Privacy Policy

ASENDIUM PTY LTD – PRIVACY POLICY

This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website, the Asendium Software Platform, or through any mobile applications that we may provide (Site). In this Privacy Policy “us, we or our” means Asendium Pty Ltd (ABN 58 633 808 027).

About Asendium

Asendium provides a software-as-a service platform to enable financial planners (Clients) to more efficiently complete financial advice documents such as file notes, fact finds, strategy papers and statements of advice (Financial Advice Documents).

Personal information

The types of personal information Asendium may collect about you will vary depending on Asendium’s relationship with you. Asendium may collect personal information from your use of the Website. Asendium may collect additional personal information from you if you or your organisation seeks to become or does in fact become a Client. Asendium will also process personal information collected by a Client from any person who seeks financial advice from that Client. The types of personal information that Asendium may collect includes:

your name;
images of you;
your contact details, including email address, mailing address, street address and/or telephone number;
your age and/or date of birth;
your credit card or payment details (through our third party payment processor);
your preferences and/or opinions;
information you provide to us through customer surveys;
sensitive information of the kind described in the next section;
details of products and services we provide to our Clients and/or that you have enquired about, and our responses to you;
your browser sessions and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing and usage behaviour;
information about your access and use of the Site, including through the use of internet cookies, your communications with the Site, the type of browser you are using, the type of operating system you are using and the domain name of your internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of the Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
any other personal information requested by us and/or provided by you or a third party. We may collect these types of personal information directly from you or from third parties.

Sensitive information

Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

The type of sensitive information we may collect about an individual includes:

financial and health information that is provided to us; and
financial and health preference information that is provided to us.

We may collect sensitive information about a person through the manner in which a Client completes Financial Advice Documents using the Site. We will not otherwise collect sensitive information about you without first obtaining your consent.

Collection and use of personal information

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

to enable you to access and use the Site, associated applications and associated social media platforms;
to generate Financial Documents;
to contact and communicate with you;
for internal record keeping, administrative purposes, invoicing and billing purposes;
for analytics, market research, generating market reports and business development, including to operate and improve the Site, associated applications and associated social media platforms;
to run competitions and/or offer additional benefits to you;
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
to consider your employment application.

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

If you are a Client, 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 by a Client without your 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;
sponsors or promoters of any competitions we run;
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 our Clients;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
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 Google Analytics, Microsoft Dynamics 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 you have consented to the use or disclosure or where our Client who has provided us with your personal information has confirmed to us (including by its use of the Site) that you have provided your consent to the use or disclosure;
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.

Your rights and controlling your personal information

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

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.

Cookies and web beacons

We may use cookies on the Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide the Site with personal information, this information may be linked to the data stored in the cookie.

Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
Analytical or performance cookies. These are cookies that allow us to recognise and count the number of visitors to the Site and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

We may use web beacons on the Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on the Site. We recommend you check the Site regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact our Privacy Officer at: Asendium Pty Ltd (ABN 58 633 808 027).

Email: contactus@asendium.com