Updated: 17 October 2022
If you are seeking information on how our international business manages personal information, please refer to our website, via www.fidante.com.
1. What personal information is collected?
Fidante collects personal information that is reasonably necessary for us to provide you with financial products and services and to administer them. The kind of personal information we collect and hold will depend upon the type of products and services that you request from us and may include:
- information you give us when you request a product or service from us. This information may include your name, date of birth, address, contact details, suitability for our products and relevant identification documents;
- communications between us and your financial, legal or other adviser, including your broker or other agent;
- communications between us and associations that you are a member of and with which we have an affiliation;
- transactional information about the use of a product if you have or had a product with us;
- financial information about you such as your financial position and information obtained from credit checks if you have authorised us to carry out those checks;
- in some cases sensitive information obtained with your consent or otherwise where required or permitted by law (e.g. in relation to anti-money laundering laws)
- information such as your name, address and date of birth where an investor or borrower has listed you as a beneficial owner or other related party in connection with the investment or loan;
- if you are a financial adviser or other authorised representative of a customer, your name, contact details and any other information you provide when communicating with us in relation to our products and services, or in connection with a mutual customer; and
- information regarding your website interaction with us (i.e. the sections or features of our website that you have visited or used). This information will be anonymous, unless you have registered your details with Fidante. See the “Use of our website” section of this policy for further information.
2. How is personal information collected?
Fidante collects personal information in a number of ways including:
• directly from you (including via your financial, legal, or other adviser including your broker or other agent), such as when you provide the information by phone, email or in an application form, or when you access your account via InvestorServe or AdviserServe (sites supported by our unit registry provider, Boardroom), or when you register for our newsletter or participate in a survey, promotion or competition;
• from other Fidante group companies where permitted by law;
• from third parties such as your financial adviser, lawyer or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorise us to do so;
• from our appointed unit registry services provider; ;
• from an investor or borrower where they have nominated you as a beneficial owner or other related person in connection with the investment or loan;
• from publicaly or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (e.g. anti-money laundering laws)
3. What if you do not provide certain information?
If you provide an incomplete application form (including answering questions to ensure you are likely to be within the target market for the product), we may not be able to provide you with the product or service until the application is complete.
If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with the product or service.
If you choose not to disclose your Tax File Number ('TFN'), TFN exemption or Australian Business Number ('ABN'), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you.
If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process transactions requested.
4. How do we use and disclose your personal information?
Fidante may collect, use and disclose your personal information for the primary purpose of providing the products and/or services requested, as well as for related purposes such as:
- to verify your identity or transactions which you may enter into with us (including the identities of third parties connected with your application for products and services, such as beneficial owners, where applicable);
- to process your applications for our products and services;
- to administer and manage the provision of our products and services;
- to respond to queries, complaints or to provide you with our general customer services;
- to provide your nominated financial adviser or other agent with details of your investment;
- to confirm your membership of an association with which we have an affiliation;
- to assess credit which you seek from Fidante loan programs and to administer any credit a Fidante loan program provides, including providing your nominated mortgage broker with details of your loan;
- to provide you with offers of other Fidante products or services and to improve and personalise our products and services;
- to provide you with offers from organisations with whom we have an alliance;
- to comply with laws and regulatory requirements, including anti-money laundering, financial services and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime;
- to ensure that the target market determinations made for our products are appropriate, and to ensure that distribution of our products is in accordance with the target market determinations that we have made;
- to comply with Fidante's risk management policies and procedures;
- to perform statistical analysis, product and market research, or to seek feedback relating to improving the customer experience;
- to train our staff; or
- if attending our offices in person, to assist Fidante in providing a safe and secure environment for employees and visitors.
We may disclose your personal information to:
- your financial, legal or other adviser, including your broker or other agent;
- professional service firms that provide services to us, such as, legal, audit or data/ information services;
- our appointed unit registry services provider;
- digital service providers, such as Facebook, Google and LinkedIn, to develop a better understanding of our current and prospective customers and advisers;
- electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment/product) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws);
- our related companies and/or the investment manager that may also provide you with a financial product or financial service; or
- Organisations with which we have an association and you are a member; and
- otherwise in accordance with this policy and the APPs.
5. Overseas disclosures
Fidante may, in limited circumstances, disclose personal information we have collected from you in Australia to recipients in foreign countries.
This may occur when Fidante uses ‘lookalike audience services’, provided by LinkedIn, Facebook and Google who may hold data outside Australia. Further detail on how these services work is available below in ‘14. Use of our website’.
Personal information may also be used (or accessed) by third party service providers located overseas to perform administrative functions in relation to your investment (for example, Link Market Services provides registry services for certain listed products from its global hubs in India and in the UK). Fidante has reviewed these arrangements to ensure appropriate security protections are in place to protect the personal information of its investors.
In some cases, Fidante may utilise 'Cloud' storage solutions for data storage purposes, and the relevant servers may be located overseas. Please see 'Storage and security of information' section of this policy for further details.
6. Use of service providers
We may contract out some of our administrative and support functions such as mailing, settlement services, unit registry services, document and data storage, background checking or identity verification to external service providers from time to time. Only information necessary for the service provider to carry out their function will be provided and will be subject to confidentiality clauses in the relevant services agreement.
7. Keeping us up-to-date
Personal information such as contact details may change from time-to-time and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment/product (such as a beneficial owner), and the information is no longer current, you must provide up-to-date information. Changes to some details, such as a change of name, may require additional documentation to verify the change.
Fidante is unable to change any account details over the phone. To change your contact information please log in to the InvestorServe Portal and update your details. You can also request a change in writing.
Please see the 'Contacting us' section of this policy if you would like to request an update to the personal information we hold about you.
8. Storage and security of information
Fidante stores personal information in a combination of computer storage facilities, paper-based files and other records. These are held on our premises and systems as well as offsite using trusted third parties. Some personal information may be held by data service providers located overseas (such as 'Cloud' service providers for data storage and management purposes) and Fidante maintains effective control of the information under contractual arrangements.
We will take reasonable steps to protect personal information from loss, interference or misuse, and unauthorised access, modification or disclosure. Where data is held by a third party administrator (such as our appointed unity registry services provider), we take reasonable steps to ensure that the provider has appropriate security measures in place to protect your information.
Where personal information is no longer required to be retained, we will take such steps as are reasonable in the circumstances to de-identify the information or put it beyond use.
This policy sets out Fidante’s approach to the management of personal information and is made freely available on our website or in hardcopy if requested.
10. Access and correction
Generally, Fidante will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:
- it would be unlawful to provide the information;
- providing access would be likely to prejudice an investigation of possible unlawful activity;
- the information is relevant to legal proceedings and would not be accessible in the normal discovery process;
- giving access would have an unreasonable impact on the privacy of other individuals;
- it would pose a serious and imminent threat to the life or health of any individual; or
- the request is frivolous or vexatious.
If a request for access would divulge a commercially sensitive decision-making process, then Fidante may provide an explanation rather than direct access to the information.
If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Fidante disagree about the accuracy, completeness or currency of our records, then you have the right to request that we note your disagreement on those records.
Please see the 'Contacting us' information below if you would like to request an update or seek access to the personal information we (or our appointed unit registry services provider) hold about you.
Fidante does not use any government-issued identifiers (such as TFNs, Medicare numbers and Drivers Licence numbers) for use as its own identifier for individuals. Instead, Fidante issues numbers such as Unitholder Numbers are used to identify individuals and the Fidante products and services they obtain.
12. Anonymity and pseudonymity
Given legal requirements on financial institutions to identify their customers, in most situations Fidante is unable to allow you to transact with it on the basis of anonymity (including the use of a pseudonym). Access to the Fidante public website, and some other interactions with Fidante may be done anonymously, or in the case of general enquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.
13. Direct marketing
Fidante will not use your personal information for direct marketing purposes unless;
- we have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
- we have provided you with a simple means to 'opt-out' from receiving direct marketing; and
- we have not received such a request from you.
Fidante will not use any sensitive information collected from you for direct marketing purposes. To opt-out of receiving direct marketing, please refer to the ‘Contacting us’ section below for the relevant contact information.
14. Use of our website
We may collect some information from you and about your use of the site when you visit the Fidante website. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. This may be used in order to ‘personalise’ your experience on the site by displaying content that is likely to be most relevant to you. This information may also be used to help us understand whether you may benefit from additional support (e.g. we may contact you to determine whether you need assistance in finalising or progressing incomplete applications). Some of this information will not be personal information because it will not reveal your identity.
We will collect your personal information when you tell us about yourself via the website; for example, by completing an online form such as an application form or by asking for a disclosure document for our products or by sending us an email. When you access your account via InvestorServe or AdviserServe, information only provided by you will be collected to keep your records up-to-date.
Because our login sites have access restricted to users with an account, you will be required to use your secure login. Unique identifiers (such as your login identification) are collected from website visitors to verify the user’s identity.
Unique identifiers may also be used to store information about preferences, to enable dynamic display of the site according to your preferences when you return.
Fidante uses the data collected for statistical analysis and business purposes. We may also use your personal information to contact you via email or phone to tell you about other products or services that we think may be of interest to you, or seek feedback relating to improving the customer experience. If you do not wish to be contacted for these purposes, you can opt-out by contacting us (see the ‘Contacting us’ section of this policy for the relevant contact information). The data is accessible only to authorised staff. Information which is automatically collected may be published internally as aggregated (de-identified) information to assist with improving the services offered by Fidante through the website.
Fidante uses third party web analytics providers to collect information on how people use our website and to help us know what our customers find interesting and useful in our website. Our web analytics providers use "cookies" and in some cases "clear gifs/web beacons" to collect information. For more information on our web analytics providers, please visit Adobe Analytics and Google Analytics sites.
Fidante uses the Facebook Pixel, Microsoft Advertising and the LinkedIn Insight Tag to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. We use both the Facebook Pixel and the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about Facebook and LinkedIn members interacting with our Facebook and LinkedIn adverts. Challenger will only use the Pixel and the Insight Tag to retarget and analyse aggregate data for non-EU residents.
Clear gifs (also known as web beacons) are used in combination with cookies to help us understand how visitors interact with our website. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows us to measure the actions of the visitor opening the page that contains the clear gif.
Fidante may use a lookalike audience service provided by LinkedIn, Facebook and Google. These services allow us to reach people who are similar to our current customers. In simple terms, we provide encrypted information about our customer base to LinkedIn, Facebook and Google (including your name, email address and phone number), which is used to check if you have an existing profile with them. If you do, they will already hold this information about you. LinkedIn, Facebook and Google then use this information to help us understand the types of customers that are more likely to be interested in our products, so that we can develop more effective online marketing strategies. At no stage can they de-crypt the information we provide them about you (i.e. they can’t read it or know it relates to you as an individual). They can only use it to determine whether it matches information they already hold about you (if you have a profile with them). We only receive anonymised data back from LinkedIn, Facebook and Google (consisting of aggregated ‘lookalike audience’ data).
Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising.
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as: www.allaboutcookies.org.
15. Electronic verification
We are required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to verify your identity before we can provide you with financial products and services. When you apply for a product via an online application form, our registry provider will attempt to verify your identity electronically. This may also occur if you have provided copies of identity documents that have not been certified or if we need to perform any additional checks to meet our legal requirements.
How electronic verification works
To verify your identity electronically, certain information will be passed to official State and Commonwealth record holders via our service provider to electronically match your information with information on their databases. These organisations will compare the information to their records and confirm whether all or some of the information you provided matches their records.
What information will be shared and who will it be shared with
If your identity is being verified electronically, the following information will be provided to our service provider:
- Full name
Date of birth
- Residential address
- Government identifiers such as your passport or driver’s licence number.
The service provider will check the relevant identity document details you have provided against the records held by the government authority that issued it (either via the government’s Document Verification Service or directly with the relevant issuer) and to check the document is valid and has not expired.
If you have any questions around our electronic verification process, please contact us (refer to ‘Contacting us’ below).
16. Employment opportunities at Fidante
If you are seeking employment or contracting opportunities with us, we will collect personal information from you and, where applicable, from any referees you have provided to us during the recruitment process. Personal information gathered during the recruitment process will only be used to assess your suitability for the relevant role, and if you are not the preferred candidate, your information may be retained to assess your suitability for roles offered in the future.
We may also collect sensitive information about you as part of our background checking process (with your consent). This information may be disclosed to (and obtained from) third party agencies that we engage to conduct screening checks on our behalf, including overseas agencies where you have prior residential or working history in those locations. For some roles, we may request that candidates complete psychometric testing to assist in candidate selection. This may involve you taking an ability assessment or providing information about your work style and preferences. Testing is undertaken via our service provider’s online system, with results provided to Fidante. Results are also stored by the provider in its Australian data centre and are backed-up in its UK data centre.
If you complete psychometric testing but are not subsequently employed by us, you may contact us at any time to request that your results are de-identified by Challenger and/or our third party provider, and we will take reasonable steps to comply with such requests.
17. Contacting us
If you would like more information about how we manage your personal information (or you would like to opt out from receiving marketing), please contact our Fidante Investor Services team (available Monday to Friday, from 8:15am to 5:30pm EST) on 1300 721 637, or write to us at the following address:
GPO BOX 3993
Sydney NSW 2001
If you have a specific privacy query, you can also contact:
The Privacy Officer
Level 2, 5 Martin Place
Sydney NSW 2000
Or send an email to: email@example.com
18. Complaints about your privacy
If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following;
- Your complaint should be made in writing to the Privacy Officer (via post or email)
- We will attempt to respond within 30 days from receipt of your request
- If you feel your concerns have not been resolved, you may take them to an external dispute resolution service, such as the Australian Financial Complaints Authority (AFCA)
- AFCA provides fair and independent financial services complaint resolution that is free to consumers. There are some time limits for lodging certain complaints, please consult the AFCA website to find out if or when the time limit relevant to your circumstances expires
- The complaint may also be taken to the Office of the Australian Information Commissioner (OAIC)
For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email firstname.lastname@example.org
Fidante may make changes to this policy from time to time for any reason and we will update the website in a timely manner.