1.1 Purpose of this Policy
Segue Financial Services Pty Limited and its wholly owned subsidiaries (being Portfolio Administrative Services Pty Limited and its related bodies) (‘Segue Financial Services’, ‘we’, ‘us’, ‘our’) understands that protection and confidentiality of its clients’ personal information is important.
Segue Financial Services Pty Limited holds an Australian Financial Services Licence (‘AFSL’) No. 255257 is subject to Corporations Act 2001 (Cth) and regulations and ASIC Regulatory Guides.
a) the kinds of personal information that Segue Financial Services collects and holds;
b) how Segue Financial Services collects and holds personal information;
c) the purposes for which Segue Financial Services collects, holds, uses and discloses personal information;
d) how you may access the personal information that Segue Financial Services holds about you and seek correction of that information;
e) how you may complain about a breach of the APPs and how the complaint will be dealt with;
f) whether Segue Financial Services is likely to disclose personal information to overseas recipients and if so and if practicable, the countries in which they are likely to be located.
1.2 Application of this Policy
Subject to legislative requirements, Segue Financial Services only collects personal information relevant to its business relationship with you
This Policy applies to Segue Financial Services and its representatives (directors, employees and authorised representatives).
1.3 Review and amendment of Policy
2. Personal information we collect
“Personal information” is any information that identifies an individual or can be linked to an individual. The type of personal information that Segue Financial Services collects includes – your name, contact
details (such as your address, telephone numbers and email address), date of birth, tax file number, gender, health, bank account and investment details.
Anti-Money Laundering and Counter Terrorism Financing Act 2006 (‘AML-CTF Act’) may also require us to collect additional personal information from you.
We collect personal information to enable us to provide you with our products and services.
3. How we collect personal information
Segue Financial Services primarily collects personal information through its standard forms, in particular Application Forms.
We may obtain information through telephone conversations, correspondence or direct contact. Phone calls to some personnel may be monitored or recorded for training, regulatory or other
compliance reason. We will advise you if this is the case.
In certain cases we may collect personal information from third parties. For example, we may need to collect personal information from a representative (such as a legal adviser) or your accountant.
Segue Financial Services collects statistical information on website activity, such as the number of users who visit, the date and time of visits, the number of pages viewed and how users navigate through the websites and other anonymous information.
We collect this information for the purposes of our own analysis (and in these cases will only do so in aggregate form without identifying individual subscribers).
4. Using and disclosing personal information
The information we collect from you is strictly confidential for use within Segue Financial Services. Segue Financial Services use your personal information to establish and administer the financial products and services Segue Financial Services provides to you and communicate with you on an on- going basis about those financial products and services.
Personnel may use personal information to verify your identity over the telephone.
Unless you choose to opt out, Segue Financial Services may also send you educational or marketing material about new products or services or other opportunities. You may contact us at any time and ask that we not send this material.
Segue Financial Services may need to disclose personal information to external persons or entities:
• Segue Financial Services may be required to provide details to a governmental or regulatory body to fulfil its legal requirements (for example, disclosure to enforcement bodies such as the Australian Securities and Investments Commission (ASIC), the Australian Taxation Office (ATO), the Australian Transaction Reports and Analysis Centre("AUSTRAC").
• Segue Financial Services may be required to disclose certain information pursuant to a court order.
Segue Financial Services uses agents and external service providers, (such as registry providers, printing
companies, external consultants) to assist it with the delivery of the financial products and services Segue Financial Services provides to you.
Segue Financial Services will take steps to ensure that its agents and external service providers keep the personal information confidential and that the information is only used for the purpose Segue Financial Services has authorised. Those parties must undertake to comply with our confidentiality requirements under privacy law.
Where personal information is passed to external parties that perform specific services for Segue Financial Services, for example mailing, Segue Financial Services limit the disclosure to the information needed to perform the service.
• In 2010, the United States enacted a law (the HIRE Act) which included provisions commonly referred to as the “Foreign Account Tax Compliance Act” or FATCA. While the final regulations have not yet come into effect, FATCA will require participating non-US financial institutions to report certain information about financial accounts held directly or indirectly by US persons to the US Internal Revenue Service (IRS). To comply with these requirements, these participating financial institutions will be required to:
• undertake certain identification and due diligence procedures with respect to its existing and new account holders;
• report annually to the IRS on US persons who directly or indirectly own financial accounts; and
• generally withhold and pay 30% of US source income to the IRS, as well as gross proceeds from the sale of property that generates US source interest, or dividends made to US account holders failing to provide certain information. Beginning in 2017, withholding may also be required by participating non-US financial institutions on certain other payments of foreign source income.
• FATCA and potentially any intergovernmental agreement may affect the Responsible Entity and how it uses information you provide to us. Accordingly, when you apply to invest you agree to:
• provide us certain identification and other information that we may need in order for us to comply with our obligations under FATCA including obligations under any agreement with the IRS:
• waive any provision of foreign law that would, absent a waiver, prevent us from complying with our obligations under FATCA including obligations under any agreement with the IRS and acknowledge that, if you fail to provide such a waiver, we may withhold any payments to you;
• acknowledge that if you fail to provide information on a timely basis, you may be subject to a 30% US withholding tax;
• acknowledge that if you fail to comply with such obligations and such failure could result in us being unable to enter into or comply with any agreement with the IRS, we can terminate your investment; and
• acknowledge that you will indemnify us and the other Investors for any losses resulting from your failure to meet your obligations under this provision, including any withholding tax imposed by FATCA as a result of such failure.
Depending upon the products or service you select, Segue Financial Services may exchange information about you with, for example:
• other financial institutions, including stockbrokers, custodians and fund managers,
• insurance companies,
• superannuation funds,
• other organisations or firms, who jointly with us, provide products or services to you.
You may authorise us to disclose personal information we hold to your financial adviser or other person nominated by you. Your express consent is required prior to disclosure being made.
Segue Financial Services will only disclose personal information where we are allowed to by law and have your express or implied consent, or where we are obliged to by law.
Segue Financial Services may rely on some of the exemptions permitted in the Privacy Act, such as the exemption for disclosing information to a related body corporate.
5. Maintenance of accurate records
Segue Financial Services aim to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date.
If Segue Financial Services is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete or irrelevant or misleading we will take reasonable steps to correct it. If you believe your personal information is inaccurate, out-of-date, incomplete or irrelevant or misleading, please contact us or submit a change of details form available from us or from your financial planner. Where available, you may have access to login and directly edit your details in
the profile section. We will respond to your request within a reasonable period and not charge you for making the request.
If we correct personal information about you that was previously disclosed to another APP entity, we will take reasonable steps to notify the other APP entity of the correction where you request that notification.
6. Protecting your information and our website
The security of personal information is a priority for Segue Financial Services and we take reasonable steps to protect it from misuse, interference, loss, modification, unauthorised access or disclosure. We achieve this through the following measures.
Paper documents are protected from unauthorised access or use through the various security systems that are in place at our premises. We also maintain up-to-date computer and network security systems with appropriate firewalls, encryption technology and passwords to protect electronic copies of personal information.
Segue Financial Services will take reasonable steps to destroy or permanently de-identify your personal information if it is no longer needed for any purpose for which the information may be used or disclosed in accordance with the APPs:
a) if it is not contained in a Commonwealth record and
b) if we are not required by or under and Australian law, or a court/tribunal order, to retain the information.
To protect your personal information online, Segue Financial Services does not provide any direct access via our website.
You should be aware that the internet is not a totally secure environment. Segue Financial Services cannot guarantee the security of information you provide to us or we provide to you via the internet.
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need review those websites to ascertain their privacy standards, policies and procedures
7. Access to your personal information
You may request access to the personal information we hold about you. Your right of access is subject to some exceptions. If it is not possible for us to give you access we will endeavour to explain why.
8. Contact us
Any complaint will be handled in accordance with our Complaints Handling and Dispute Resolution
You can contact us by using one of the following methods:
Phone 03 9509 1599
Segue Financial Services
Suite 2, 307 Wattletree Road
Malvern East VIC 3145