Privacy Policy
1. Introduction
At Frame Investments Pty Ltd (“Frame Investments”) your privacy is important to us.This privacy policy explains how we collect, hold, use, disclose and protect personal information.
2. Collection, use and disclosure of personal information
When you invest in a financial product that is offered by Frame Investments, personal information about you is collected and used to establish, administer and manage your investments. Frame Investments uses this personal information to maintain a record of your investment details and to communicate with you.
Frame Investments may disclose your personal information to:
- organisations involved in providing investment services, brokers and third party platform providers- any joint holder of an investment; and
- parties to whom individuals have consented to the disclosure, which may include a licensed financial adviser or dealer group or a service provider.
Frame Investments also uses your personal information to comply with Anti-Money Laundering / Counter Terrorism Financing laws, Australian taxation laws and all other applicable laws; and discloses personal information to various law enforcement agencies, regulatory authorities and governments around the world, including the Australian Taxation Office and the Australian Transaction Reports and Analysis Centre.
Frame Investments may also be required to ask about your tax residency status under taxation information sharing agreements between the Australian and other countries. Specifically, under the Foreign Account Tax Compliance Act (a tax treaty between Australian and the United States), Frame Investments is required to collect additional personal information about US citizens and/or US tax residents who invest in Frame Investments’ financial products.
Personal information may also be used for secondary purposes such as for the provision of promotional and marketing material. Individuals can notify Frame Investments at any time if they do not wish to receive such materials or information. Where Frame Investments collects your personal information for a specific purpose not contemplated in this Privacy Policy, Frame Investments will provide you with a collection notice which explains the primary purpose and any related secondary purposes for which your personal information is being collected.
We do not actively seek to collect sensitive information (for example health information or information about any criminal record), unless it is necessary for our business purposes. If we do have to collect sensitive information, we will only collect, use and disclose it in accordance with privacy laws.
3. Accessing and correcting personal information
If you require access to, or wish to update your personal information, please contact our
Privacy Officer:Attention: Privacy Officer
Frame Investments Pty Ltd
St James Trust Building
Suite 516, Level 5, 185 Elizabeth Street
Sydney, New South Wales, 2000
Ph: +61 2 8668 4877
Fax: +61 2 8323 4214
Email: info@frameinvestments.com.au
If you believe that the personal information we hold is inaccurate, incomplete or out-of-date, you should contact us to correct this information.
We will endeavour to promptly update any personal information that is inaccurate, incomplete or out-of-date. If we do not agree that the personal information is inaccurate, incomplete or out-of-date, we will notify you in writing of our reasons to refuse any corrections. We will also notify you of what you can do if you are not satisfied with our response.
4. Protection of personal information
We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, interference, modification or disclosure.We have physical, electronic and procedural safeguards to protect your information which is held by us. For example, your personal information is stored in secured office premises, in electronic databases requiring logins and passwords for access and/or at one of our secured warehouses. Access to information stored electronically is restricted to staff whose job purpose requires access. We require all staff to maintain the confidentiality of customer information.
We use secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose. Ordinarily, for information about a particular account, we destroy the information seven years from the date you close the account.
5. Complaints
If you have any questions, concerns or complaints about this privacy policy or our practices relating to the handling of personal information please contact our Privacy Officer:Attention: Privacy Officer
Frame Investments Pty Ltd
St James Trust Building
Suite 516, Level 5, 185 Elizabeth Street
Sydney, New South Wales, 2000
Ph: + 61 2 8668 4877
Fax: +61 2 8323 4214
Email: info@frameinvestments.com.au
We will try to answer any questions you may have, correct any error on our part or resolve any complaint that you may have about our information handling practices. If we do not resolve a complaint to your satisfaction, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au).