The collection of personal information about individuals by organisations is governed by the Privacy Act 1988 (the Privacy Act) which contains a national scheme for the collection, use, correction, disclosure and transfer of personal information by organisations in the private sector.
The Policy explains our policies and practices with respect to the collection and management of personal information we collect from you.
The Privacy Act requires us to handle your personal information in accordance with a set of principles, known as the Australian Privacy Principles (APPs). Those Principles and our approach to those Principles are set out below.
The Policy applies to BlueKite Capital (Holdings) Pty Ltd and all of its related companies together referred to in this Policy as “BlueKite Capital”, “us”, “our”, or “we”.
What information do we collect?
We will collect and hold your personal information for the purposes of:
Providing Financial Advisory services to you
Providing recommendations in relation to Investment Products
Investment in, managing and administering investment products and services on your behalf;
Managing our business relationships with you and with others, including our Panel Lenders;
Completing a transaction on your behalf (e.g. processing of application forms to arrange a loan or other forms of finance);
Providing you with information about our other products and services;
Our internal administrative, marketing, planning, product development and research requirements.
The type of information collected from you includes information that is necessary to operate your accounts or for us to provide advice to you. We may ask you to provide personal information such as your:
residential and/or postal address
date of birth
bank account details
tax file number (TFN)
Much of this information is collected through application forms, the use of our online facilities or through ongoing communications with you.
We will not collect any personal information about you except where you have knowingly provided that information to us or we believe you have authorised a third party to provide that information to us.
There are also specific circumstances in which we will ask for your sensitive information such as:
personal health information from you when applying for insurance
personal health information from medical practitioners when you are making a claim
income information from employers in instances where you are applying for additional insurance protection or salary continuance insurance
details of your dependents, as defined at section 10 of the Superannuation Industry (Supervision) Act 1993, for the purposes of paying benefits in the event of your death
We will always seek your consent before collecting this kind of sensitive information.
We may also need to collect information from third parties. For example, we may need to collect information from your accountant, product issuer and employer.
We are also required to ask for certain information by law. Wherever there is a legal requirement for us to ask for information about you, we will inform you of the obligation and the consequences of not giving us the requested information. For example, in addition to obtaining personal information from you, whenever you acquire a new product or service from us, we will need to obtain certain documentary evidence from you as to your identity.
Such evidence may include items such as a certified copy of your driver’s licence, passport or birth certificate.
What if you don’t give us the information we request?
You are not required to give us the information that we request. However, if you do not give us the information that we ask for, or the information you give is not complete or accurate, this may:
prevent or limit the quality of advice we provide to you
prevent or delay the processing of an application or any claim
affect your eligibility for specified insurance cover
prevent us from contacting you
impact on the taxation treatment of your account
For example, we are required to ask for your TFN when you invest in a superannuation product. If you choose not to give us your TFN, you may be subject to higher tax charges on your superannuation and the fund may not be able to accept personal contributions.
3. Use of information
How do we use the information that we collect from you?
We use your personal information for the purposes for which it has been obtained. We collect your personal information so that we are able to act on your request. Personal information will also be used where you have consented to such disclosure or where it is required or authorised under law, in circumstances relating to public health and safety or in connection with certain operations by or on behalf of an enforcement body.
From time to time, we will use your contact details to send you direct marketing communications including offers, updates and newsletters that are relevant to the services we provide. We may do so by mail or electronically unless you tell us that you do not wish to receive these communications. We always give you the option of electing not to receive these communications in the future. You can unsubscribe by notifying us and we will no longer send this information to you.
We do not sell, trade or rent client lists or personal information to any third party. We will disclose personal information about you to our lenders and agents where necessary to do so for the ordinary operation of our business.
In all cases we will only disclose that information that is strictly required and take all reasonable steps to ensure that your personal information is handled in accordance with the APPs. These third parties are strictly prohibited from using your personal information for any purpose other than in the pursuit of business related to BlueKite Capital and its related companies.
Who do we give information to?
We may provide your information to external parties. Where personal information is disclosed there are strict controls in place to ensure information is held, used and disclosed in accordance with the APPs.
The types of external organisations to which we often disclose your personal information include:
any organisations involved in providing, managing or administering investment products or services such as actuaries, custodians, external dispute resolution services, insurers, investment managers or mail houses
your employer (relates only to employer sponsored superannuation arrangements)
any fund (administrator or trustee) to which your benefit is to be transferred or rolled over
medical practitioners and other relevant professionals, where you have applied for insurance cover or made a claim for disablement benefit
your personal representative, or any other person who may be entitled to receive your death benefit, or any person contacted to assist us to process that benefit
any financial institution who holds an account for you
any professional advisers appointed by Havana Financial Services Pty Ltd.
businesses that may have referred you to us (for example your lawyer).
Like other financial services companies, there are situations where we may also disclose your personal information where it is:
required by law (such as to the Australian Taxation Office)
authorised by law (such as where we are obliged to disclose information in the public interest or to protect our interests)
necessary in discharging obligations (such as to foreign governments for the purposes of foreign taxation)
required to assist in law enforcement (such as to a police force). We will also disclose your information if you give your consent.
5. Access and correction of information
Can I access my information and what if it is incorrect?
You have the right to access your information and if necessary, for it to be corrected. Upon receipt of your written request and enough information to allow us to identify the information, we will disclose to you the personal information we hold about you. We may incur costs in giving you that information, in which case we reserve the right to charge you for our reasonable expenses incurred in doing so.
You have a right to ask us to correct any information we hold about you if you believe it is inaccurate, incomplete, out of date, irrelevant or is misleading. You can make a request for access to or correction of your personal information by contacting our Privacy Officer. Refer to section 9 for contact details for our Privacy Officer.
In some limited circumstances we may need to refuse access to your information or refuse a request for correction. If this is the case, we will advise you as soon as possible after your request and provide you with our reasons for the refusal.
If you believe that we have mishandled your personal information, in turn, breaching the APPs, you may lodge a complaint with us. The complaint, addressed to the Privacy Officer, must be in writing in accordance with the Privacy Act 1988. Refer to section 9 for contact details for our Privacy Officer.
From receipt of your written complaint, the Privacy Officer has 30 days to respond.
In the event that the Privacy Officer is unable to resolve your complaint, you may lodge a complaint with the Information Commissioner. You can lodge a written complaint with the Information Commissioner by:
Submitting an online form through the Information Commissioner’s website:
fax to 02 9284 9666
7. Protection of the personal and sensitive information that we hold
How do we protect the security of your information?
We have practices and procedures in place to safeguard your privacy. Your personal information is stored on highly secure cloud servers with strict password access. The people who handle your personal information for us have the training, knowledge, skills and commitment to protect it from unauthorised access or misuse. We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or exposure. All BlueKite Capital staff are required by the terms of their employment to maintain the confidentiality of customer information. Access to your information is restricted to those employees whose job requires that information.
Risks of using the internet
You should note that there are inherent security risks in transmitting information through the internet. You should assess these potential risks when deciding whether to use online services. If you do not wish to transmit information via email or through our website, there are other ways in which you can provide this information to us. You can, for example, call us or send us information by post.
All browsers allow you to be notified when you receive a cookie and you may elect to either accept it or not. If you wish not to accept a cookie, this may impact the effectiveness of the website. Your internet service provider or other IT service provider should be able to assist you with setting your preferences.
How long do we retain your personal information?
We are required by law to retain certain records of information for varying lengths of time. Depending on the context surrounding the information, we may be required to retain records which include your personal information from 7 years to permanently. Where your information is not required to be retained under law, we will take reasonable steps to permanently destroy or de-identify your personal information when it is no longer required for the purpose for which it was collected.
9. How do I contact the Privacy Officer?
You can contact us by email at firstname.lastname@example.org or as detailed below:
Suite 107 Level 1
109 Pitt Street
Sydney NSW 2000
p. 1300 883 594