PRIVACY POLICY

This Privacy Policy details how Vincents (ABN 69 984 359 704) and its related entities, which include VCA Services Pty Ltd, Vincents Lending Solutions Pty Ltd, Vincents Lending Solutions Unit Trust, VCA Finance Pty Ltd, VCA Finance Unit Trust, Vincents Audit Services Pty Ltd, Vincents Advisory Pty Ltd, Vincents Capital Management Pty Ltd, Vincents LifeVantage Pty Ltd, Vincents Corporate Advisory Pty Ltd, Vincents Private Wealth Pty Ltd and their related entities and operating entities (collectively Vincents, we, us and our) manage your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (collectively Privacy Act).

All references to “personal information”, “sensitive information” and “health information” in this Privacy Policy have the meanings given to these terms under the Privacy Act. Unless otherwise specified all references to “personal information” in this Privacy Policy includes “sensitive information”.

The specific types of personal information and sensitive information we collect about you depend on which of our services are being provided to you. For some services or where additional personal information or sensitive information not detailed in this Privacy Policy is to be collected, we will provide you with a separate privacy collection notice (PCN) for that service or collection. Any such PCN is to be read together with this Privacy Policy in relation to that service or collection.

By providing us with any of your sensitive information identified in this Privacy Policy or a PCN provided to you at the time of collection of your sensitive information or using our services, you consent to us collecting, using and disclosing your sensitive information as detailed in this Policy or any relevant PCN, as applicable. This consent remains valid unless and until you notify us in writing (using the details in the section “Our Contact Details” below) of the withdrawal of your consent to our processing of your sensitive information. However, if you do so or if you do not provide us with the requested sensitive information for the relevant purpose(s) in the first place, we will be unable to provide you with the relevant services for which we are seeking to collect, use and disclose your sensitive information.

You are not required to provide us with any personal information. However, if we do not receive the personal information we request, we will not be able to respond to your requests or queries or provide our services to you.

The Kinds of Personal Information We Collect & Hold

The kinds of personal information that we collect depends on the nature of our engagement with you and includes:

Personal information

For our individual clients and directors and employees of our corporate clients

1. Name and date of birth
2. Contact details including phone number, address and email addresses
3. Identity information including driver’s licence details, Medicare card details, pension card details, passport details and work permit or visa details and their respective government related identifiers including driver licence numbers, Medicare numbers and passport numbers
4. Employment information including job title and salary
5. Financial information including bank account information, taxation information such as tax file numbers, payment details, credit information such as credit reports, credit terms and current and prospective guarantees, superannuation arrangements, information relating to personal spending habits, personal assets and liabilities, and details of businesses relating to you
6. Family information such as marital status, dependents and beneficiaries
7. Subscription and marketing preferences and responses to our surveys
8. Details of requests and complaints received by us
9. Information relating to our provision of services and performance of our functions or activities or the processing of claims

For individuals who are not an individual client or directors or employees of our corporate clients but whose personal information is provided to us by or on behalf of our clients, for example, by our Audit & Assurance, Forensic Services, Lending Solutions, Private Wealth and Restructuring & Recovery clients (Other Individuals)

1. Name and date of birth
2. Contact details including phone number, address and email addresses
3. Identity information including driver’s licence details, Medicare card details, pension card details, passport details and their respective government related identifiers including driver licence numbers, Medicare numbers and passport numbers
4. Financial information including bank account information, taxation information such as tax file numbers, payment details, superannuation arrangements, information relating to personal assets and liabilities and details of businesses relating to you
5. Family information such as marital status, dependents and beneficiaries
6. Information relating to our provision of services and performance of our functions or activities or the processing of claims

For participants of our networking, education or other public events

1. Name
2. Contact details including phone number, address and email addresses
3. Employment information including job title
4. Subscription and marketing preferences and responses to our surveys
5. Dietary requirements
6. Photos and videos in which you are reasonably identifiable
7. Other information you provide to us when attending our events

For visitors to our websites

1. Subscription and marketing preferences
2. Other information you provide to us or submit when visiting our website or information we receive when you interact with our websites or other websites that can reasonably ascertain your identity

For job applicants

1. Name and date of birth
2. Contact details including phone number, address and email addresses
3. Identity information including driver’s licence details, passport details, and work permit or visa details and their respective government related identifiers including driver licence numbers and passport numbers
4. Employment information including employment history and references and educational qualifications

Sensitive information

For our individual clients

1. Health information and medical information
2. Criminal record

For Other Individuals

1. Health information and medical information
2. Criminal record

For participants of our networking, education or other public events

1. Dietary requirements that reveal your racial or ethnic origin or religious beliefs
2. Other requests that reveal your health information (e.g. if you have a disability)

For job applicants

1. Criminal record

How We Collect Your Personal Information

We collect personal information by the following means:

Personal information

For our individual clients and directors and employees of our corporate clients

1. Directly from you when you provide us with your personal information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from your agent, authorised representative or employer
3. Indirectly from third parties that we have engaged to provide our services to you or your employer, such as legal professionals, investigators, experts and witnesses, other third parties such as product issuers or a publicly available source such as government database and social media platform
4. Indirectly from credit reporting bodies if our services for you involves analysis of your financial position and creditworthiness which requires us to obtain your credit reports from credit reporting bodies

For Other Individuals

1. Directly from you when you provide us with your personal information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from our clients, other third parties such as legal professionals, investigators, experts and witnesses or a publicly available source such as government database and social media platform

For participants of our networking, education or other public events

1. Directly from you when you provide us with your personal information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from your agent, authorised representative, employer or family member
3. Indirectly from third parties that we have engaged to manage our events and marketing activities, other third parties such as sponsorship partners, associations and other participants of the event or a publicly available source such as government database and social media platform

For visitors to our websites

1. Directly from you when you visit and interact with us through our website or via different types of technology, including, but not limited to, cookies and tracking technologies
2. Indirectly from third parties that we have engaged, in relation to information they received when you interact with other websites that can reasonably ascertain your identity

For job applicants

1. Directly from you when you provide us with your personal information in your job application, when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from nominated referees, other third parties such as recruiters, current or former employers and contractors that conduct background checks and right to work checks for us or a publicly available source such as government database and social media platform

Sensitive information

For our individual clients and directors and employees of our corporate clients for the sensitive information noted above

1. Directly from you when you provide us with your sensitive information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from your agent, authorised representative or employer
3. Indirectly from third parties that we have engaged to provide our services to you or your employer, such as legal professionals, investigators, experts and witnesses

For Other Individuals for the sensitive information noted above

1. Directly from you when you provide us with your sensitive information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from our clients, other third parties such as legal professionals, investigators, experts and witnesses or a publicly available source such as government database

For participants of our networking, education or other public events

1. Directly from you when you provide us with your sensitive information when corresponding with us in writing, whether it is by mail, email, electronically or in any other format, or verbally, whether it is in person (such as during meetings) or over the phone (including phone recordings when notified)
2. Indirectly from your agent, authorised representative or employer
3. Indirectly from third parties that we have engaged to manage our events and marketing activities or other third parties such as sponsorship partners, associations and other participants of the event

For job applicants for the sensitive information noted above

1. Directly from you if you provide us with your criminal record in your job application
2. Indirectly from third parties such as contractors that conduct background checks for us or a publicly available source such as government database

The Purposes for which We Collect Your Personal Information

The purposes for which we collect, use and disclose your personal information include:

Personal information

For our individual clients and directors and employees of our corporate clients

1. To provide our services including, but not limited to, Audit & Assurance, Business Advisory, Corporate Advisory, Economics & Data Analytics, Forensic Services, Governance, Risk & Controls Advisory, Lending Solutions, Private Wealth, Restructuring & Recovery, SMSF & Superannuation Advisory and Workforce Advisory
2. In relation to your government related identifiers, to verify your identity
3. To administer your accounts with us, manage insurance policies, billings and refunds, and collect payments
4. To contact you about other services that may be relevant to you and our networking, education or other events, and for training purposes
5. To respond to your queries and service reviews, analyse your survey responses and respond to and investigate your complaints and requests
6. As required or authorised by law including, but not limited to, the Corporations Act 2001 (Cth) (Corporations Act) and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AMLCTF Act)

For Other Individuals

1. To provide our services including, but not limited to, Audit & Assurance, Forensic Services, Lending Solutions, Private Wealth and Restructuring & Recovery to our clients

For participants of our networking, education or other public events

1. For marketing and business development purposes and to manage our events
2. To contact you about services that may be relevant to you and other events
3. To analyse your survey responses and respond to and investigate your complaints and request

For visitors to our websites

1. To measure the effectiveness and usage of our website
2. To contact you about other services that may be relevant to you and our networking, education or other events, and for training purposes

For job applicants

1. For recruitment purposes and to assess your suitability for the position
2. In relation to your government related identifiers, to verify your identity

Sensitive information

For our individual clients and directors and employees of our corporate clients for the sensitive information noted above

1. To provide our services including, but not limited to, Audit & Assurance, Forensic Services, Lending Solutions, Private Wealth and Restructuring & Recovery
2. In relation to your criminal record as required or authorised by law including but not limited to the AMLCTF Act

For Other Individuals for the sensitive information noted above

1. To provide our services including, but not limited to, our Audit & Assurance, Forensic Services, Lending Solutions, Private Wealth and Restructuring & Recovery to our clients

For participants of our networking, education or other public events

1. To accommodate your dietary requirements and manage the event

For job applicants for the sensitive information noted above

1. For recruitment purposes and to assess your suitability for the position

Direct Marketing

In addition to the above purposes, we may use and disclose your personal information to provide you with information and offers about our products and services or products and services of others that we believe are relevant to you (including by way of direct mail, telephone, email, SMS, and online advertising and marketing) for marketing and business development purposes or to request your feedback for research purposes.

You have the right to opt out of direct marketing and the right to withdraw your consent to receive direct marketing from us by following the “unsubscribe” link provided in our electronic communications or contacting our firm’s marketing manager as identified within our website.

Automated Decision Making

If you are a customer or a prospective customer in our Lending Solutions services, we use a software application that conducts a preliminary assessment of your capacity to service your existing commitments and additional debt that is sought, as part of our decision on what solutions we can provide to you. This software application uses your personal information including age, relationship status, dependents, income, existing commitments, proposed commitments and assets. The software application generates a preliminary assessment which helps to determine your financial position and capacity to support additional debt. and the outcome influences what solutions (if any) we propose to you as part of our Lending Solutions services. In circumstances where the preliminary assessment outcome is not positive, we will aim to provide alternative solutions, including providing you information about the outcome to ensure you are clear on why an application may not be supported and/or what steps could be taken to improve your chances of a successful application in the future.

Disclosure of Personal Information

For the purposes noted above, we may disclose your personal information to the following entities:

 Personal information

For our individual clients and directors and employees of our corporate clients

1. Providers of insurance or related products, superannuation fund trustees, fund managers and their authorised representatives in connection with our services for you or companies of which you are a director or employee
2. If our services for you involves analysis of your financial position and creditworthiness which requires us to obtain your credit reports from credit reporting bodies, credit reporting bodies, and information that we disclose will be limited to information that is required by the credit reporting body to provide the credit reports
3. If our services for you involves share trading and/or investment administration on your behalf, Morgans Financial Limited, through which we lodge and conduct share trading
4. Courts and tribunals
5. Legal professionals and other third parties such as investigators, experts and witnesses that assist in the preparation of expert reports, relevant documents or other evidence in connection with our services for you or companies of which you are a director or employee
6. Vincents (other than the Vincents entity with which you are dealing) to assist in the performance of our services, including auditing, accounting, payments, compliance, fraud detection, anti-money laundering, marketing or other professional services or store information on behalf of the Vincents entity that originally collected your personal information
7. Third parties that assist us in our provision of our services to you or companies of which you are a director or employee, assist us in the delivery of direct marketing materials to you, perform auditing, accounting, payments, insurance administration, compliance, fraud detection, anti-money laundering, marketing or other professional services for us, or manage our information systems, software, platforms or applications that process information for us
8. Government agencies, regulators or other parties as required or authorised by law including, but not limited to, the Corporations Act and the AMLCTF Act, for an enforcement related activity, when it is reasonably necessary for a claim or a confidential alternative dispute resolution process or otherwise as permitted or required by law

For Other Individuals

1. Courts and tribunals
2. Legal professionals and other third parties such as investigators, experts and witnesses that assist in the preparation of expert reports, relevant documents or other evidence in connection with our matters
3. Vincents (other than the Vincents entity that collected your personal information) to perform compliance or other professional services or hold information for the Vincents entity that collected your personal information
4. Third parties that perform compliance or other professional services for us or manage our information systems, software, platforms or applications that process information for us
5. Government agencies, regulators or other parties as required or authorised by law, for an enforcement related activity, when it is reasonably necessary for a claim or a confidential alternative dispute resolution process or otherwise as permitted or required by law

For participants of our networking, education or other public events

1. Vincents (other than the Vincents entity that collected your personal information) to perform marketing or other professional services or hold information for the Vincents entity that collected your personal information
2. Third parties that perform services for us to manage our events and marketing activities or manage our information systems, software, platforms or applications that process information for us

For visitors to our websites

1. Vincents (other than the Vincents entity that collected your personal information) to perform professional services or hold information for the Vincents entity that collected your personal information
2. Third parties that manage our information systems, software, platforms or applications that process information for us

For job applicants

1. Vincents (other than the Vincents entity that collected your personal information) to perform compliance or other professional services for or on behalf of the Vincents entity that collected your personal information
2. Third parties that perform professional services for us to assess your suitability for the position or manage our information systems, software, platforms or applications that process information for us

Sensitive information

For our individual clients and directors and employees of our corporate clients for the sensitive information noted above

1. Providers of insurance or related products, superannuation fund trustees, fund managers, or their authorised representatives in connection with our services for you or companies of which you are a director or employee
2. Courts and tribunals
3. Legal professionals and other third parties such as investigators, experts and witnesses that assist in the preparation of expert reports, relevant documents or other evidence in connection with our services for you or companies of which you are a director or employee
4. Vincents (other than the Vincents entity with which you are dealing) to perform professional services or hold information for the Vincents’ entity that collected your sensitive information
5. Third parties that assist us in our provision of our services to you or companies of which you are a director or employee, perform professional services for us, or manage our information systems, software, platforms or applications that process information for us
6. Government agencies, regulators or other parties as required or authorised by law, for an enforcement related activity, when it is reasonably necessary for a claim or a confidential alternative dispute resolution process or otherwise as permitted or required by law

For Other Individuals for the sensitive information noted above

1. Courts and tribunals
2. Legal professionals and third parties such as investigators, experts and witnesses that assist in the preparation of expert reports, relevant documents or other evidence in connection with our matters
3. Vincents (other than the Vincents entity that collected your personal information) to perform professional services or hold information for the Vincents entity that collected your sensitive information
4. Third parties that assist us in our provision of our services or manage our information systems, software, platforms or applications that process information for us
5. Government agencies, regulators or other parties as required or authorised by law, for an enforcement related activity, when it is reasonably necessary for a claim or a confidential alternative dispute resolution process or otherwise as permitted or required by law

For participants of our networking, education or other public events

1. Vincents (other than the Vincents entity that collected your personal information) to perform marketing or other professional services or hold information for the Vincents entity that collected your personal information
2. Third parties that perform professional services for us to manage our events and marketing activities or manage our information systems, software, platforms or applications that process information for us

For job applicants for the sensitive information noted above

1. Vincents (other than the Vincents entity that collected your personal information) to perform professional services or hold information for the Vincents entity that collected your sensitive information
2. Third parties that perform professional services for us to assess your suitability for the position or manage our information systems, software, platforms or applications that process information for us

Disclosure to Overseas Recipients

For the purposes noted above, we may disclose your personal information to offshore recipients as follows:

Personal information

Some of our third-party contractors that assist us in our provision of services as specified in the section “Disclosure of Personal Information” above are located overseas in the Philippines and Malaysia and personal information may be disclosed to them for purposes noted above.

Sensitive information

Health information and medical information may be disclosed to our third-party contractors noted above located overseas in the Philippines which assist us in our provision of services as specified in the section “Disclosure of Personal Information”.

How We Secure Your Personal Information

We take reasonable steps in the circumstances to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. However, we cannot guarantee the security of your personal information at all times.

Access to & Correction of Your Personal Information

You have the right to ask for access to and seek correction of your personal information that we hold about you.

You may ask us at any time to provide you with access to personal information we hold about you. Once we verify your identity, subject to any relevant exceptions, we will provide you with that personal information as required under the Privacy Act.

If you believe that we are holding incorrect, out-of-date, incomplete, irrelevant or misleading information about you, you may request us to correct it. Once we verify your identity, subject to any applicable exceptions and if we are satisfied that, having regard to the purpose for which that information is held, that information is incorrect, out-of-date, incomplete, irrelevant or misleading, we will take steps that are reasonable in the circumstances to correct that information in accordance with the Privacy Act.

If you want to request access to your personal information that we hold about you or ask us to correct it, please reach out to us using the details set out in the section “Our Contact Details” below.

Complaints

If you have a complaint about how we manage your personal information or believe we have breached this Policy, a PCN or the Privacy Act, please contact us using the details set out in the section “Our Contact Details” below and provide us with reasonable detail for us to understand and investigate your complaint.

We will investigate your complaint, respond within a reasonable time and attempt to resolve it. If we cannot resolve your complaint to your satisfaction you may complain to the Australian Financial Complaints Authority by following the steps in their website (here) or contact the Office of the Australian Information Commissioner for consideration of your complaint online (here) or by phone at 1300-363-992 (from within Australia) or +61-2-9942-4099 (from outside Australia).

Our Contact Details

In the event that you wish to access or correct personal information that we hold about you or if you have a query or complaint about our privacy practices, you may contact us by the below means:

Privacy Enquiries and Complaints

Vincents

Level 34, Santos Place 32 Turbot Street

Brisbane QLD 4000

(07) 3228 4000

privacy@vincents.com.au

Amendments to this Privacy Policy

This Privacy Policy will be reviewed and updated from time to time. We strongly recommend that you review this policy on a regular basis to ensure that you are aware of any amendments to this Privacy Policy. If any changes are significant or substantial we will let you know of this on our website or by email if you have provided us with your email address.

Your continued use of our services or providing further personal information to us after notice that the Privacy Policy has been revised will be deemed to be your acceptance of (and in the case of sensitive information, consent to) the revised Privacy Policy.