Privacy Policy

Purpose

The Company is committed to providing information on its services within a secure and confidential online environment. The Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) govern the way in which the Company must manage personal information. This policy sets out how the Company collects, uses, discloses and otherwise manages personal information.

Applicability

References to the Company mean EC Pohl & Co Pty Ltd (ACN 154 399 916), the holder of Australian Financial Services Licence 421704, its related entities and Directors, employees, contractors, and representatives.

Policy Detail

What Information We Collect

Personal information that identifies an individual and is relevant to providing requested services may be collected and retained. This may include names, contact details such as phone numbers, addresses and email addresses, and financial information related to investments, including tax file numbers and bank account details. Any personal information collected will be used only in accordance with this Privacy Policy.

When an individual accesses or uses the Company's services, the Company may also collect information such as the date and time of the visit, pages viewed and information downloaded.

Purpose of Collection

The Company collects personal information based on its interactions with individuals. Personal information is generally collected, used and stored where necessary for the Company's functions and activities, including providing services or information requested or expected by clients, conducting research, planning, product development, risk assessment, risk modelling and marketing, sharing information about services offered by the Company, related entities or affiliated organisations, facilitating internal business operations and meeting legal requirements. Personal information may also be collected, used or stored for any other purpose required or permitted by law.

Method of Collection

The Company will generally gather information directly through standard forms, the internet, email, telephone conversations or face-to-face meetings. Personal information may be collected indirectly where it is impractical or unreasonable to collect it directly, including from brokers, accountants, financial or legal advisers, or related parties providing services.

The Company will usually notify individuals about the collection of their personal information from third parties in advance, or as soon as reasonably practicable after the information has been collected, if prior notification is not possible.

Failure to Provide Information

If the personal information provided to us is incomplete or inaccurate, we may be unable to provide the services sought.

Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

Sensitive Information

The Company does not generally collect sensitive information about individuals unless it is reasonably necessary for its functions and activities and the individual has consented to the collection, or the collection is otherwise permitted or required by law.

Use and Disclosure of Information

Generally, personal information obtained is used or disclosed only for the purposes for which it was collected. Personal information may be disclosed to service providers who assist in operating the business, including auditors, and to related entities or affiliated organisations so they can provide information about services and promotions. Personal information may also be disclosed to third parties in Australia or overseas where required or permitted by law.

Security of Information

The Company takes reasonable precautions to safeguard the security of any personal data collected. However, the security of information transmitted to or received from its online services cannot be ensured or guaranteed. Transmissions are at the individual's risk. Once received, appropriate security measures are implemented to protect the information on systems from unauthorised access, interference, misuse, loss, modification, or disclosure. These measures include both electronic and physical safeguards. When personal information is no longer required, reasonable steps will be taken to securely destroy or de-identify the information.

From time to time, the website may include links to external websites. The privacy practices and content of these linked websites are beyond the Company's control and are not governed by the Company's privacy policies and procedures.

Data Breach Notification

The Privacy Amendment (Notifiable Data Breaches) Act 2017 requires us, in the event of a data breach, such as the unauthorised loss, use or disclosure of personal information, to assess and respond in line with our applicable policies and procedures. We have an obligation to report data breaches to the Office of the Australian Information Commissioner (OAIC) in certain circumstances. In the unlikely event that we have to notify the OAIC we will also notify the individuals affected.

Access and Updating of Information

Personal information held can be amended or updated anytime upon a written request. We will respond to requests within a reasonable time frame. A reasonable fee may be charged for processing requests (but not for access requests). Requests for access to personal information may be declined in circumstances outlined by the Privacy Act. If this occurs, a written notice will be provided outlining the reasons for refusal (unless providing these reasons is deemed unreasonable).

Upon receiving access to personal information or at any other time, if there's a belief that the personal information held is inaccurate, incomplete, or out of date, please notify us immediately. Steps will be taken to correct the information so that it's accurate, complete, and up to date.

If personal information correction is refused, a written notice will be provided outlining the reasons for refusal (unless providing these reasons is deemed unreasonable). This notice will include details of the mechanisms available for making a complaint.

You can contact us using the contact form on our website or through our complaints channel.