards to the disclosure.
If we do disclose personal information to an overseas recipient without your consent, we are required to take reasonable steps to ensure that this recipient does not breach the Australian Privacy Principles or a similar applicable law in relation to that information.

9. Adoption, use or disclosure of government related identifiers

Ulton will not adopt, use or disclose government agency identifiers, for example, tax file numbers, as our primary means of identifying you unless it is required or authorised by or under an Australian law or a court/tribunal order.

10. Quality of personal information

Our goal is to ensure that, at all times, the personal information we collect, hold, use or disclose is up to date, accurate and complete. We will take reasonable steps to correct personal information. If you become aware, or believe, that any personal information we hold is inaccurate, incomplete or out of date, please contact your relationship manager or the Privacy Officer at the details provided below. 

11. Security of personal information

Ulton takes the security of your personal information very seriously. We have implemented significant measures and precautions to protect the personal information we hold (electronic and physical) from such risks as misuse, interference and loss, and from unauthorised access, modification or disclosure. We take reasonable steps to destroy or permanently de-identify any personal information no longer required.

12. Access to personal information

Individuals may at any time request access to personal information that Ulton holds about them. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. If Ulton were to refuse to give access to the personal information, or in the manner requested, we will provide written notice of the reasons (unless unreasonable to do so) and details should you wish to complain about the refusal. Generally a refusal will only be in cases where denying such access is permitted under the Australian Privacy Principles or is otherwise lawful.

All requests for access to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period (but not more than 30 days) after the request is made. Ulton may charge a reasonable fee for supplying personal information.

13. Correction of personal information

If Ulton holds information about you for a purpose and knows that the information is inaccurate, out of date, incomplete, irrelevant or misleading we will take steps to correct the information. If you request us to correct the information we will take reasonable steps to do so.

If a third party is relying on this information, at your request we will also notify them, unless it is impracticable or unlawful to do so. If we refuse to make a correction, we will let you know why and the complaint mechanisms that are available to you. If we continue to use this information, you may request us to associate a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

All requests for correction to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period after the request is made. We will not charge you for making the request for the correction of personal information.

Privacy on our website

Ulton is strongly committed to your right for privacy. www.ulton.net is administered by Ulton and its primary purpose is to be a useful resource and business tool to support you. Ulton want you to feel secure when visiting our site and are committed to maintaining your privacy when doing so.

Ulton believes that the responsible use of client and visitor information collected through its website is a critical function of its relationship with clients. To reflect our commitment to client and visitor privacy, we have adopted the privacy principles outlined in this policy. In addition to these principles, and specifically in relation to our website, we implement the following policies:

Cookies and IP address Information

In order to monitor our website's performance, and to measure if we are fulfilling your needs for a relevant and up to date information service, we may track your IP address and session time. This information cannot be used to identify you and will at all times remain anonymous.

Ulton’s website may use cookies. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognise your browser and capture and remember certain information. We use cookies to 'remember' your browser between page visits. In this situation, the cookie identifies your browser, not you personally. A cookie in no way gives us access to your computer or any information about you, other the information you choose to share with us. Cookies help us analyse data about web page traffic and improve our website in order to tailor it to customer needs. If you prefer not to accept a cookie, you can set your web browser to warn you before accepting cookies, or you can refuse all cookies by turning them off in your web browser.

Personally Identifiable information disclosed by third parties

Ulton provides its services to you with the assistance of related companies, contractors, agents and suppliers. It may need to provide these parties with some of your personal information. Where your details are provided to any other party, Ulton will require them to be kept safe and secure and only used for the intended purpose.

Links to Third Party Sites

This website contains links to other sites, maintained by other organsiations, and Ulton does not take any responsibility for the content or functionality of those sites.

When you visit any part of our websites, we collect statistical data about that visit (e.g. what you looked at, the way in which you moved around the site, etc) which is not personally identifiable. We use this information for statistical purposes and to improve our website. We generally only collect personal information from our website when it is provided voluntarily by you.

How to Contact Us

All requests for access or correction to personal information, privacy complaints, queries in relation to this Privacy Policy, or any other privacy related matter, should be directed to the Privacy Officer at Ulton as follows:

The Privacy Officer
Ulton
PO Box 3321
HERVEY BAY QLD 4655 
T: 07 4197 6301  
F: 07 4197 6310  
E: bwhebell@ulton.net

We will respond to your request within a reasonable time and in accordance with the requirements of the Privacy Act.

If you have made a privacy complaint and believe that Ulton has not adequately handled your complaint, you may complain to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
T: 1300 363 992
E: enquiries@oaic.gov.au 
 
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