Last updated 19 April 2021
1. Who are we?
This privacy notice is issued by intelliflo Australia Pty Ltd and its related bodies corporate (“we”, “our” or “us”).
We are a technology company that provides business management solutions to financial advisors and institutions through our cloud-based platform and services. You can find more information about our solutions and services on our website.
2. What is the purpose of this privacy notice?
When we provide our services or otherwise interact with individuals, we collect personal information about them. The definition of personal information may vary under applicable laws, but it typically means information that identifies, or which can reasonably identify, a particular individual. This privacy notice explains the kinds of personal information we collect, and how we collect, use, share and protect such personal information. Please read this privacy notice carefully to understand what we do with your personal information. We may change this privacy notice from time to time. Changes to this privacy notice will be effective when we make the updated privacy notice available on our website. The date at the bottom of this page indicates when this privacy notice was last updated. In certain circumstances, we may provide supplemental privacy notices which should be read together with this privacy notice.
By visiting or using our website or services, you accept this privacy notice and agree to our collection, use, disclosure, protection and other processing of your information as described in this privacy notice as it applies from time to time. If you do not agree to this privacy notice, you should not use our website or services.
3. When does this privacy notice not apply?
Information for our customer’s clients
Links to other websites
This website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy notice of such websites to understand how your personal information that is collected on that site is used and protected.
4. Whose personal information do we collect?
This privacy notice applies to the following individuals:
- A user of our services (e.g. an employee of our customers);
- A representative of our former, current or prospective customers, partners, or vendors;
- A visitor to our website;
- A visitor to our premises or facilities;
- Subject to paragraph 3, individual clients of our customers (e.g. individual end investors who are clients of financial advisors we provide services to); and
- Any other individual (outside our organisation) with whom we interact (“you”).
5. What personal information do we collect about you, and how?
We may collect and process your name, information about the company you work for, your job title and role, your business contact details (email, mobile number), information about your business relationship with us, your regulatory registration number (if any), information about your use of our services or websites, online identifiers such as social media details from LinkedIn, and any other information that we ask you to provide or you choose to share with us.
If you are a client of one of our customers, then (subject to paragraph 3) we may also process personal information about you that our customers provide to us for processing when using our services. This information might include for example, your name, age, sex, contact details, financial dependent details, investment and retirement plan information, protection and mortgage details, income and expenditure details, tax details and adviser remuneration, bank account details, or policy numbers. We may also process certain government-issued identifiers about you, such as your passport number, driving license number, any other ID card numbers, or vehicle registration number, for the purposes of verifying your identity, or as required by law.
We may collect and process personal information about you in the following ways:
Information that you give us:
- By filling in forms on our website e.g. when you submit your personal details in our “Get In Touch” form to ask us to send you information about us, our products and services, or to respond to your requests and questions;
- By providing your information when using our services (e.g. via our online community portal); or
- By interacting with us by phone, email, chat or by other means.
Information that our services, systems and websites may collect about you:
- Information that allows us to understand how you do, or did, use our services e.g. from log information or database entries that are, or were, triggered by your engagement with our services;
- If you contact us (e.g. vie email or phone), we may log your correspondence with us; and
- If you visit our facilities or premises, your visit may be recorded by our CCTV systems for security reasons.
Information about you that we may collect from other sources:
- From a colleague of yours, or the organisation you work for or represent;
- From publicly available profiles and registers, as well as public and private databases;
- From our related bodies corporate, or our partners e.g. custodians or other third parties who may integrate their services with our solution;
- From other third parties who run industry events where we have been present, and you have registered to attend;
- We may validate the quality of the data we hold, by leveraging third party services such as email verification tools or tools that allow us to understand what social media systems you may use; and
- In some circumstances, from authorities and governmental agencies.
6. How do we use your personal information?
We may collect and use your personal information to:
- Perform and administer our agreement with you or your organisation, and maintain the relationship or otherwise interact with you for day-to-day business purposes e.g. to provide you with support for the service;
- Provide you with updates and training to help you get the best out of our services;
- Respond to any questions or queries you may have for us;
- Better understand your use of our services and the financial advice sector in Australia to allow us to develop products and services that best serve our customers and the market;
- Send you newsletters or other information about us, our products and services and Australian financial advice sector (subject to applicable laws);
- Log and monitor calls and electronic communications for record keeping, security, quality, staff training and other business purposes;
- Inform you about our or our related bodies corporate’ products and services, conferences, events, publications or anything else that you have requested or we think may be of interest to you or your organisation, and subject to applicable laws, this information may be provided to you by mail, phone, email, text message, social media or in the form of other digital advertisement and where you receive marketing via email or text message from us, we will tell you in that message how to unsubscribe;
- Manage our and our related corporate bodies’ business operations, and for other internal administrative and legitimate business purposes, including to promote, market, distribute and provide our and our related corporate bodies’ products and services to you or your organization;
- Conduct business analysis and market research relevant to our business;
- Test, develop and improve our or our related bodies corporate’ products, services and IT-infrastructure, including our websites or systems;
- Ensure network and information security, and investigate, detect and prevent fraud and other crime;
- Protect our and our related bodies corporate’ interests, including establishing, exercising and defending legal rights and claims; and
- In some circumstances, comply with our legal obligations and requests from authorities.
We may also use your personal information in connection with corporate transactions or restructurings.
Any information collected about you from our website, your use of our services or otherwise, can be associated with other identifying information we have about you e.g. from other sources, and we may derive inferences based on that information.
We may aggregate and/or de-identify information about your use of our website and services for our business purposes e.g. product development and improvement activities, or to create business intelligence reports or statistical information about the use of our services.
7. How do we collect, use, and disclose your information during the recruitment process?
If you apply for a role at intelliflo, we collect and use personal information about you to enable the recruitment process to run smoothly. Depending on the relevant circumstances and subject to applicable laws, we may collect the following personal information about you during the recruitment process (please note that the personal information in italics is only collected in limited circumstances where collection of this information is applicable/appropriate):
- Your personal details (e.g. name; age/date of birth; sex/gender; your signature, including in electronic form; immigration status (eligibility to work in Australia, whether you need a work permit, etc.); nationality/citizenship/place of birth; health and disability-related information);
- Your private contact details (e.g. address, email address and telephone number);
- Your education and employment history (e.g. academic results, employment history and locations of previous employment; details about your current or former role(s) including remuneration, pension and benefits arrangements (subject to any confidentiality requirements));
- Your identification information for the purposes of verifying your identity (e.g. a copy of your driving license and/or passport/identity card; Medicare number and any other tax-related information; biometric information; information we obtain from background verification checks, including information relating to credit checks, criminal convictions and offences);
- Financial-related information (e.g. information we obtain from credit checks, including bankruptcy and court judgments for debt checks);
- Automatically collected personal information (e.g. CCTV footage (in locations where applicable); communications that you send to intelliflo which pass through intelliflo’s systems, including emails and social media messages);
- Other information (e.g. extra information that you or third parties such as your referees choose to provide to us).
If you do not provide us with any personal information we reasonably request from you during the application and recruitment process, then we may not be able to satisfy ourselves that you are suitable for the relevant role. This will mean that we may not be able to progress your application with intelliflo further.
How do we collect this information?
We may collect personal information about you during the recruitment process in the following ways:
(a) Information you give to us:
- When you make a job application to intelliflo via our website or other recruitment portal;
- When you register to receive more information from us at a job fair or other intelliflo careers event; or
- Information you provide to our staff in communications during the recruitment process.
(b) Information about you that we may collect from other sources:
- LinkedIn and other job sites or from third parties such as recruitment agencies, consultants, and members of our staff who refer you to us;
- Our internal recruitment team who receive your information;
- Third party service providers who undertake background checks about you on our behalf;
- Your referees, past employers, educational institutions, and Twitter or similar sites on which you 'follow' us.
How do we use and disclose this information?
We may use the personal information about you that we collect during the recruitment process for the following purposes:
- Ensuring the smooth running of the recruitment process and enabling us to make a decision about your suitability for the role;
- Retaining your personal information to contact you about, and assess your suitability for, future roles (e.g. if you are unsuccessful in your application for a role with intelliflo, we may retain your application in the event that a suitable role at intelliflo becomes available that we think you may be interested in applying for); and
- Making appropriate adjustments for you (e.g. if you suffer from any health conditions or disabilities, we may record details of them so that we can make reasonable adjustments for interviews and other recruitment procedures if required).
We may also disclose your personal information during the recruitment process to:
- Our related bodies corporate, including our overseas offices (e.g. for internal administrative, regulatory compliance and other legitimate business purposes);
- Individuals and organisations who hold information related to your reference or application to work with us, such as current or past employers, educators and examining bodies, immigration agencies, employment and recruitment agencies and criminal convictions checks providers;
- Third parties who hold information related to your financial record such as financial organisations, credit reference agencies and debt collection and tracing agencies;
- Where appropriate, and with your consent, medical professionals such as your GP or an occupational health specialist;
- Third party service providers who perform functions on our behalf or provide services to us (including pension scheme administrators, external consultants, business associates and professional advisers such as lawyers, auditors, accountants, technical support functions, IT consultants carrying out testing and development work on our business technology systems and psychometric testing providers)
8. Who do we share your personal information with?
We may disclose your personal information, for the purposes set out in this privacy notice, to
- A colleague of yours, or other staff within the organisation you work for or represent;
- Our related bodies corporate, our and their vendors, information technology service providers, data analysis and web hosting companies or other third parties who support us or them e.g. in providing services to you, conducting marketing and CRM activities, and in managing business operations;
- Our partners who integrate their services with our platform;
- Our agents, distributors, auditors and consultants; and
- In some circumstances, the police, courts, governmental agencies and authorities, where we are legally obliged to do so or in our reasonable opinion such disclosure is necessary to comply with laws or legal processes, support an investigation or to protect our rights and interests.
We may also disclose your personal data in connection with any proposed purchase, merger or acquisition of any part of our or our related bodies corporate’s business e.g. to a potential buyer and their professional advisers.
The entities with whom we may share information, as described in this privacy notice, may be located in countries other than Australia. The countries in which these third parties are located will depend on the circumstances. However, in the course of our ordinary business operations or providing our services to customers we may allow access to personal information to third parties that may be located in the United Kingdom, Ireland, elsewhere in Europe, the United States and India. These entities may be subject to laws that differ from the laws which apply in Australia.
When we disclose your personal information overseas, we take steps to ensure that such entities are obliged to protect the privacy and security of your personal information in accordance with the standards that apply in Australia (or substantially equivalent standards), including that they only use the personal information for the purpose for which it is disclosed.
10. How do we protect your personal information?
We have implemented commercially reasonable technical and organisational security measures to seek to protect your information transmitted through, or stored in, our website or services, from unauthorised access, or use. Your personal information resides behind a firewall, which is designed to restrict access to authorised personnel. However, no data transmission over the Internet can be guaranteed to be totally secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of the information you transmit to us or from our website or services.
If you are a user of our services, you are responsible for maintaining the secrecy of your user credentials. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us.
9. How long do we retain your personal information for?
We will retain your personal information for a time manner that is consistent with the purposes for which we have collected such information. When determining the appropriate retention period, we consider the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies and our legitimate business interests. At the end of the retention period, and subject to any record keeping obligations we may have at law, we will destroy or de-identify your personal information.
10. What are your rights in relation to the personal data we hold about you?
You have a right to request access to, or to update or correct, your personal information held by us by contacting us (see “How can you contact us?” section below). We reserve the right to:
- Request information from you to verify your identity before we respond to a request access, update, or correct your personal information; and
- Charge a reasonable fee for the costs of retrieval and supply of any requested information.
If you are a client of our customer (e.g. your financial advisor) then we may cooperate with your financial advisor to respond to your request to access to, or to update or correct, your personal information.
If you have any questions or concerns about our collection, use or disclosure of your personal information, please contact us (see “How can you contact us?” section below) and provide us with as much detail as possible about your question or complaint. We will take any privacy question or complaint seriously and will aim to resolve it in a timely and efficient manner. If you are not satisfied with the outcome of our assessment of your complaint, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia) using the details below:
Office of the Australian Information Commissioner
Telephone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001
Online enquiry form
11. How can you contact us?
You may contact us if you have any questions about this privacy notice: firstname.lastname@example.org