In this Privacy Policy, Babo Group, ‘we’, ‘us’ and ‘our’ refers to the partnership carrying on business under the name Babo Group and includes any entity owned or controlled by a Babo Group firm
At Babo Group, we recognise the importance of protecting and maintaining your personal information. We appreciate that you may have concerns about your privacy and about the security, accuracy and confidentiality of personal information. Babo Group is committed to providing you with the highest quality professional service whilst also protecting your privacy. Babo Group abides by the Australian Privacy Principles established under the Privacy Amendment (Enhancing Privacy Protection) Act 2012 and the Privacy Act 1988.
Open and transparent management of personal information
Babo Group manages personal information in an open and transparent way by complying with the Australian Privacy Principles. We will remain open with you about what sort of personal information we hold, how we collect it, and for what purposes we use and disclose this information
The Babo Group’ Privacy Policy is available on our website or may be obtained by contacting the Privacy Officer. If you have any queries or complaints about Babo Group’ compliance with the Australian Privacy Principles, please contact the Privacy Officer using the ‘How to Contact Us’ information shown below.
If you believe that Babo Group has breached the Australian Privacy Principles, please contact the Privacy Officer in writing. We will respond to you within 30 days. If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner.
Anonymity and pseudonymity
When engaging with Babo Group, you have the option of not identifying yourself or you may use a fictitious name. At times this may not be practicable because we need personal information to provide services to you and if you do not provide the information requested, we may be limited in our dealings with you. If it is important to you, and your identification is not required by us, you may request that we deal with you anonymously or by using a pseudonym.
Collection of solicited personal information
Our ability to provide you with a comprehensive service is dependent on us obtaining certain personal information. This might include:
- name and contact details
- date of birth and gender
- bank account details
- employment details and employment history
- details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, investments, insurance cover and superannuation
- documentation used for identification and verification purposes
Some personal information is considered to be ‘sensitive information’. It may be necessary in some instances for Babo Group to collect sensitive information about you, for example, your Tax File Number, professional memberships and health information.
Babo Group will collect information that is reasonably necessary for the primary purpose of providing a professional service to you and also for complying with our legal obligations. If this information is considered sensitive, then unless the law provides otherwise, Babo Group will also require your consent to the collection of this sensitive information. We will only collect sensitive information if it is necessary to provide our services to you.
Babo Group will collect personal information in a fair and lawful manner. In most instances, we will collect personal information from you unless it is unreasonable and impracticable to do so.
Dealing with unsolicited personal information
If Babo Group receives unsolicited personal information that we know could have been collected from you, we will afford it the same privacy protection as if we had solicited this personal information. If the information is not reasonably necessary for one or more of Babo Group’ functions or activities or we know that we could not normally have collected the personal information, we will destroy or de-identify the information as soon as practicable, unless it is unlawful or unreasonable to do so.
Notification of the collection of personal information
Babo Group will endeavour to collect personal information directly from you, however, at times Babo Group may need to collect personal information from a third party and when this occurs we will inform you. We will also be clear about the purpose of the collection, who we might disclose this information to, whether the personal information is required under an Australian law or a court/tribunal order and the main consequences of not collecting this information.
We will also inform you if Babo Group is likely to disclose the personal information to overseas recipients, including the countries in which the recipients are located.
Use or disclosure of personal information
Babo Group will not use or disclose personal information collected by us for any purpose other than the primary purpose for which it is collected, unless you would reasonably expect us to use or disclose the information for a secondary purpose or your consent has been obtained to use the information for additional purposes. Exceptions to this include where disclosure is:
- required by superannuation fund trustees, insurance providers, and product issuers for the purpose of giving effect to your financial plan and recommendations made by us
- required by law or for inspection to ensure compliance with mandatory professional standards
- reasonably necessary to assist a law enforcement agency
- external service providers for the purposes of audit, peer reviews, legal advice, consultancy, outsourced administration, issuing statements or handling mail
- required by reporting entities for the purpose of complying with the Anti-Money Laundering and Counter-terrorism Financing legislation
- permitted under the Australian Privacy Principles
Where Babo Group has collected the information from you, we may use this information for the purpose of direct marketing.
Direct marketing
Babo Group may use or disclose the personal information we hold about you for the purpose of direct marketing, such as articles that may be of interest to you, if there is a reasonable expectation that your personal information will be used for this purpose and you have not
opted out of receiving direct marketing communications from us, or where you have provided your consent.
Babo Group will not directly market to you using information that is considered sensitive unless you have provided consent.
Cross-border disclosure of personal information
Babo Group may transfer or store your personal information outside Australia. If we engage with, or are required to send personal information to an overseas entity to fulfil the purpose for which the personal information was collected (or a related or ancillary purpose), we may seek your consent with regards to the disclosure.
If we do disclose personal information to an overseas recipient without your consent, we are required to take reasonable steps to ensure that this recipient does not breach the Australian Privacy Principles or a similar applicable law in relation to that information.
Adoption, use or disclosure of government related identifiers
Babo Group will not adopt, use or disclose government agency identifiers, for example, tax file numbers, as our primary means of identifying you unless it is required or authorised by or under an Australian law or a court/tribunal order.
Quality of personal information
Our goal is to ensure that, at all times, the personal information we collect, hold, use or disclose is up to date, accurate and complete. We will take reasonable steps to correct personal information. If you become aware, or believe, that any personal information we hold is inaccurate, incomplete or out of date, please contact your relationship manager or the Privacy Officer at the details provided below.
Security of personal information
Babo Group takes the security of your personal information very seriously. We have implemented significant measures and precautions to protect the personal information we hold (electronic and physical) from such risks as misuse, interference and loss, and from unauthorised access, modification or disclosure. We take reasonable steps to destroy or permanently de-identify any personal information no longer required.
Access to personal information
Individuals may at any time request access to personal information that Babo Group holds about them. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information held. If Babo Group were to refuse to give access to the personal information, or in the manner requested, we will provide written notice of the reasons (unless unreasonable to do so) and details should you wish to complain about the refusal. Generally a refusal will only be in cases where denying such access is permitted under the Australian Privacy Principles or is otherwise lawful.
All requests for access to personal information should be in writing to the Privacy
Officer. We will respond to your request within a reasonable period (but not more than 30 days) after the request is made. Babo Group may charge a fee for supplying personal information.
Correction of personal information
If Babo Group holds information about you for a purpose and knows that the information is inaccurate, out of date, incomplete, irrelevant or misleading we will take steps to correct the information. If you request us to correct the information we will take reasonable steps to do so. If a third party is relying on this information, at your request we will also notify them, unless it is impracticable or unlawful to do so.
If we refuse to make a correction, we will let you know why and the complaint mechanisms that are available to you. If we continue to use this information, you may request us to associate a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.
All requests for correction to personal information should be in writing to the Privacy Officer. We will respond to your request within a reasonable period after the request is made. We will not charge you for making the request for the correction of personal information.
Privacy on our website
When you visit any part of our websites, we collect statistical data about that visit (e.g. what you looked at, the way in which you moved around the site, etc) which is not personally identifiable. We use this information for statistical purposes and to improve our website. We generally only collect personal information from our website when it is provided voluntarily by you.
