Privacy

This Privacy Policy applies to Barbacane Advisors Pty Ltd trading as Walbrook Wealth Management ("Walbrook"), and all our representatives. It sets out how we collect, maintain, use and disclose personal information we collect from you, in accordance with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles.

Walbrook is an authorised credit representative of Australian Credit Licence 389328. Where we engage in credit activities, this Privacy Policy should be read in conjunction with our Privacy Policy - Credit, which can be found at www.walbrook.com.au/privacy-credit.

Our commitment to you

We take your right to privacy seriously, and the secure handling of your information is our top priority. This Policy explains our approach to the management of personal information, including:

How we may collect, maintain, use and disclose your information.
The types of information that we collect and record.
Your privacy rights, along with our rights and obligations.

In seeking financial advice from a representative of Walbrook, you consent to Walbrook collecting, maintaining, using and disclosing your personal information in accordance with this Policy.

Information that we collect and hold

Personal information means information, or an opinion about, an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Before we provide you with financial services, the Corporations Act 2001, Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and financial services regulations require us to obtain certain personal information. The information we may collect includes, but is not limited to, the following:

Information that identifies you, such as your name, address, date of birth, Tax File Number (TFN), Tax Identification Number (TIN), nationality and contact details.
Your financial needs and objectives.
Your assets and liabilities (current and future), income and expenses.
Information regarding your dependents, beneficiaries, insurance claims history, health information and family commitments.
Your occupation, employment history, employment circumstances, family commitments, and social security eligibility.
Your superannuation and insurance details, including transaction history.
Your investment preferences, risk ability, risk tolerance, investment knowledge and investment experience.

All information that we request is for our business purposes, which are summarised in this document and more specifically in forms and disclosure documents, e.g., Financial Services Guides and Statements of Advice. Any form used to collect your information may give further details about the way we use your data.

Sensitive Information

We do not collect sensitive information unless we need it to provide you with the financial services that you have requested. For example, sensitive information includes details of your medical history or criminal record.

If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws.

Identification Numbers

In certain circumstances, we are required to collect government identifiers such as your Tax Identification Number (Tax File Number), Medicare number or pension card number. We do not use or disclose this information other than when required, authorised by law or unless you have voluntarily consented to disclose this information to any third party.

We may also be required to collect information relating to your tax residency. This data is necessary to comply with information sharing agreements that the Australian Government has entered into with other countries. These agreements include the Common Reporting Standard (CRS) and the Foreign Account Tax Compliance Act (FATCA).

How we collect your information

Generally, we only collect personal information about you from you, unless it is unreasonable or impractical for us to do so, or if you consent to a third-party releasing information to us. For example, we may collect information your accountant, a product provider, or your employer for superannuation purposes.

Where we obtain information from you directly, this is generally accomplished in meetings, by phone, by email, forms and when you visit our website or those of our external service providers.

Sometimes we act as an intermediary for others when collecting information about you, such as to assist you to apply for insurance. We will inform you when we do this.

We may collect information from you about another individual. A typical example is where you provide us with details of your nominated beneficiaries. Please ensure you are authorised to disclose that information, make the individual or individuals aware of the disclosure and provide them with this document.

Collection of information via our website

We also collect statistical information about visitors to our website. Examples of the information we collect include browser type, operating system, the number of visitors, pages viewed, types of transactions conducted, time online and documents downloaded. This information is used in an aggregated manner to analyse how people use our website and to improve our website.

We collect some of this statistical information by using cookies. Cookies are small data files that are downloaded from our website and stored on your computer when you visit our site. We use this information only to evaluate our website performance (including identifying potential performance problems) and continually improving our services. None of the statistical data we prepare from information collected using cookies identifies individual visitors to our websites.

Your computer's web browser will allow you to configure your computer to refuse to accept cookies. You can also delete cookies from your computer's hard drive at any time. Doing so should not negatively impact your experience on our website.

We do not collect any further information about you via our website unless you provide the information to a service provider that we have linked to or us. You control the personal information we collect from you through online forms, chat transcripts, emails or newsletter subscription forms. We will use any data we collect only for the requested and other related purposes. We will only disclose this information with your consent or when required or authorised by or under law.

You may be able to access external websites, including those of other service providers, by clicking links on our website. Those other websites are not subject to our privacy standards, policies and procedures. You will need to review those websites directly to ascertain their privacy standards, policies and procedures.

Are you obliged to provide us with your personal information?

Unless required by law, you are not required to provide us with the information that we request, or to allow us to collect data from third parties. However, where you choose not to provide us with the required information, we may not be able to offer you the services that you have requested from us.

If you provide us with inaccurate or incomplete information, it may result in you obtaining products or services that are not suitable for your needs. Incorrect or incomplete information may increase the risk that you will suffer a financial loss.

What happens if we obtain information about you which we have not solicited?

Where we receive unsolicited personal information about you, we will consider if we could have collected the information if we had solicited the information.

Where we determine that we could have collected the personal information from you, we will treat your information as if we have sought the information directly from you.

Where we determine that we could not have collected the personal information, we will destroy the information or ensure that the data is de-identified as soon as practicable.

How we use your information

We use your data for the primary purpose for which we obtained the data. As an Australian Financial Services licensee, we use your personal information to:

Assist us in providing financial services to you
Implement investment or risk management recommendations on your behalf
Ensure we are compliant with our legal and regulatory obligations
Process any complaints
Ensure our business is running compliantly and efficiently, which amongst other practices may include confidential systems maintenance and testing etc

We may also use the information for the secondary purpose of identifying and marketing other products or services that may be suitable for you.

Use of your personal information by a Product Provider or Insurer

If you acquire a financial product, the product provider may use personal information about you for purposes disclosed in their Privacy Policy and Product Disclosure Statement. You can obtain a copy of their Privacy Policy by contacting the product provider directly.

When we disclose your personal information

Generally, we must obtain your consent before we tell anyone about you or your investments. You can give us your consent expressly (by telephone or writing to us), or your conduct may imply it.

Sometimes the law requires or allows us to give out information about you. For example, we may be required to give your information to AUSTRAC or product providers for anti-money laundering purposes. If you are involved in legal proceedings, we may be required under subpoena to provide your information to a court.

We may also disclose your personal information to the entities described below.

Our external service providers, including but not limited to organisations that provide us with financial, advisory, paraplanning, administrative, client relationship management, information technology or other services.
The product issuers of products and services that you have elected to acquire, vary or dispose of using our assistance, and other organisations who support the products and services we offer.
Other parties involved in the management and administration of your financial affairs, including custodians, credit reporting bodies, actuaries, mail houses, product registries, guarantors and claims assessors.
Your professional advisers, including your solicitor or accountant, as authorised by you.
Any party acquiring or considering acquiring, an interest in our business
A complaints body to whom you or we have referred a complaint relating to a product or service
Government and regulatory authorities and other organisations, as required or authorised by law.

With your consent, we may also share your full name, date of birth, residential address and contact details with an identity agent to help us verify your identity against government and non-government electronic data sources.

For insurance products, where required by law, we may disclose personal information about you to the Insurer without getting your consent. These parties are required to comply with the privacy laws in using any such information.

Overseas Disclosure and Storage of Personal Information

We use cloud infrastructure that is physically located in Australia and have carried out suitable due diligence on our cloud service providers.

We may offer you access to a personal wealth portal provided by myprosperity Aust Pty Ltd (‘myprosperity’). Data provided to myprosperity by you, Walbrook and financial institutions linked to your personal wealth portal is stored with Yodlee Inc in the United States of America.

We may transfer personal information to other financial product and service providers in locations outside Australia when using or disclosing it for one of the purposes referred to above. We may need your consent before this occurs. When transferring personal information to foreign jurisdictions, we take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles.

How we store and secure your personal information

We take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We have physical, electronic and procedural safeguards to protect your information held by us. For example, we store your personal information in secured office premises and encrypted electronic databases requiring logins and passwords for access. We require all staff to maintain the confidentiality of your personal information.

We use secure methods to destroy or de-identify any personal information as soon as the law permits, and we no longer need it for any purpose. Legislative and professional requirements generally require that we retain your personal information for seven years after you cease to be a client.

Correction of Information

We will take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete, relevant and up-to-date. Please promptly notify us if there are any changes to your personal information.

If you become aware or believe that any personal information which we hold about you is inaccurate or incomplete, you may contact us to correct the information.

If we disagree as to the accuracy of the information and refuse to correct the personal data, we will give you a written notice to that effect. If we believe that we are unable to comply with your request to access information that you have provided us, we will give you written notice. You may request that we make an appropriate notation to that information noting you consider it is not accurate, complete or up to date.

You have a right to make a complaint if you disagree with our decisions concerning these matters (see 'Complaints' below).

Access to your personal information

You may request access at any time to the personal information we hold about you. You can do this by contacting us with your request, stating the information you require. We will respond to your request within a reasonable period, usually 14 days for a straightforward application. Sometimes we are not required to provide you with access. If we refuse, we will tell you the reason why.

Where we provide you access to such information, we may charge a reasonable fee to cover our costs. We will disclose the amount of such costs to you before providing you with the information.

Your rights if you are in the European Economic Area (EEA)

For data protection laws, we are a data controller in respect of personal data that we collect, process and store in connection with the products and services we offer. Per the General Data Protection Regulation (GDPR), if you are an individual (data subject) in the EEA, you have the right:

to access your data;
to correct or rectify your data;
to delete your data subject to applicable laws and regulations;
to have your data processed only under applicable law;
to have copies of your data to be moved to another data controller;
to object to our processing your data otherwise than per applicable laws and regulations; and
to withdraw any consent to our processing your data at any time.

Please email info@walbrook.com.au to exercise any of those rights.

Complaints

If we have breached the Australian Privacy Principles, this Privacy Policy or not respected your privacy, please lodge a complaint with our Privacy Officer. Please call or write with the reason for your complaint and any actions or remedies you seek. We have included our contact details at the end of this document.

We aim to investigate and respond to your complaint within 30 days. If you are not satisfied with the outcome of your complaint or require further information on privacy, you have the right to contact the Office of the Australian Information Commissioner (www.oaic.gov.au) on 1300 363 992.

If you are in the EEA, you may also contact the relevant Data Protection Regulator, which may vary by jurisdiction. Should you require assistance in determining the applicable regulator, please email info@walbrook.com.au.

Policy updates

We regularly review and update our compliance and quality control framework, including this Privacy Policy, for changes in legislation, regulation and technology. You can find the most recent version of this Privacy Policy on our website. We will notify you of any change that requires your consent before being implemented.

Marketing opt-out

If you do not want to receive information about products and services, then please let us know by email, phone or by writing to us at the address below.

Contact Details

Postal Address	Email	Telephone
GPO Box 1717	info@walbrook.com.au	+61 3 9013 6262
Melbourne VIC 3001

Important Information

Walbrook Wealth Management is a trading name of Barbacane Advisors Pty Ltd (ABN 32 626 694 139, Australian Financial Services Licence No. 512465). Credit Representative Number 534783 authorised under Australian Credit Licence 389328. Liability limited by a scheme approved under Professional Standards Legislation.

Version 1.50 Issued 7 October 2021