Privacy Policy

Who are we?

‘We’, ‘us’ and ‘our’ or TLK refer to TLK Management Services Pty Ltd, its affiliated entities and their licensees authorised to carry on a financial services business and our related body corporates.

Our commitment to protect your privacy

We understand how important it is to protect your personal information. This document sets out our privacy policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act (1988) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (collectively referred to as the Privacy Act) and any other relevant law.

Further information and feedback

The pages that follow set out more detailed information about our privacy and information handling practices. If you have any questions or would like further information on our Privacy Policy or information handling practices, please contact our team via
info@tlkpartners.com.au

Members of our group

TLK Partners includes TLK Management Services Pty Ltd ABN 27 605 517 833 and its affiliated entities as follows:

• TLK Accountants Pty Ltd ABN: 25 263 276 494, member of Chartered Accountants Australia New Zealand
• TLK Wealth Pty Ltd ABN: 15 605 435 532, Corporate Authorised Representative #1007998 of TLK Financial Services Pty Ltd, ABN 50 640 424 433, Australian Financial Services Licence Number 522950 (TLK Wealth’s Privacy Policy can be viewed in the Financial Services Guide by clicking here).
• TLK Mortgage and Finance Brokers Pty Ltd ABN: 25 148 943 579 Authorised Representative #401564 of Connective Credit Services Pty Ltd ABN 51 143 651 496, Australian Credit License Number 389328
• TLK Financial Services Pty Ltd, ABN 50 640 424 433, Australian Financial Services Licence Number 522950. (TLK Financial Services’ Privacy Policy can be viewed in the Financial Services Guide by clicking here).

Personal information

When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.

AML information is information which is used to assess whether your investment in any way breaches the terms and conditions of Anti- Money Laundering and Counter Terrorism Financing Act (2006) currently prevailing in Australia.

The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, tax file number (TFN) and any other information we made need to identify you

Why we collect your personal information

We collect personal information to provide you with the products and services you request as well as information on other products and services offered by or through us. The law also requires us to collect and retain personal information. Personal information may be used and disclosed within the Group to administer our products and services, as well as for risk management purposes and, unless you tell us otherwise, to provide you with related marketing information.
The kinds of personal information we collect and store will depend on what products and services you request from us. However, our ability to provide you with service and advice that meets your particular needs and objectives may entail us collecting information which may include any or all of the following:

(a) Your contact details including names, address, phone and email address;
(b) details of your financial needs and objectives and what hardship means to you;
(c) personal details including your date of birth, associated entities, visa and residency status, private healthcare and smoking status;
(d)  your occupation, marital status, financial dependants and identification details such as copies of birth certificate or drivers licenses or other documentation;
(e) details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, insurance cover, general insurance, superannuation and taxation;
(f) details of your investment preferences, past experience and aversion or tolerance to risk;
(g) details of any professional advisers you engage with;
(h) estate planning details;
(i) information about your employer, your employment history including future, family commitments including dependents and social security eligibility;
(j) your tax file number;
(k) personal and family medical history and /or lifestyle pursuits; and
(l) your agreement to grant access to a spouse or partner’s information.

We will collect, maintain and use personal information both initially and ongoing which is necessary for us to adequately provide the services you have requested including:
(a) preparation and provision of initial financial advice;
(b) preparation and provision of ongoing financial advice;
(c) placement of financial products including purchase, variation or redemption of investments;
(d) provision of a financial service, such as actioning share buy/sell instructions;
(e) provision of a financial service, such as purchase, variation or cancellation of insurance products;
(f) set up and administration of a Self-Managed Super Fund;
(g) providing assistance with ancillary services such as Centrelink;
(h) providing assistance with the coordination of other providers or experts such as solicitors, accountants etc;
(i) providing credit assistance such as assisting to establish, terminate or vary a loan contract; and
(j) providing credit services by sourcing and recommending appropriate loan arrangements.
As well as providing us with information upon which to provide a customised solution to your particular needs and objectives, we are required under the Corporations Act 2001 and the National Consumer Credit Protection Act 2009 to collect and hold this information.

It is possible that additional information may be collected to allow assessment by insurance providers so they may accept your proposal and, if so, determine terms. This information is only collected where necessary and may include details of your sexual activities and/or personal pursuits.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. The types of organisations to which we are likely to disclose information about you include fund managers, bankers, accountants, credit reporting bodies, product issuers, investment managers and lawyers. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your investment, or in our business.

How do we collect your personal information?

Where reasonable and practical we will collect your personal information directly from you. We also collect your personal information from people such as accountants, fund managers, bankers, credit reporting bodies, product issuers, real estate agents and lawyers.

Do we disclose your personal information?

Depending on the product or service you have requested, we may disclose your personal information to:

• your financial planner or authorised representative in relation to your finance/investments;
• other organisations that are involved in managing or administering your finance/investments such as third party suppliers, printing and postal services, call centres;
• associated businesses that may want to market products to you;
• companies that provide information and infrastructure systems to us;
• anybody who represents you, such as your financial planner, lawyers, and accountants;
• anyone, where you have provided us consent;
• where we are required to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth); or
• an organisation providing verification of your identity, including on-line verification of your identity;
• data aggregators who collate and report information between us and our business partners and /or you;
• our authorised representatives when it is commercially prudent to do so;
• financial institutions including stockbrokers, custodians, fund managers and portfolio service providers and other entity that administer your financial products;
• insurers, if you obtain insurance through us; or
• your employer, referees or identity verification services.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

A. the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
B. you have consented to us making the disclosure.

We may use a combination of our internal servers and cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located inside or outside Australia.

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and correction to your personal information

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.

An explanation will be provided to you, if we deny you access to the personal information we hold about you.

If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal or credit information within 30 days.

If we refuse to correct personal information we will provide you with our reasons for not correcting the information.

Using government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about current promotional offers.

Sensitive information

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional association or trade unions, sexual preferences, criminal record, or health.

How safe and secure is your personal information that we hold?

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Our security measures include, but are not limited to:

• educating our authorised representatives and staff as to their obligations with regard to your personal information;
• access to our premises is controlled by only allowing authorised personnel to access those locations where personal information is stored;
• all computer-based information is protected through the use of access passwords on each computer and screen saver passwords;
• client data is backed up each evening and stored securely off site;
• encrypting data sent from your computer to our systems during Internet transactions and customer access codes transmitted across networks;
• employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems;
• using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; and providing secure storage for physical records.

In the event you cease to be a client of this organisation, any personal information which we hold about you will be maintained in our secure storage facility for a period of 7 years in order to comply with legislative requirements. Where information we hold is identified as no longer needed for any purpose we ensure it is effectively and securely destroyed, for example, by shredding in the case of paper records and other means in the case of electronic records and equipment.

Your personal information may be accessed by our Group staff, representatives or agents in other countries, if that becomes necessary to deliver our services to you. This access is via secure internet connection or, in some instances by email;

from time to time, information may be loaded to the cloud for storage or access through programs such as Dropbox etc; and

it is possible that product and services providers we recommend may outsource functions using overseas contractors or companies that process these services using offshore resources. Where this is a concern to you, we suggest that you carefully read their privacy policy to determine the extent to which they send information overseas.

We allow access to relevant personal information for external organisations that help us provide services. These organisations are bound by confidentiality arrangements. From time to time we may use service providers whose staff accesses our data outside of Australia to provide services. Where this is the case, these service providers have committed to adhere to the Australia Privacy Principles. These service providers may be located in a number of countries.

Direct marketing

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with.

If you do not wish to receive marketing information, you may at any time decline to receive such information by writing to us at info@tlkpartners.com.au or PO Box 1419 Parramatta NSW 2124. If the direct marketing is by email you may also use the unsubscribe function.

We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

Website and email

When you visit our website, details may be recorded about your visit, such as time and date, your computer IP address, pages accessed, time spent on page and type of browser. This information is used in an anonymous format for statistical purposes and as such cannot identify you individually. When you log into the client section of our site, we may use cookies to identify who you are, while you are logged in for the session. The cookie is unique to that session, and the data within the cookie is encrypted. You must have cookies enabled to be able to use our site. Our website may contain links to other websites. When visiting these websites be sure to check the privacy policy as we are not responsible for privacy practices of those other parties.

Where you chose to communicate with us by email, we will store your email, name and address with any other contact or personal details you have provided on our database.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act and the Credit Reporting Code, you may contact our complaints officer on(02) 8090 4324 or by writing to us at either:

We will acknowledge your complaint within seven days. We will provide you with a decision on your compliant within 30 days.
If you are dissatisfied with the response of our complaints officer you may make a compliant via the following:

– Mortgage and finance complaints refer to the Credit Guide in the TLK Mortgage and Finance Brokers subsite of this website.
– Accounting complaints refer to Chartered Accountants Australia New Zealand via https://www.charteredaccountantsanz.com/contact-us
– Financial planning complaints refer to the FSG in the financial planning subsite of this website.

to our External Dispute Resolution Scheme, Financial Ombudsman Service Limited which can be contacted on either:

Ph: 1300780808  or
GPO box 3 Melbourne Victoria 3001 or
Privacy Commissioner who can be contacted on either www.oaic.gov.au or
1300 363 992.

Further information

You may request further information about the way we manage your personal information
by contacting us.

Change in our privacy policy

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

As a consequence we may change this privacy policy from time to time or as the need arises. You may request this privacy policy in an alternative form.

This Privacy Policy came into existence on 20 March 2017