Privacy Policy

Financial Framework's Privacy Policy

Financial Framework 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 National Privacy Principles (NPPs) 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 Federal Privacy Commissioner atwww.privacy.gov.au.

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 on our website 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 www.financialframework.com.au, from your website, from media and publications such as social media and Facebook, from other publicly available sources, from cookies and from third party applications such as online chat. 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 or selecting the unsubscribe option in the footer of our emails.

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.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing at admin@financialframework.com.au.

Financial Framework will not charge any fee for your access request.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

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.

Do We Use Cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in quote submissions. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We do not use cookies on our website to identify personally identifiable information. Cookies on the website are completely anonymous and we will not use personably identifiable information unless you have voluntarily provided information via the use of a form on www.financialframework.com.au.

Data may become personally identifiable when cookies are used in association with visitors coming from email marketing campaigns and submitting forms on www.financialframework.com.au. However, this information will not be used for any other purpose than to approve a request of the individual user.


We use cookies to:
• Understand and save user’s preferences for future visits.
• Keep track of advertisements and remarket appropriate offers to visitors of www.financialframework.com.au across the Google network.

• Remarket to visitors via the use of banner ads.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.

• Compile aggregate data about site traffic and site interactions in order to create more relevant offers across lookalike audiences online across Google’s advertising network.

We may also use trusted third party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled. It won’t affect your site experience if you choose to turn of cookies.

To find out more information about how to control the information that cookies can see visithttp://www.google.com/settings/ads.

If you would like to opt out of our third party use of cookies visithttp://www.networkadvertising.org/managing/opt_out...to find out more.

Third Party Disclosure

No, we do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Financial Framework is backed by Synchron - Australia’s largest independent licensed dealer. This means that we hold an Australian Financial Services (AFS) license, and that every member of the Financial Framework team is a licensed Synchron Adviser - receiving the highest level of training and certification available, and held to the strictest code of conduct.

Statement of Synchron’s Privacy Policy

Synchron is committed to ensuring the confidentiality and security of the information provided by you to us. We support and embrace the Australian Privacy Principles set out in the Privacy Amendment (Private Sector) Act 2000 and the protection afforded by this act for the security of private information held on ordinary Australians.

A full copy of our Privacy Policy is available on our website www.synchron.net.au.

We may, on occasion, have administrative & or Paraplanning tasks completed outside Australia. Our offshore provider is Integra Asset Management Australia, their operation is based in India. To contact Integra please email the Managing Director, Mr Mark Fisher at mark@integraassetmanagement.net or in writing at Suite 6, Level 2, 11 Ventor Avenue, West Perth 6005.

We also need to collect copies of your identification to meet our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006. We may also request that you provide us with your Tax File Number, however if you choose not to, there may be tax implications for you.

If you have any complaints about how we handle your private information for advice purposes, please contact one of the Principals of Synchron at the contact points shown below. We take your privacy seriously and will address your concerns through our complaints handling process. If you believe you do not receive a satisfactory resolution to your concerns, you may contact the Office of the Australian Information Commissioner (OAIC). The website of the OAIC is www.oaic.gov.au.

Third Party Links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.https://support.google.com/adwordspolicy/answer/13...
We have not enabled Google AdSense on our site but we may do so in the future.
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy Policy’, and can be easily be found on the page specified above.
Users will be notified of any privacy policy changes:
• On our Privacy Policy page
Users are able to change their personal information:
• By emailing us
How does our site handle do not track signals?
We honour do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third party behavioural tracking?
It’s also important to note that we allow third party behavioural tracking.

The Spam Act 2003

The Spam Act 2003 is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred
To be accordance with CANSPAM we agree to the following:
• NOT use false, or misleading subjects or email addresses
• Identify the message as an advertisement in some reasonable way
• Include the physical address of our business or site headquarters
• Monitor third party email marketing services for compliance, if one is used.
• Honour opt-out/unsubscribe requests quickly
• Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can
• Follow the instructions at the bottom of each email.

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:

Financial Framework

admin@financialframework.com.au

(08) 6144 4000

Synchron's Privacy Policy

Synchronised Business Services Pty Ltd (‘Synchron’) is committed to ensuring the confidentiality of your personal information in accordance with the Privacy Act 1988andthe Australian Privacy Principles (APPs).

1 Why we collect information

We collect information for a number of reasons including:

· To deliver products or services to you;

· To better understand your requirements and preferences;

· To improve our service to you;

· Preparing your financial plan;

· To provide financial advice to you;

· Establish and manage your investments and accounts;

· Implement your investment and insurance instructions;

· Process any contributions, transfers or payments of benefits;

· Monitor and report the investment performance of your account;

· Reviewing your financial plan;

· To provide you with future products and services you may be interested in; and

· To fulfil our regulatory and legislative requirements.

2 How we collect this information

Information is generally collected:

· When we ascertain from you the facts necessary to make a fair and reasonable assessment of their insurance or financial needs and objectives (“Fact Find”);

· When you complete an application form for insurance;

· When you complete an application form for an insurance claim;

· When you complete and application form for investments;

· When you complete an application form for superannuation

· When you complete an application form to increase their level of insurance; or

· When you complete supplementary medical or financial questionnaires.

If you are unable to provide us with their personal information, we may not be able to organise for them to receive a product or service. You can nominate an Authorised Representative to access their personal information. This can be revoked at any time.

Synchron may collect personal information from a third party (such as another Financial Adviser, Product Provider or Medical Practitioner) or a publicly available source but only if you have consented to the collection or it can reasonably be expected that consent has been provided by you.

2.1 Privacy on the internet

Synchron and our Authorised Representatives may use websites to collect personal information from you. Synchron and Authorised Representatives may receive a password and a personal identification number to access details online. This information will be kept confidential and secure at all times.

2.1.1 Cookies

These are text files stored on a person’s computer when they visit a website. Their sole purpose is to identify users and possibly prepare customised web pages or to save site login information. Synchron and our Authorised Representatives may use cookies on our websites.

Cookies can be purged from your browser after every use. This is generally a very simple procedure. Please refer to your browser’s help file for more information.

Although Synchron and our Authorised Representatives strive to ensure your security, no data transmission over the internet can be guaranteed to be completely secure.

2.1.2 Links to third party websites

Synchron and our Authorised Representatives may provide links on our web pages to external industry parties. The content and views expressed on these third party websites are not the responsibility of Synchron or our Authorised Representatives.

2.2 Tax File Numbers

Synchron and our Authorised Representatives may need to collect you tax file number to provide you with a product or a service (for example, managed fund investments and superannuation products). However this information will be kept securely and destroy or we will permanently de-identify TFN information where it is no longer required.

3 What we collect

The personal information generally collected includes:

· Name;

· Address;

· Phone number;

· Email address;

· Age details;

· Occupation;

· Financial details;

· Health Details;

· Transaction information;

· Bank account details;

· Tax File Number;

· Income details from employers;

· Details of dependents;

· Beneficiary details.

Where the information is deemed to be sensitive, for example, the collection of health information, there will be higher level of privacy protection afforded.

4 Disclosure of personal information

There may be cases where Synchron and our Authorised Representatives will need to disclose your personal information to third parties. This is generally to assist us in providing you with a product or service. This may include:

· Doctors, medical services or other organisation to help assist with the collection of information for an insurance application or a claim;

· Any fund (investment administrator or superannuation trustee) to which your benefit is transferred, created or rolled over;

· Your employer where it relates to your employer sponsored superannuation arrangement;

· Your personal representative or any other person who may be entitled to receive your death benefit;

· An external dispute resolution service, insurer or legal representative (where required or applicable);

· The policy owner (where you are the life insurer but not the owner);

· Exchange of information with authorised financial institutions to confirm bank account details for payment;

· Service providers that maintain, review and develop our business systems;

· Regulatory bodies (including the Australian Securities and Investment Commission) as required by law.

If required by law or a regulatory body to do so, Synchron and our Authorised Representatives will comply and provide the appropriate body with the required information.

We do not currently disclose your personal information overseas.

4.1 How we hold personal information

Your hard copy and electronic records are stored in secure buildings and internal information systems.

4.1.1 Protecting personal information

We protect your information by way of staff training, secure storage and system security.

Synchron will take reasonable steps to destroy or de-identify the personal information we hold once it is no longer needed for any purpose for which it may be used or disclosed.

5 Collection of sensitive information

Where you apply for certain life risk products (such as life insurance, income protection insurance, trauma insurance, total and permanent disability insurance) it will be necessary for Synchron and our Authorised Representatives to collect sensitive information about your health. This information will only be collected when you give consent by completing the product’s application form. The information will be sourced by the Life Insurance company from the you, your medical professional and by other medical professionals where medical tests may have been performed. Due to confidentiality, it is sometimes the case whereby Synchron or the Authorised Representative may not be made fully aware of the medical circumstances by the Life Insurance Company.

Unless required by law, we will only collect sensitive information with your consent.

6 Sale of an Authorised Representative’s business

In the event that and our Authorised Representative proposes to sell their business, or if an Authorised Representative is no longer eligible to provide advice, we may disclose some of your personal and sensitive information to potential purchasers for the purpose of conducting due diligence investigations. Any such disclosures will be made in the strictest confidence and conditional that no personal information will be used or disclosed by them. In the event of a sale being effected, Synchron or our Authorised Representatives may transfer your personal information to the purchaser of the business. In this instance, you will be provided a notice by mail to your last known mailing address that such a transfer will be taking place. You will then have the opportunity to object to the transfer within 14 days of the date of the notice.

7 Access to personal information

You are able to access any personal information that is held by Synchron or our Authorised Representatives subject to limited exceptions or required by law. The following factors will be considered:

· The information is related to a commercially sensitive decision making process;

· Access would be unlawful;

· Denying access is required or authorised by or under law;

· Providing access would be likely to prejudice an investigation of possible unlawful activity.

To access the information, you will need to contact the Privacy Officer as detailed in this policy.

You may be charged a small fee applicable to the collection and provision of their personal information but will be notified of this fee prior to processing their request. The Synchron Privacy Officer will be able to advise you how long it will take to provide the information. Generally however, you will receive the requested information within 14 days of the request.

If you believe that the personal information we hold about you is incorrect, you have a right to request your personal information be corrected.

Where we are unable to provide you with the information you have requested or correct your information, we will inform you and explain the reasons why.

7.1 Anonymity and pseudonymity

You may remain anonymous or use a pseudonym when dealing with us. However, it may not be possible for us to assist you with your request if you wish to use a pseudonym or remain anonymous.

8 Privacy Officer

Synchron has nominated a Privacy Officer to handle any queries or issues related to Privacy. This person has been nominated at a senior level and has access to the Board.

Name: Michael Jones

Phone: 03 9328 3900

Email: m.jones@synchron.net.au

Post: PO Box 438

North Melbourne VIC 3051

We take your privacy seriously and any complaints you may have will be addressed through our complaints handling process. All complaints will be given fair consideration and we will aim to resolve them within 45 days. We encourage you to submit your complaint to the Privacy Officer (details above) either via email to post. Where it is found that we are unable to finalise the investigation of your complaint within 45 days, we will contact you to request an extension.

If you believe you did not receive a satisfactory resolution to your concern, you may contact the Office of the Australian Information Commissioner. You are able to do so by:

·Visiting www.oaic.gov.au and submitting an online form;

·Obtaining a hard copy form at www.oaic.gov.au/about-us/contact-us-page;

· Phone: 1300 363 992;

· Fax: 02 9284 9666;

·Email: enquiries@oaic.gov.au

The Office of the Australian Information Commissioner is also available via Social Medial outlets. Please refer to the Contact Us page at www.oaic.gov.au/about-us/contact-us-page.