This privacy policy applies to IWL Limited and its subsidiaries (other than its broking subsidiaries,
Australian Investment Exchange Limited, JDV Limited and Avcol Stockbroking Limited,
and each of their subsidiaries, which have separate policies).
Your privacy is important to us.
It is our policy to respect the confidentiality of information and the privacy of individuals.
We are bound by the Privacy Act and the National Privacy Principles contained in the Privacy Act.
In your dealings with us, we may collect personal information about you.
Personal information is information or opinion about an individual whose identity is apparent,
or can reasonably be determined, from the information or opinion.
COLLECTION OF PERSONAL INFORMATION
Why do we collect Personal Information?
Personal information is collected so that we may:
provide information about a product or service;
consider your request for a product or service;
provide a product or service;
make arrangements with other organisations (such as mailing houses) in relation to the promotion and provision of a product or service;
administer our customer relationships (including risk management, systems development and testing, staff training and market or customer satisfaction research;
tell you about other products and services offered by or through IWL companies that may be of interest to you
prevent or investigate any fraud or crime; and
comply with relevant laws, regulations and the requirements of the Australian Stock Exchange, the Australian Clearing House or other relevant body.
When and what Personal Information is collected?
The types of personal information that we collect will depend on the nature of your dealings with us.
Generally collection of your personal information will be obtained over the telephone,
over the internet when you register for a product or service or when you complete an application form
or through business dealings.
From time to time, additional and/or updated personal information may be collected from you.
We may collect personal information about you when you open an account with us,
when you become a member or subscriber to a service with us or through business dealings with you.
The type of personal information collected and maintained by us generally includes name,
address, age group, contact details (including phone, fax and e-mail),
the name of your bank and your bank account number and your tax file number (if you choose to provide it to us).
For training and compliance purposes we may record and monitor telephone calls.
We may collect personal information about officers and staff of our corporate customers as well as
contact people in regulatory bodies, external service providers and the investment industry.
If you are a "business contact" of ours, we may collect business contact information about you including your name,
your position and the organisation you work for, your business telephone and fax number and your email address.
We also maintain information about our shareholders to meet our legal obligations and to keep
them informed of our IWL's business activities (including our products and services).
What happens if you do not provide personal information to us?
If we do not collect this information from you, we will not be able to provide you with our products and services.
Disclosing to third parties
We may need to disclose your personal information to:
issuers of financial products marketed by an IWL company;
any service provider to which we outsource certain activities (for example, a mailing house);
any third party or organisation that introduces you to us or other financial institutions linked with your dealings with us (eg Margin lenders);
an organisation that is in an arrangement or alliance with us for the purpose of promoting or using their respective products and services (and any agents used by that organisation in administering such an arrangement or alliance);
any person acting on your behalf, including your financial adviser, solicitor, accountant, executor, administrator, trustee, guardian or attorney;
regulatory bodies, government agencies, law enforcement bodies and courts;
Share registries and the Stockbrokers Mutual Reference Society; and
credit reporting or debt collecting agencies.
In all cases where personal information is disclosed to persons or organisations outside the IWL group of companies, there are confidentiality arrangements in place to protect the privacy of the information and they may only use the information for our purposes.
Sharing of personal information within IWL
The Privacy Act allows your personal information to be shared with other IWL companies. This enables us to service our relationship with you and to operate as a group. Without your consent, other IWL companies may not use or disclose your personal information for purposes other than for which your information was originally collected.
Marketing our Products and Services
It is our practice to use your personal information to let you know about developments and products provided by or through IWL companies that may better serve your financial and investment needs or promotions or other opportunities in which you may be interested.
If you do not want to receive information on products and services offered by or through the IWL company to which you provided your information, you can contact the IWL company at any time to indicate that you wish to 'opt out' of receiving such information.
Please note that if you provide your information to more than one IWL company, you will need to tell each IWL company separately if you wish to 'opt out' of receiving marketing information from them.
INFORMATION SECURITY, QUALITY AND ACCESS
Security of your personal information
We are committed to keeping your personal information secure the personal information you provide to us. We maintain strict procedures and standards to protect your personal information from misuse and loss and from unauthorised access, modification or disclosure.
Keeping Accurate records
We try to ensure personal information that we hold is accurate and up-to -date.
Accurate information helps us to provide you the best service possible. To assist us with this, please inform us of any changes to your personal records such as change of telephone number or address as soon as possible. If you have web access to your account with us, you may also make changes to your personal information online.
We may need to maintain records for a significant period of time. However, when we consider information is no longer needed for any purpose, we will remove any details that identify you or we will securely destroy the records.
Accessing your Personal information
If you have web access to your account with us, you may be able to access the majority of your personal information online.
You may request us to provide you with access to the personal information we hold about you. Requests for access to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled over the telephone.
We will need to verify your identity before answering a request for access.
If your request is for access to more substantial amounts of personal information, you should make the request to our Privacy Officer (see details below). We will endeavour to respond to any request for access within 14 – 30 days depending on the complexity of the information and/or the request.
In certain circumstances, we are permitted by the Privacy Act to deny your request for access, or limit the access we provide. We will let you know why your request is denied or limited.
There may be charges that apply to giving you access to the information that we are holding.
For joint accounts, we will allow each accountholder access to their own personal information and to the joint information but not to the personal information of the other accountholder.
If you find any errors in the personal information that we are keeping, please inform us so that we can correct these.
ONLINE PRIVACY ISSUES
Online
IWL does not collect personal information about you when you are using an IWL company website except when you specifically provide personal information on a voluntary basis. For example, personal information may be gathered from the registration process for products or services and in connection with content submissions, user forums, training requests, suggestions and support.
We use a technology known as cookies when you visit an IWL company website. A ‘cookie’ is a packet of information that allows our web server to identify and interact more effectively with your computer.
We collect information on website activity using cookies. This information on its own does not identify the individual user. We use this information to analyse user behaviour and characteristics. We may provide aggregated data from the analysis to third parties who advertise on an IWL website (for example, the number of users that clicked on their advertising banner).
We also use cookies for security reasons as part of the customer identification process when you log on to an IWL company website by entering your username and password.
Links to other websites
From time to time we may provide access to external websites through links provided on our website. Be aware that when you access a website other than ours, we are not responsible for the privacy practices of that site. We suggest that you review the privacy policies of each site you visit.
CONTACTING US ABOUT PRIVACY ISSUES
Complaints
If you have a complaint about the way that we have handled the privacy of your personal information, please let us know so that we can fix the problem. In the first instance we suggest that you phone the relevant IWL company that you’ve been dealing with. Often a problem can be fixed quickly, once we learnt about it.
If the matter is not resolved to your satisfaction, please contact our Privacy Officer (see contact details below). The Privacy Officer will then investigate your complaint and will generally try to resolve the complaint within 10 business days.
If you are still not satisfied after our Privacy Officer has investigated the matter, you may lodge a complaint with the Federal Privacy Commissioner.
For more information about how to lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hotline on 1300 363 992.
Contact Us
If you have any questions or would like further information regarding this policy, please contact us by: