OUR COMMITMENT TO PRIVACY
This Privacy Statement is made on behalf of Innova Asset Management (“Innova”) and its related bodies corporate. Innova recognises an individual’s right to privacy and understands the protection and confidentiality of your personal information is important to you.
The Privacy Act sets out the information that it protects.
Personal information generally means information or an opinion about a person, where the person is identified or is reasonably identifiable.
Sensitive information means a person's health information, genetic information, certain biometric information and biometric templates. It also means certain personal information, being an opinion about a person's:-
- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- membership of a professional or trade association;
- membership of a trade union;
- sexual orientation or practices; or
- criminal record
Sensitive information will seldom be relevant for collection by Innova.
PERSONAL INFORMATION WE COLLECT
Any personal information we collect is through our standard forms (e.g. the Contact Us Form), information you provide through our website, and when you phone or e-mail our staff.
The type of personal information Innova collects from you includes (but is not limited to):
- your name;
- your address;
- your telephone number;
- your date of birth;
- your investment details;
- your bank account information; and
- your tax file number.
The Corporations Act 2001 (Cth) requires us to collect your name, address and date of birth. The Government’s anti-money laundering laws may also require us to collect additional personal information from you.
Phone calls to our Investor Services staff may be recorded or monitored for quality control, training, regulatory or other compliance reasons.
When browsing our website Innova’s webservers automatically collect standard information as part of the HTTP web protocol – your IP address, browser type, operating system, access times, referring sites, pages viewed and other anonymous information. From time to time, Innova may use ‘cookies’ in its website and may collect ‘clickstream’ data. Cookies and clickstream data collects information about your use of our website and potentially other websites.
HOW WE USE PERSONAL INFORMATION
Innova uses your personal information to administer your investment, comply with relevant laws and communicate with you on an ongoing basis about your investment and the market. We may also send you educational and marketing material about our other products and services we offer – you may contact us at any time to unsubscribe from this information.
Innova may use information that you provide through our website or over the phone for analysis to improve our products and services. If we were to do this we will not disclose your personal identification particulars (e.g. your name, date of birth, contact details, bank account details or tax file number).
Staff may also use personal information to verify your identity over the phone.
In some circumstances Innova may disclose your personal information to persons/entities outside of Innova.
- Innova uses agents and external service providers to help us provide our services to you (such as our registry provider, mailing houses, printing companies and external consultants).
- From time to time we may be required to provide your details to a governmental or regulatory body (such as ASIC, ATO, AUSTRAC, or a law enforcement agency).
- A court order may require us to disclose certain information.
Innova takes steps to ensure that our agents and third parties keep your personal information confidential and use it only for the purposes for which they, and Innova, are authorised.
You may also authorise us to disclose information we hold about you to your financial adviser*, administrator* or other person nominated by you. Your express consent is required.
Exemptions Note – Innova intends to rely on some of the exemptions permitted under the Privacy Act. For instance, the exemption for disclosing personal information to our related bodies corporate. Similarly, the employer exemption relating to employee records (we have, however, adopted a number of measures designed to protect the privacy of our employees).
* If you nominate an individual contact within an Advisory firm or Administrative firm, you will be taken to have given authority to the firm and as well as the individual contact.
PERSONAL INFORMATION SECURITY
Innova regards the security of your personal information as a priority and has a number of physical and electronic protection measures in place.
You should be aware that the Internet is not a secure environment. Whilst Innova takes reasonable steps, we cannot guarantee the security of information you provide to us via our website or that we make accessible to you via the secure Investor site. No personal data is stored on our public website. Personal data is stored on our secure Investor site.
ACCESS TO YOUR PERSONAL INFORMATION
If you think the personal information Innova hold about you is not accurate, complete or up-to-date, you should let us know. Also, please let us know any relevant changes to your personal circumstances as soon as possible.
We will take reasonable steps to correct information where you provide sufficient evidence or we are otherwise satisfied, having regard for the purpose for which the information is held, that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will also notify the correction to other parties to whom we have previously disclosed the information and if such a party refuses to make a correction, we will notify you of that refusal and how you can make a complaint.
If you require access to personal information we hold about you, please send us an email to email@example.com. We will generally allow access, unless certain exceptions apply under the Australian Privacy Principle - for example, if we reasonably consider providing access would pose a serious threat to the life, health or safety of any person, or providing access would be likely to prejudice action being taken by an enforcement body, or providing access would be unlawful.
Your request should specify the information to which you require access or which you wish to be corrected.
We will not charge you for requesting access to, or correction of, your personal information. We may, however, charge you the costs associated with meeting your request for access, for example photocopying and postage costs.
We will provide you with access in the manner you request, if it is reasonable and practicable to do so.
We are required to respond to your request for access or correction within a reasonable period.
If we cannot meet your request for access or correction, we will notify you by email and where reasonable we will give you our reason and take steps to provide you with access. We will also tell you about how you can complain about our decision.
NEED TO CONTACT US?
If you have any questions about this Privacy Statement, or wish to make a complaint about how Innova has handled your personal information, or wish to access or correct your personal information held by us, please contact:
Innova Asset Management
Suite 401, 93-95 Pacific Highway
North Sydney NSW 2060