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Your rights in relation to privacy
The privacy of personal information is important to KA JV Pty Ltd (ACN 637 769 361) and its related entities (“Kooyong Group”, “we” or “us”). Kooyong Group is committed to protecting the privacy of an individual’s personal information. This statement sets out how Kooyong Group aims to protect the privacy of your personal information, your rights in relation to your personal information managed by us and the way Kooyong Group collects, holds, uses and discloses your personal information.

In handling your personal information, we comply with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

By providing us with your personal information, you confirm that you have had sufficient opportunity to access and review the terms of this policy and that you have read and consented to them.

What kinds of personal information does Kooyong Group collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its services, Kooyong Group may collect your personal information.

The personal information Kooyong Group collects depends on, and is specific to, the products and services you engage us to provide. Generally, the kinds of personal information we collect includes:

  • your name, address, telephone number, email address and date of birth;
  • other identification verification information, including photographic information, from documents including your birth certificate, passport, driver’s license, pension card, citizenship certificate, tax notice assessment, Medicare card and utilities notices;
  • financial information about your assets, occupation and income, account balances, bank account details, account activities, trust arrangements, payment history and transactions with us and third parties;
  • tax information including your tax file number, tax returns and related information;
  • professional and business information about your membership of a professional association, partnerships, directorships, business names and trust arrangements.

Kooyong Group is also required to collect and verify identification information as required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). In some circumstances, we may also hold other personal information provided by you.

Cookies
Cookies are small text files placed on your hard disk that allow a server to identify and interact more effectively with your computer or device. We may use cookies to enable us to identify you and to personalise and enhance your experience and use of our website (www.kooyonggroup.com.au). For example, a cookie may be used to pre-populate a registration form, or avoid details having to be entered more than once. You can choose if and how a cookie will be accepted by changing your preferences and options in your browser. Please note that declining cookies may impact your experience of our service or limit the use or functionality of our website.

Once you choose to furnish our website with personally identifiable information, this information may be linked to the data stored in the cookie. If requested by you, we will assist you to remove our cookies and/or web beacons.

Web Beacons
Web beacons or clear GIFs are small pieces of code placed on a web page to monitor visitors’ behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons on our website from time to time.

Facebook Pixels, Google Analytics and other similar code
Facebook Pixels, Google Analytics and other similar code are used to analyse and track site visitors and to understand the actions visitors take on websites. We may use Facebook Pixels, Google Analytics and other similar code on our website from time to time.

Geo-tracking
We may (with your prior consent) use geo-tracking to personalise suggested items you may be interested in and to provide you with a better website user experience. Geo-tracking is intended so that our website is useful at particular locations.

Sensitive Information
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by Kooyong Group only:
• for the primary purpose for which it was obtained;
• for a secondary purpose that is directly related to the primary purpose;
• with your consent, or where required or authorised by law.

As part of Kooyong Group’s recruitment process for employees and contractors, we may collect and hold the following kinds of personal information about you: your name, contact details, date of birth, citizenship, employment references, civil, credit and criminal records, regulatory accreditation (such as RG 146 accreditation for advisers), media, directorship, property ownership and driver’s licence information, education and employment history. In the employment context, we may also collect and hold your financial information and banking details.

Kooyong Group does not collect information from you in relation to:
• your race or ethnic origin;
• your political opinions;
• your religious or philosophical beliefs;
• your trade union memberships;
• your genetic or biometric data;
• your health or mortality; and
• your sex life or sexual orientation.

How does the Kooyong Group collect personal information?
Generally, Kooyong Group collects your personal information directly from you, through:

  • completion of an application or other form either online or in hard copy;
  • provision of original, or copies of, documentation whether delivered in person, by post or electronically;
  • direct communication via in-person meetings or telephone/web meetings and exchanges;
  • recordings of conversations (in which case you will be informed of such recording prior to the recording commencing);
    email, or other electronic, correspondence or via our website (www.kooyonggroup.com.au); or
  • receipt of mail which you have directed to be sent to Kooyong Group.

There may be occasions when Kooyong Group collects your personal information from other sources such as from an information services provider, publicly maintained record or third parties such as your family members or professional advisers where we are authorised to do so. Generally, Kooyong Group will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

Why does Kooyong Group need your personal information?
Kooyong Group collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:

  • providing its products and services to you, including:
    – wealth management and investment products and services;
    – tax, accounting and superannuation products and services including audit insurance;
    – estate and succession planning products and services;
    – document and asset custody services;
    – family office services, being financial and intergenerational wealth management products and services specific to family groups;
    – products and services in accordance with any agreement you enter into with Kooyong Group; accounting, billing and other administrative purposes;
    – identifying and informing you of products and services that may be of interest to you from Kooyong Group or other selected third parties; and to assist with your finance and mortgage brokage requirements;
    – any legal requirements, including Kooyong Group’s obligations under:

• the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
• applicable taxation law;
• the Corporations Act 2001 (Cth);
• the Australian Securities and Investments Commission Act 2001 (Cth); and
• the Bankruptcy Act 1966 (Cth).

Tax file numbers are only collected for tax-related purposes.

Where personal information is used or disclosed, Kooyong Group takes reasonable steps to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information but without certain personal information, Kooyong Group may not be able to provide the products or services you require.

We may transfer your personal information to service providers who will hold your information on a cloud computing system, and which may host your data on servers located outside of Australia. However, where your personal information is disclosed to an overseas recipient and/or held on a cloud computing system located overseas, we will take reasonable measures to ensure that your personal information is handled in accordance with the Australian Privacy Principles, the Privacy Act and in accordance with the terms of this policy.

To whom does Kooyong Group disclose your personal information?
Generally, Kooyong Group will only disclose your personal information for the purposes of providing its products and services to you. This may include disclosing your personal information to various entities within Kooyong Group and third parties where necessary to provide you with our products and services. These third parties may include government departments or other regulatory authorities and professional associations, our lawyers, auditors, financial market and clearing and settlement facility operators, lenders, credit providers, insurers and audit insurance providers, custodians, certain software and IT providers, third parties engaged to perform administrative tasks, professional advisers or, if authorised by you, your staff, family members, and associated entities This disclosure is always on a confidential basis. The Kooyong Group may also disclose your personal information with your consent or if disclosure is required or authorised by law.

Direct marketing
Kooyong Group may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting our Privacy Officer on the contact details set out below or through any opt-out mechanism contained in a marketing communication to you.
Security of your personal information

Kooyong Group regards the security of personal information as very important and has implemented a range of measures to ensure the personal information it holds is protected from misuse, interference and loss from unauthorised access, modification or disclosure. The protection measures in place include:

– confidentiality requirements for employees;
– confidentiality statements on all outgoing correspondence including
email;
– document storage security policies;
– security measures including encryption, firewalls, site monitoring and
intrusion detection;
– providing a discreet environment for confidential discussions; and
– only allowing access to personal information where the individual seeking
access has satisfied the Kooyong Group’s identification requirements.

However, Kooyong Group cannot guarantee the security of personal information provided to us electronically via the internet, email or text nor can it guarantee the safe delivery of personal information via ordinary post and as such any communication is made at your own risk. The security arrangements are reviewed and tested from time to time.

Unsolicited Information
Where unsolicited information is received by Kooyong Group, we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information. If it would not be permitted for us to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.

Can you access and correct the personal information that the Kooyong Group holds about you?
Kooyong Group seeks to ensure personal information we hold is accurate, current, complete, relevant and not misleading. We realise that this information may change frequently with changes of address and other personal circumstances. Under the Privacy Act, you have a right to access and seek correction of your personal information that we collect and hold.

If at any time you would like to access or correct the personal information Kooyong Group holds about you, or you would like more information on information security or privacy please contact the Privacy Officer. Kooyong Group will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access or make a correction to your personal information we will have to verify your identity and may charge you an administration fee.

If Kooyong Group refuses your request to access or correct your personal information, we will provide you with written reasons for the refusal and details of complaint mechanisms. Kooyong Group will endeavor to respond to your request to access or correct your personal information within 30 days from your request.

We will keep your personal information as long as it is required for our purposes. We are required to keep some personal information for specific periods of time under the law. When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information is or will be stored in client files which will be kept by us for a minimum of 7 years.

How to contact us – further information, enquiries, or requests
For further information, enquiries or requests regarding your personal information, or if you would like to opt-out of receiving any promotional and marketing communications, please contact Kooyong Group’s Privacy Officer.
Complaint handling processes
Please direct all privacy complaints to Kooyong Group’s Privacy Officer:

The Privacy Officer
Kooyong Group
Level 2, 456 St Kilda Road,
Melbourne VIC 3000
Telephone: 1300 992 208

In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner (OAIC) on 1300 363 992.

Further Information
More information about Australian privacy law is available from the Federal Privacy Commissioner’s website: www.privacy.gov.au

This privacy statement may be updated from time to time. By continuing to use, access or browse our website (www.kooyonggroup.com.au), you accept this policy as modified from time to time.

Last update – September 2020