ShineWing Australia collects and holds personal information from clients, customers, employees, contractors and other individuals necessary for business purposes. The main type of information ShineWing Australia generally collects and holds about you could include:
ID information such as your name, postal or email address, telephone numbers, and date of birth;
other contact details such as social media handles;
health information where permitted;
your location or activity including IP address;
credit information such as details relating to credit history, credit capacity, and eligibility for credit (‘credit worthiness’);
investment details; and
payroll details, taxation details (including tax file number), job titles and other accounting and financial services related information.
ShineWing Australia collects most information directly from you when we deal with you. The personal information ShineWing Australia collects may be provided in forms filled out by you, face to face meetings, email messages, telephone conversations or by third parties.
Cookies are small files that are placed on your device by websites which collect information about your use of those websites. Different types of cookies are used for different purposes. There are cookies that are active for a single session which, for example, help to facilitate the completion of application forms or surveys. On the other hand, persistent cookies are stored on your device and help websites remember your information and settings when you visit them in the future.
• Determining if your browser has previously visited the website; and
• remembering your settings/preferences and tracking and reporting on website usage.
We may also collect information about you that is:
Publically available (for example in public registers or on social media);
From your representatives (including your financial or legal advisor, accountant, mortgage broker, executor, administrator, guardian, trustee, or attorney); and
The Privacy Act protects your sensitive Information – such as information about your religion, ethnicity, or health. Unless required by law, we will only collect sensitive information with your consent.
We also collect information about you when you use our services or deal with us in some way.
ShineWing Australia collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities. If you choose not to provide us with personal information, ShineWing Australia may be unable to do such things.
ShineWing Australia may collect, hold and use personal information about individuals to market its services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from ShineWing Australia by writing to the Privacy Officer. Please allow for 28 days for your request to be processed. Alternatively, if ShineWing Australia contacts you by email, you may use the unsubscribe function in that email to notify ShineWing Australia that you do not want to receive further marketing information by email.
ShineWing Australia will only use your information for the purpose for which you provided it to us, related purposes and as permitted by law.
Staff of ShineWing Australia will have access to their personal records, for use in the provision of services to them.
ShineWing Australia discloses your personal information for the purpose for which ShineWing Australia collects it. That is, generally, ShineWing Australia will only disclose your personal information for the purpose carrying out our business functions and activities. This may include disclosing your personal information to third parties engaged to perform administrative or other business management services. This disclosure is always on a confidential basis or otherwise in accordance with law. ShineWing Australia may also disclose your personal information with your consent or if disclosure is required or authorised by law.
ShineWing Australia may also need to disclose your personal information to one or more of the third party organisations which may include (but is not limited to):
A client’s personal financial advisor and their service provider;
Individuals or organisations that are your representatives including a client’s legal advisors;
Authorised representatives of the ShineWing Australia who sell products or services on our behalf;
Insurance, investment, superannuation and managed funds organisations, and their advisers and service provider;
Fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
Government or regulatory bodies (including the Australian Securities and Investment Commission, AUSTRAC and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
Off-site third-party organisations providing storage and archiving services; and
Other third parties (including Joint Venture partners) as required by us in performing the functions and activities of the service.
Our business is affiliated with other businesses located overseas. In the course of doing business with you, we may disclose some of your personal information to overseas recipients. However, we will only do so where:
It is necessary to complete the transaction you have entered into; and
You have provided consent; or
We believe on reasonable grounds that the overseas recipient is required to deal with your personal information complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme; or
It is otherwise permitted by law.
At present, some of our network entities may exchange data with our overseas affiliate located in India. However, any such exchange does not change any of our commitments to safeguarding your privacy and the data remains subject to existing confidentiality obligations.
We may store your information in cloud or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Our staff are trained in how to keep your information safe and secure. We use secure systems and buildings to hold your information.
We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
Here are some of things we do to protect your information:
Confidentiality requirements and privacy training of our employees; and
Only giving access to personal information to a person who is verified to be able to receive that information.
Secure handling of Information
When we send information overseas or use third parties that handle or store data, we put arrangements in place to protect your data; and
Mandatory confidentiality guidelines for all staff and data processors within the business.
We use a mix of alarms, camera’s and other controls in our buildings to prevent unauthorised access.
Destroy or de-identifying data when no longer required
We aim to keep your information as long as it’s needed. When we no longer need information, we take reasonable steps to destroy or de-identify it.
Security procedures within our offices;
IT systems designed to ensure personal information is only available to those staff who require access; and
IT security procedures including password protection, firewalls, intrusion detection and site monitoring.
Ensuring third parties and Joint Venture partners meet ShineWing Australia’s privacy obligations.
ShineWing Australia will endeavour to take all reasonable steps to keep secure any information which it holds about you, whether electronically or in hard-copy, and to keep this information accurate and up to date.
ShineWing Australia will always give you access to your personal information unless there are certain legal reasons why we can’t. Where restrictions exist on our ability to provide you with access we will advise you of those reasons at the time of your request.
Should you wish to view the personal information held on you, you should contact the member of staff responsible for their file or the Privacy Officer of ShineWing Australia, and request a “Personal Information Access Form”. We may require you to provide some form of identification (such as a driver’s licence or passport) so the necessary verification can occur.
While we do not charge a client for making a request to access their personal information we may charge you a small fee to cover our costs when giving you access:
Staff costs: if an extended amount of time is required in searching for, locating, retrieving, collating and preparing the material; and
Costs associated with using an intermediary.
Any charges for accessing the information will be advised prior to commencement (estimated time and cost).
If you think there is something wrong with the information we hold about you please contact your ShineWing Australia Representative (phone, email, mail or fax) or the Privacy Officer (refer Contact Us).
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can - if we can’t, then we’ll let you know in writing.
If you wish to have your personal information deleted, please contact the Privacy Officer and we will take reasonable steps to delete it (unless we needs to keep it for legal, auditing or internal risk management reasons).
In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request and you have the right to complain about the refusal in the manner set out in the next section.
If you want to make a complaint about our handling of personal information we ask that you contact ShineWing Australia first. We will then follow our Internal Dispute Resolution process and we will endeavour to respond within a reasonable period after the request is made (not exceed 30 calendar days). If the matter proves to be more complex we will advise you of a revised response timeframe in writing.
Any complaint regarding a possible breach of privacy by ShineWing Australia should be directed to ShineWing Australia in writing; mail or e-mail to the Privacy Officer at the following address:
Level 10, 530 Collins Street
Melbourne VIC 3000
E [email protected]
If your complaint is not handled satisfactorily, you may refer your complaint to the:
The Australian Complaints Authority (AFCA) provides fair and independent financial services complaint resolution that is free to consumers.
ACFA can be contacted at:
The amended policy will apply between us whether or not we have given you specific notice of any change.
This policy was last updated 1 November 2018.