iComply2 | Privacy Policy

Updated 09 September 2023

Privacy Policy

iComply2 Financial Services Pty Ltd is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

About iComply2

iComply2 provides a software-as-a-service to financial advisers and AFSL holders. We also provide Xplan Wizards and document template coding services to AFSL’s holding their own Iress Xplan instance.

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained in many ways including interviews, correspondence, by telephone and facsimile, by email, via our website, from your website, from media and publications, from other publicly available sources, from cookies and from third parties. We don’t guarantee website links or policy of authorised third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

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 us 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.

Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

•Third parties where you consent to the use or disclosure; and

•Where required or authorised by law.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

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.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Access to Personal Information

We may collect, hold, use and disclose personal information for the following purposes:

to enable you to access and use the service;
to generate Financial Documents;
to contact and communicate with you;
for internal record keeping, administrative purposes, invoicing and billing purposes;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have; and

Where personal information is provided to us , we are relying on you that you have obtained consent to the personal information being collected by us and being stored, used, processed and disclosed as set out in this Privacy Policy.

You agree that you have obtained the authority from each person to whom you provide financial advice to provide us with their personal information and that you have obtained their informed consent for us to collect, store, use, process and disclose their personal information in accordance with this Privacy Policy. You should let us know immediately if you become aware that your personal information has been provided to us without consent.

Your personal information may only be used and disclosed for the primary purposes for which it was collected as well as for secondary purposes relating to the primary purpose for which your personal information was collected, including:

providing services for a purpose that is directly related to the primary purpose for which the personal information was collected; and
data analytics purposes. Disclosure of personal information to third parties

We may disclose personal information to:

third party service providers (whether in Australia or overseas) for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem- solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
regulatory authorities who have jurisdiction over us;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia, including without limitation, United States of America; and
third parties to collect and process data, such as Microsoft Azure, Amazon Web Services (AWS), docmosis, bubble.io or other relevant businesses. This may include parties that store data outside of Australia, including without limitation, the United States of America.

In addition, you permit us to use your personal information:

where we reasonably believe that use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone’s health or safety or the public’s health or safety;
where we reasonably suspect that unlawful activity has been, is being or may be engaged in and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process); and
where we reasonably believe that use or disclosure is necessary for the prevention, investigation, prosecution and punishment of crimes or wrongdoings or the preparation for, or conduct of, proceedings before any court or tribunal (or the implementation of orders of a court or tribunal or on behalf of an enforcement body).

By providing us with personal information, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy law. You acknowledge that some overseas third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act and if any third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act and you will not be able to seek redress under the Privacy Act.

Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Storage and security

Policy Updates

This Policy may change from time to time and is available on our website.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

Level 10, 60 York Street

Sydney, NSW 2000 Australia