About this Privacy Policy
Lothbury Advisory (‘Lothbury’) is committed to treating with care, the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act).
In this Privacy Policy, any mention of ‘Lothbury’/‘we’/‘us’ and ‘our’ refers to Lothbury Advisory.
This Privacy Policy has been published to provide a clear and concise outline of how and when personal information is collected, disclosed, used, stored and otherwise handled by Lothbury. The Policy relates to personal information collected by any means and by any technology.
By using the products or services provided by us you consent to Lothbury using your personal information as set out in this Privacy Policy.
The Policy outlines the obligations Lothbury has in managing the personal information we hold about our clients, potential clients, contractors and others, in order to comply with the Privacy Act. It is our objective to handle information responsibly and provide you with some control over the way information about you is handled and stored.
Our Commitment to Protect Your Privacy
We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any information we hold about you will be treated in a way which ensures protection of that information.
Our commitment in respect of your information is to abide by the Australian Privacy Principles, as set out in the Privacy Act 1988 (Cth).
Personal Information
When we refer to personal information we mean information or an opinion relating to an individual which can be used to identify that individual.
The kinds of personal information we collect about you includes (but is not limited to):
- Names
- Contact Details
- Genders
- Dates of Birth
- Employment details and employment history
- Tax File Numbers
You have a right not to provide us with your personal information, but failure to provide such information may affect the services we provide to you. We will not collect any personal information about you except when you have knowingly provided that information to us or authorised a third party to provide that information to us.
Why we Collect Your Personal Information
We collect personal information for the purposes of providing services to you, identifying you, providing you access to our capital raisings and managed funds. We may also collect your personal information for the purposes of managing our relationship with you. The information may also be used by us for marketing, planning, product development and research purposes.
In providing our services to you we may need to disclose personal information to a third party. This will be done to the extent that it is permitted by law and set out in this Policy.
How do we Collect Your Personal Information?
Where reasonable and practical we will collect your personal information directly from you. We will generally collect information by way of face-to-face meetings, completed forms, business cards, telephone conversations, applications, interviews, emails and invitations.
In some circumstances, we may collect personal information about you from a third party. Some examples of third party sources include referees and publicly available records.
Cookies
Cookies are small pieces of information stored on the web browser on your computer. Any web server (including our web server) may from time to time:
- Store one or more cookies on your web browser;
- Request your browser to send data back to our web server; and/ or
- Request your browser to send a cookie which has been stored on your web browser by another website in the same internet domain.
Our website may store cookies on your web browser to improve your use of our website the next time you visit. Cookies allow a website to track information about use and behavioural patterns on a website. We may use cookies to measure visitor use of our website, but we will not collect or store any personal information about you.
Do we Disclose Your Personal Information?
We may disclose your personal information:
- to share registries;
- within the Lothbury entities;
- to other financial institutions that provide financial services eg stockbrokers, fund administrators, custodians, responsible entities;
- to other organisations that are involved in managing or administering our financial services;
- to other organisations such as third party suppliers, printing and postal services;
- our technology providers;
- to anyone, where you have provided us consent;
- to any person where we are required to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth) or the Corporations Act 2001 (Cth);
- to any person or entity considering acquiring an interest in our business or assets.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
- the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
- you have consented to us making the disclosure.
Emails you receive from us
We may use your email address to send you information about our newsletters, seminars or events. We may also contact you to provide details of an offer that may be of interest to you or to seek your opinion or comment on our website and our service offering.
We do not send spam emails. You can unsubscribe from our emails at any time. You can also contact us by emailing admin@lothbury.com.au if you prefer not to receive such information and we will comply with your request. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
Updating Your Personal Information
It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed. If you wish to make any changes to your personal information, please contact our Compliance Officer in accordance with the details below.
Access and Correction to Your Personal Information
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time by contacting our Compliance Officer in accordance with the details below. We may charge a fee for our costs of retrieving and supplying the information to you, depending on its location and volume.
Depending on the type of request that you make we will usually respond to you within 14 days of receiving your request. We may need to contact other entities to properly investigate your request. If your request is urgent, please clearly indicate this in your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious. An explanation will be provided to you if we deny you access to the personal information we hold about you.
We attempt to keep all personal information which we hold about you up-to-date and accurate. If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the information. At the time of the request, otherwise, we will provide an initial response to you within 7 days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days. If we refuse to correct personal information we will provide you with our reasons.
Using Government Identifiers
We do collect government identifiers, such as your tax file number, but only when you invest in a managed fund.
Business Without Identifying You
It is necessary for us to identify you in order to undertake business with you in compliance with our legal obligations. Therefore, we will be unable to do business with you if you wish to remain anonymous.
Sensitive Information
Some personal information that we collect is “sensitive information”. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health information.
Unless you agree otherwise, sensitive information will only be used and disclosed for the purpose for which it was provided, for a directly related secondary purpose or where certain other related circumstances apply (eg: where required by law).
How Safe and Secure is Your Personal Information that we Hold?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and / or electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure. We hold information for the period reasonably necessary to provide our services to you, and to comply with our legal obligations.
If we no longer require your personal information for any of the purposes outlined in this privacy policy, we will take reasonable steps to destroy it securely.
Complaints
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact the Office:
Address:
19 Charles Street
South Perth WA 6151
Email:
admin@lothbury.com.au
We will acknowledge your complaint within 7 days. We will provide you with a decision on your complaint within 30 days.
If you believe Lothbury has not adequately dealt with your complaint and you are not satisfied, you may also complain to the Officer of the Australian Information Commissioner (OAIC) whose contact details are as follows:
Address:
GPO Box 5218
Sydney NSW 2001
T: 1300 363 992
Email: enquiries@oaic.gov.au
You may also lodge a complaint directly with the OAIC on their website.
Changes in our Privacy Policy
We may, without notice, amend this Policy from time to time for any reason and will update the Policy accordingly. We ask that you visit our website periodically in order to remain up to date with such changes. We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices. As a consequence we may change this Privacy Policy from time to time or as the need arises.
You may request a copy of this Privacy Policy in an alternative form.