- Definitions
In this Privacy Policy
- AFS Licence means the Australian financial services licence granted by ASIC to Strive Financial Pty Ltd under Part 7.6 of the Corporations Act
- ASIC means Australian Securities and Investments Commission
- ATO means Australian Taxation Office
- CEO means the Chief Executive Officer of Strive Financial Pty Ltd
- Privacy Act means Privacy Act 1988 as amended (Cth)
- Privacy Commissioner means the Office of the Australian Information Commissioner
- Strive Financial Pty Ltd means Strive Financial Pty Ltd ACN 160 969 120.
- Third Party means companies or individuals which Strive Financial Pty Ltd has contracts with to provide a service to Strive Financial Pty Ltd or our members
- We/I/Our mean Strive Financial Pty Ltd and its employees
- You mean the customers or members of Strive Financial Pty Ltd.
- Introduction
2.1 Strive Financial Pty Ltd is strongly committed to protecting your privacy when you interact with us, our products and services.
2.2 As part of our business we are committed to providing a number of services to you. To provide these services it is necessary for us to collect, store, use your personal information, and or disclose them to a 3rd Party.
2.3 Strive Financial Pty Ltd will only deal with your personal information in the ways we describe to you in this Policy.
- Objective
The objective of this Policy is to create a transparent framework about how and why we collect and use your information. In some cases, it is possible not to collect any personal information and if you do not want us to collect or use your information then we will give you the opportunity to say so.
- Why We Collect Personal Information
Strive Financial Pty Ltd collects personal information about you:
- because you have provided it to us, for instance if you contact us to make comments, complaints or to ask us questions, or you have interacted with one of our digital services (including online and mobile services);
- because we need it to provide a product or service that you have requested, for instance, if you applied for a Strive Financial Pty Ltd product or service;
- because we would like to improve our services, for instance through the collection and analysis of statistical and research data;
- because you work for us or apply to us for a job or work experience.
We will use the information collected for the purposes that you have provided it. If you cannot provide us with the information we require to provide and maintain the services which you seek we may be unable to provide you with the required financial services. We may need to source information about you from a Third Party; for example a credit reporting agency or an insurer. Wherever possible this will be done with your authorisation or where this is not possible we will inform you when such information is collected.
- Personal information Collected
5.1 We collect most personal information from you directly or from your representative. For example, we may collect personal information when you apply for membership, open an account, deal with us over the telephone, send us a letter, visit our website, or when you contact us in person.
5.2 The type of information we collect may include your name and contact details, tax file numbers, date of birth, income and financial details, employment details, credit record and transaction history.
5.3 We do not collect information that is classified as Sensitive Personal Information as defined by the Privacy Act.
5.4 Information which we collect from you will only be used for the purpose for which it was collected. We do not disclose your sensitive personal information to third parties without your permission or instructions.
- Use and Disclosure
6.1 Personal information is treated as confidential within Strive Financial Pty Ltd and is used by us for the purpose for which it was collected or for a related purpose. Related purposes may include
- our own market analysis and product development
- informing you about new products or services and
- detecting and preventing fraud and other criminal activity
6.2 Wherever our business is outsourced to Third Party contractors, such as mailing houses and Information Technology professional, we undertake to ensure that these Parties are bound by confidentiality and non-disclosure agreements. Information provided to these Parties remains the property of Strive Financial Pty Ltd and is only used for the specific purpose for which it is supplied and on completion it is returned to us. Wherever possible, Strive Financial Pty Ltd will elect to deal with agents who are bound by the provisions of the Privacy Act. Where this is not possible we will make every effort to verify that they otherwise comply with the National Privacy Principles as provided by the Officer of the Privacy Commissioner.
- Confidentiality
7.1 We have a duty to keep confidential all personal information we hold about you including:
- your name, address and financial information
- the balance in your account; and
- transactions on your account
7.2 We will not disclose your personal information unless the disclosure is
- Required by law (eg. The Australian Taxation Office has the power to order us to disclose information on your accounts)
- Authorised by law (e.g. to protect our interest or where we have a duty to the public to disclose or where it is necessary in proceedings before a court or tribunal) or
- With your consent.
- Disclosure to Third Parties
Except where required by law, we only disclose personal information to Third Parties with your express or implied consent. We do not disclose names and addresses to third parties for their own use and in particular we do not disclose names and address to third parties for their direct marketing.
- Your Consent
Your consent to us may be express or implied. We obtain your express consent by you writing to notify us of your consent or by signing to acknowledge a statement of consent. Your implied consent includes your consent, by taking up membership, to allow us to disclose your identifying information to our service providers to enable us to operate and provide services and products to you. Confidentiality of the information will at all times be maintained. Without such consent we may not be able to maintain your membership and accounts with Strive Financial Pty Ltd.
- Direct Marketing and your Privacy
From time to time we will use the personal information we collect from you to inform you of products and services that we consider may be of interest to you. If you do not wish to receive direct marketing information, you can tell us at any time by contacting us on 1300 478 748.
- Incorrect information
If you believe that the information Strive Financial Pty Ltd holds about you is incorrect, or you want to update the information, please contact Strive Financial Pty Ltd on 1300 478 748 and we will make all reasonable efforts to correct the information. We rely on the accuracy of the information you provide to us.
- Document Verification Service (DVS)
12.1 How we Use your Information
Strive Financial Pty Ltd uses the Document Verification Service (DVS) to verify the identity of our customers. When using the DVS, we may collect personal information such as name, date of birth, and address (see 12.2 for more details). This information is used to verify your identity, and comply with our regulatory obligations, by matching a document presented as proof of identity against those held by the originating agency.
Strive Financial Pty Ltd may use or disclose an Australian Government Related Identifier where:-
12.1.1 It is reasonably necessary for us to verify the identity of the individual for the purposes of our activities or functions; or
12.1.2 The use or disclosure of the identifier is reasonably necessary for you to fulfil our obligations to an Agency or an Australian State or Territory Authority; or
12.1.3 The use or disclosure of the identifier is required or authorised by or under an Australian law or a court/tribunal order.
12.2 How your information is collected
Strive Financial Pty Ltd may collect your personal information, in accordance with the Privacy Act. This includes any of the following types of information:
- biographic information, such as name, address, date of birth, and gender;
- visa and citizenship information, including visa or citizenship status and country of citizenship;
- driver licence information, including licence number and licence type (e.g. motor vehicle);
- passport information, including nationality, passport number and expiry date;
- birth information, such as a birth certificate number;
- Medicare information, such as a Medicare card number; and
- facial images.
12.3 If You Decline to Consent
If you do not give your consent for Strive Financial to verify your identity using the DVS, we may use a different method to verify your identity which might be slower or less secure. Strive Financial Pty Ltd may not be able to offer you its services if your identify cannot be verified using the DVS.
12.4 Complaints regarding the DVS
If you believe the Strive Financial Pty Ltd has wrongly collected or handled your personal information, you can email the IDMS team directly at DVS.manager@ag.
- Personal Information Security, Storage and Retention
Strive Financial Pty Ltd must keep customer identification records for seven years after we have stopped providing any designated services to the customer. We take all reasonable precautions to protect your personal information from loss, unauthorised access, modification and unauthorised disclosure. Personal information about your accounts and membership is only accessible by you and by those who are authorised to access it. Only authorised employees have access to your personal information and only for approved purposes. Your personal information can only be amended and deleted by authorised means. Records that we hold, containing your personal information may be in hardcopy documents or as electronic data. Hardcopy documents are secured on our premises and at archive sites by locks and security systems. Electronic data stored on our computers is protected by computer and network security products, including firewalls, encryption, virus software, as well as user identities and passwords. Electronic data stored on our intranet is secured by encryption at rest as well as row level security. The system also employs role base access control known as RBAC. All data is stored in highly secured enterprise grade data centres in Australia. Our website uses technology to ensure maximum security. However, no data transmission over the Internet can be guaranteed to be totally secure.
- Access to your personal information
You may request access to the Personal information that you have provided to, and retained by, Strive Financial Pty Ltd. We will provide you with such access wherever possible and within reasonable time. We may apply a fee for such access, to cover our costs. If we deny your request for access, we will provide you with reasons for that denial. We would ask that any such request is stated as clearly as possible and adequately identifies the information you are seeking and where it is located.
- Staff Training
Strive Financial Pty Ltd will properly train and update all members of staff in Privacy Procedures at least annually.
- Privacy Officer
Strive Financial Pty Ltd will appoint a member of staff as its Privacy Officer to be responsible for the implementation of this Policy and all matters of privacy within Strive Financial Pty Ltd. The Privacy officer is currently the Compliance Officer.
- Changes and Review of Policy
This information relates to our current Privacy Policy. We may vary this Policy from time to time. This Policy will be reviewed at least annually by the Compliance Officer under the approval of the Chief Executive Officer. The Privacy Policy will be available at our Office and by request.
- Resolving Privacy Issues or make a complaint
If you believe that Strive Financial Pty Ltd has failed to observe the privacy of your personal information, you can register your concern or complaint with our Privacy Officer on 1300 478 748. We will respond as soon as possible, usually within 2 working days, to let you know the person in our organisation who will be responsible for investigating the matter. If we are unable to resolve the matter within 10 working days we will contact you to let you know its progress and when we expect the matter to be resolved. If you have any questions and complaints or concern regarding this policy please contact Strive Financial Pty Ltd on 1300 478 748 for assistance.
If you are unsatisfied with our internal dispute process, you may contact the Privacy Commissioner via
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Fax +61 2 9284 9666
Post GPO BOX 5218 Sydney NSW 2001
Questions?
If you have any questions, please email us info@strive.financial