Endeavor Asset Management Pty Ltd ACN 143 340 050 and its related entities (referred to in this policy as Endeavor or we) understand the importance of privacy for personal information. We have adopted this Privacy Policy as we recognise the rights of individuals to keep their personal information private.

This Privacy Policy covers treatment of personally identifiable information that we collect or hold (personal information). We will treat personal information we collect or hold in accordance with the Australian Privacy Principles, as set out in Schedule 1 of the Privacy Act 1998 (Cth). The Australian Privacy Principles can be accessed at the Office of the Australian Information Commissioner.

The personal and sensitive information we collect and store

We may collect personal information from clients, employees, job applicants, contractors and other individuals. The types of personal information that we collect will depend on the nature of a person’s dealings with us. We collect this information for our business purposes. This information may include:

  • the products and services we provide or have provided to our clients
  • names, job titles, date of birth, bank account details, shareholding details, tax file number
  • investment experience and objectives, risk profile
  • financial interests and sometimes financial position
  • contact details

Where practicable, the purpose for which we collect personal information and the consequences of not providing it will be made clear at the time of collection.

We do not collect sensitive information about individuals without their consent. Sensitive information includes racial or ethnic origin, political opinions, membership of political, professional or trade associations, religious beliefs, sexual preferences, criminal record, health or disability information.

Any personal or sensitive information that we collect from an individual will only be used for the purpose for which it was collected subject to the exceptions if it is required by law or is necessary in handling a legal claim.

How we collect and store personal information

We may collect personal information in the following ways:

  • from a completed application form for a financial product or service, or a related form required for administering or managing the product or service we are providing
  • by telephone or email or other correspondence
  • when our advisers meet with individuals
  • completed questionnaires
  • when we receive a change of details e.g. address or banking details

If we are contacted by an individual, we may keep a record of that contact. We do not collect personal information about individuals who only browse our website but we do collect login details of registered users of our website.

We normally collect personal information directly from an individual but if an individual has consented, or would reasonably expect us to, we may collect personal information from a third party as well for example:

  • share registries;
  • other organisations providing outsourced functions on our behalf or on behalf of whom we provide outsourced functions
  • credit reporting agencies if necessary, to provide products or services

Where it is practical to do so, we will seek a signed authorisation to allow us to obtain information from third party organisations.

We may also collect information given to us by third parties such as our clients and others with whom we do business. This may include personal information contained in materials provided to us in the course of providing services to our clients or obtained from other organisations providing outsourced functions on our behalf or on behalf of whom we provide outsourced functions. When this occurs, we rely on the person providing us with that personal information having the right to do so.

The reasons we collect, hold and use personal information

The main purposes for which we collect, hold and use personal information are:

  • to provide our products and services
  • to set up, manage and administer financial products and financial services
  • to determine client requirements
  • to provide general financial product advice and financial services
  • to perform securities transactions
  • to identify clients
  • to respond to an individual’s request or enquiry
  • to communicate and maintain contact with our clients
  • to send research reports and information on related services we provide
  • for our general management and reporting purposes, such as invoicing and account management
  • for recruitment purposes and certain purposes related to employment of our personnel including providing products and services to our staff
  • other business purposes

We may use personal information collected to provide information about financial products and services or survey opinions on products or services. An individual may elect at any time not to receive information from us by contacting our advisers or writing to our Privacy Officer, in which case, we will record that request not to receive marketing material.

Disclosure of personal information

Personal information that we collect will be held in the strictest confidence by us. Any personal information we collect may be made available to, or used by our employees and entities carrying out functions on our behalf for the purposes related to the provision of our services.

We do not disclose personal information unless one of the following applies:

  • it is necessary in order to provide the financial services requested or expected of us
  • we have consent from the individual to do so
  • it is required or authorised by law

While we are required under certain circumstances to collect government identifiers such as tax file number, we do not use or disclose this information other than when required or authorised by law or unless the individual has voluntarily consented to disclose this information to any third party.

If we do not have consent from a client to such disclosure, we may not be able to provide any financial services to that client. The types of organisations to whom we typically disclose personal information include information technology providers (for the purpose of maintenance of our IT systems) and related service providers, a settlement and clearance organisation, product issuers, organisations undertaking compliance reviews of our representatives or other due diligence undertaken by us or our representatives.

We may use overseas facilities or contractors to process, store or backup the information we hold or to provide certain products and services to us. If we have to transfer personal information outside Australia, we will comply with trans-border data flow standards under the Privacy Act 1988, for example, by taking reasonable steps to protect the information being held, used or disclosed by the recipient as not to breach the Australian Privacy Principles.

Choices

If we do not have information to identify an individual and certain other personal information, or we have information that is incomplete or inaccurate, it may:

  • mean that we cannot provide financial services to that individual
  • result in the individual paying more tax than may otherwise apply
  • result in the provision of a financial service that is not appropriate

Access

An individual may request access to the personal information that we hold about them and ask us to correct personal information we hold. We will respond to requests in a reasonable timeframe.

We are bound by the Australian Privacy Principles and reserve the right to charge a fee for providing access to or copies of personal information we hold and in some circumstances, may deny access to that information, in which case we will provide a written response setting out the reason for the denial of access.

Accuracy of Records

We take all reasonable steps to ensure that all information we hold is as accurate as is possible, up-to- date and complete. Individuals may contact us at any time and ask for any correction if they feel the information we have about them is inaccurate or incomplete. We will take reasonable steps to correct personal information to ensure that it is correct, update-to-date complete, relevant and not misleading if we believe it needs to be corrected or we receive a request that it be corrected.

We will destroy or de-identify personal information when it is no longer needed.

Links

From time to time we may provide access to external websites through links provided on our website. We take no responsibility for any such websites nor the privacy practices that may apply in connection with that website or the persons who are responsible for it. Individuals accessing such websites should review the applicable privacy policies before sharing personal information.

Data Breach

We may be required to notify individuals and the Office of the Australian Information Commissioner about ‘eligible data breaches’. An eligible data breach occurs when the following criteria are met:

  • there is unauthorised access to or disclosure of personal information held by us (or information is lost in circumstances where unauthorised access or disclosure is likely to occur)
  • this is likely to result in serious harm to any of the individuals to whom the information
  • we have been unable to prevent the likely risk of serious harm with remedial

We will conduct an assessment if it is not clear if a suspected data breach meets these criteria. The assessment will determine whether the breach is an ‘eligible data breach’ that triggers notification obligations. If we are required, we will notify the individuals who are impacted.

Complaints

We are committed to providing quality services to our clients. This commitment extends to providing accessible complaint resolution mechanisms for our clients. If any client has a complaint about the treatment of their personal information or if they would like to discuss our Privacy Policy, they can write to or email our complaints officer at:

Complaints Officer
Endeavor Asset Management Pty Ltd
Suite 4, 1-3 Faussett St. Albert Park VIC 3206

Email: enquiries@endeavoram.com.au

We will review and assess any complaint we receive and provide feedback as quickly as possible. If a client making a complaint is not satisfied with our handling of the issue raised, the complaint may be submitted to the Privacy Commissioner.

How to contact us:

Write to us at:

Privacy Officer
Endeavor Asset Management Pty Ltd
Suite 4, 1-3 Faussett St. Albert Park VIC 3206

Email us at: enquiries@endeavoram.com.au

Contacting us anonymously

An individual may choose to contact us anonymously or by using a pseudonym, however, we will be limited in our ability to answer queries or to provide services in response.

Further Information

For more information about our Privacy Policy please call us on +61 3 9014 7740.

For more information on privacy matters in general please visit the Privacy Commissioner’s website at www.privacy.gov.au.

Updating our Privacy Policy

From time to time we may review, amend or revise our Privacy Policy. Any changes will be consistent with the requirements of the current privacy legislation. The updated Privacy Policy will be posted on our website: www.endeavoram.com.au

Last Update July 2022.