This policy applies to Integrated Execution Services Pty Ltd (ACN 083 142 438, AFSL# 405897) and Integrated Portfolio Solutions Pty Ltd (ACN 134352828, Corporate Authorised Representative # 000412557) who are together referred to as ‘Integrated’, ‘we’, ‘our’ or ‘us’.

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Integrated is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au

What is Personal Information and why do we collect it?

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers.

This Personal Information is obtained in many ways including correspondence, by telephone and facsimile, by email, via our website www.ipsinstruct.com.au, from media and publications, from other publicly available sources and from third parties. We don’t guarantee website links or the polices of third parties.

We collect your Personal Information for the primary purpose of providing our services to you, providing information to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

Sensitive information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

• • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  • With your consent; or where required or authorised by law.

Third parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances we may be provided with information by third parties. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• • Third parties where you consent to the use or disclosure; and
  • Where required or authorised by law.

Sending your Personal Information overseas

Should you ask us to facilitate an investment for you in a foreign jurisdiction we will need to disclose any personal information required by the particular investment manager and/or any of their agents to progress and complete your instructions. If any such investment managers and/or agents operate under foreign jurisdictions, they may not adhere to the Privacy Act or any other relevant local or international privacy regulations. Integrated makes no assessment of the privacy arrangements of these parties in foreign jurisdictions and will not take any steps to ensure that the stakeholders operating in foreign jurisdictions adhere to the Privacy Act. Subclause 8.1 of the APP’s will not apply to such disclosures in foreign jurisdictions. Integrated takes no responsibility for any usage of your Personal Information that may result from such disclosure to a third party in a foreign jurisdiction and you will not have recourse under the Privacy Act.

The data centres of some of the service providers that we utilise may be located in foreign jurisdictions including India. Where this takes place, Integrated will have in place a contract with the organisation that that governs the use of the data to a level that Integrated deems to be adequate.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
Integrated Portfolio Solutions will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

Policy Updates

This Policy may change from time to time and is available on our website. 

If you have any queries or complaints about our Privacy Policy please contact us at:

support@ipsinstruct.com.au
1300 764 829