Privacy Policy
Eolution Financial Planing Pty Ltd (Evolution Financial Planning, we, us or our) is committed to protecting your privacy and handling your personal information responsibly.
We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other applicable privacy laws and regulatory requirements.
Evolution Financial Planning Pty Ltd is a Corporate Authorised Representative of Evolution Advisory Pty Ltd (AFSL 412063). Personal information may be collected, used and disclosed between Evolution Financial Planning and Evolution Advisory where reasonably necessary to provide financial services, meet our regulatory obligations and manage our relationship with you.
This Privacy Policy explains how we collect, hold, use and disclose personal information, how you can access or correct information we hold about you, and how you can make a privacy complaint.
1. The personal information we collect
The information we collect depends on the nature of our relationship with you and the services we provide.
For clients and prospective clients, this may include:
- your name, date of birth and contact details;
- identification information;
- family and relationship information;
- employment, occupation and business information;
- income, expenses, assets and liabilities;
- superannuation, pension and retirement information;
- investment and banking information;
- taxation information;
- insurance information;
- estate planning and succession planning information;
- information about companies, trusts, self-managed superannuation funds and other entities associated with you;
- information about your financial objectives, needs, preferences and circumstances;
- government-related identifiers where permitted or required by law;
- records of our communications, meetings and advice provided to you; and
- other information reasonably necessary for us to provide financial planning and related services.
In some circumstances we may collect sensitive information, such as health or medical information, where this is relevant to insurance, financial planning or another service you have asked us to provide. We will only collect sensitive information where permitted by law, including where you have consented to its collection.
2. How we collect your personal information
Where practical, we collect personal information directly from you.
We may collect information through:
- meetings, telephone calls, emails and correspondence;
- fact finds, questionnaires and other forms;
- our website and online forms;
- documents and information you provide to us;
- financial planning, client management and communication systems;
- interactions with us through digital platforms; and
- your ongoing dealings with us.
With your authority, or where otherwise permitted by law, we may also collect information from third parties including:
- accountants;
- solicitors and estate planning professionals;
- banks and financial institutions;
- superannuation funds;
- investment and platform providers;
- insurers;
- government agencies;
- other professional advisers;
- your authorised representatives or family members; and
- other service providers relevant to your financial affairs.
If we receive personal information about you that we did not request, we will determine whether we could lawfully have collected that information. If not, and where required by law, we will destroy or de-identify it.
3. Why we collect, hold and use your information
We collect, hold and use personal information primarily to understand your circumstances and provide the financial planning and related services you have requested.
This may include using your information to:
- assess your financial position, objectives and needs;
- prepare and provide financial advice;
- implement agreed financial strategies;
- establish, administer and review financial products and services;
- provide ongoing financial planning services;
- communicate with you;
- liaise with your other professional advisers and authorised representatives;
- verify your identity;
- meet our legal, regulatory, compliance and record-keeping obligations;
- manage complaints and enquiries;
- administer and improve our business, systems and services; and
- provide information and communications that may be relevant to you.
If you do not provide information that we reasonably require, we may be unable to provide financial advice or other services to you, or the advice we can provide may be limited.
4. Who we may disclose your information to
We do not sell or rent your personal information.
Where reasonably necessary to provide our services, or where authorised or required by law, we may disclose personal information to:
- Evolution Advisory Pty Ltd;
- financial product and platform providers;
- superannuation funds;
- insurers and underwriting service providers;
- banks and other financial institutions;
- accountants, solicitors and other professional advisers;
- government agencies and regulators;
- auditors, compliance consultants and professional service providers;
- technology, software, cloud storage and data hosting providers;
- electronic signature and document management providers;
- mailing, communications and email service providers;
- outsourced administrative and support service providers; and
- other persons or organisations authorised by you.
We may also disclose personal information where required or authorised by Australian law, a court or tribunal order, or where otherwise permitted under the Privacy Act.
Where we engage service providers, we take reasonable steps appropriate to the circumstances to protect personal information and to ensure it is handled consistently with applicable privacy requirements.
5. Overseas disclosure and cloud services
Some of the technology, cloud, software, communications and support services used in operating our business may involve personal information being accessed, processed or stored outside Australia.
This may include providers or personnel located in countries such as the United States and the Philippines, and other countries in which our technology or service providers operate.
Where we disclose personal information to an overseas recipient, we take reasonable steps as required under the Privacy Act to ensure the information is handled appropriately, unless an exception under the Privacy Act applies.
The countries involved may change from time to time as our service providers and technology arrangements change.
6. How we protect your information
Protecting the confidentiality and security of client information is important to us.
We take reasonable technical, physical and organisational measures to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.
These measures may include:
- access controls and authentication;
- password and account security;
- secure financial planning and client management systems;
- appropriate cybersecurity controls;
- secure document and data storage;
- restrictions on access to client information;
- staff and contractor confidentiality requirements;
- monitoring and review of our systems and processes; and
- physical security measures where appropriate.
No method of electronic storage or transmission is completely secure. Accordingly, while we take reasonable steps to protect personal information, we cannot guarantee absolute security.
7. Data retention
We retain personal information for as long as reasonably necessary to provide our services and meet our legal, regulatory, professional and record-keeping obligations.
When personal information is no longer required to be retained and we are not legally required to keep it, we take reasonable steps to destroy or permanently de-identify it.
Financial services laws may require us to retain certain client records for specified periods.
8. Data breaches
We maintain processes for responding to suspected or actual data breaches.
Where a data breach involving personal information is likely to result in serious harm and the requirements of the Notifiable Data Breaches scheme are met, we will take the steps required by the Privacy Act 1988, including notifying affected individuals and the Office of the Australian Information Commissioner (OAIC) where required.
We may also take other appropriate steps to contain, investigate and remediate a data breach.
9. Digital tools and automated processing
We may use software, digital tools and technology to assist with the administration, analysis, preparation and delivery of our services.
Technology may assist our advisers and staff with tasks such as organising information, preparing documents, maintaining records, conducting calculations and supporting internal workflows.
We do not rely solely on automated decision-making to provide personal financial advice or make significant decisions about a client's rights or interests unless appropriate controls, human oversight and applicable legal requirements are satisfied.
Where we use personal information in automated decision-making in circumstances that require disclosure under the Australian Privacy Principles, we will provide the information required by those Principles in this Privacy Policy.
10. Direct marketing and communications
From time to time, we may use your contact details to send you newsletters, articles, invitations, updates and information about our services that we believe may be relevant to you.
We will only do this where permitted by law.
You can opt out of receiving marketing communications at any time by:
- using the unsubscribe facility included in an electronic communication; or
- contacting us and asking to be removed from the relevant communication list.
Opting out of marketing communications will not prevent us from contacting you where necessary to administer our relationship with you or provide services you have requested.
11. Our website
When you visit our website, certain technical information may be collected automatically.
This may include:
- your device or browser type;
- IP address or general location information;
- pages viewed;
- links selected;
- referring websites;
- dates and times of visits; and
- other website usage information.
We may use this information to operate our website, understand how visitors use it, improve its performance and content, maintain security and better understand the effectiveness of our communications.
Some information may be collected through third-party website, analytics or technology providers.
12. Cookies and similar technologies
Our website may use cookies and similar technologies.
Cookies are small data files stored on your device or browser. They can help websites operate effectively, remember preferences and provide information about how visitors interact with a website.
Depending on the technologies used on our website, cookies may be used for:
- essential website functionality;
- website performance and analytics;
- remembering preferences;
- security; and
- measuring the effectiveness of communications or marketing.
You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of parts of our website.
Third-party services integrated with our website may also use cookies or similar technologies and may handle information in accordance with their own privacy policies.
13. Links to other websites
Our website may contain links to third-party websites.
We are not responsible for the privacy practices or content of websites operated by other organisations. We recommend reviewing the privacy policy of any external website before providing personal information.
14. Accessing your personal information
You may request access to personal information we hold about you.
To protect your privacy, we may need to verify your identity before providing access.
We will respond to access requests within a reasonable period and will generally not charge you for making a request. In some circumstances, we may charge reasonable costs associated with providing access where permitted by law. We will tell you about any proposed charge before proceeding.
There are circumstances under the Privacy Act in which we may refuse access to some or all of the information requested. If this occurs, we will provide reasons where required by law.
15. Correcting your personal information
We take reasonable steps to ensure that personal information we hold is accurate, up to date, complete, relevant and not misleading.
If you believe information we hold about you is incorrect or needs updating, please contact us.
Where appropriate and required by law, we will take reasonable steps to correct the information.
16. Privacy complaints
If you have a concern or complaint about how we have handled your personal information, please contact our Privacy Officer.
Please provide sufficient information for us to understand and investigate your concern.
We will acknowledge and investigate your complaint and aim to provide a response within 30 days. If we require additional time, we will let you know.
If you are not satisfied with our response, you may be entitled to refer your complaint to an applicable external dispute resolution scheme and/or the Office of the Australian Information Commissioner (OAIC).
Information about privacy complaints and the OAIC is available at the OAIC website.
17. Contact us
For questions about this Privacy Policy, to request access to or correction of your personal information, or to make a privacy complaint, please contact:
Privacy Officer
Evolution Financial Planning Pty Ltd
2/95 Tamar Street
BALLINA NSW 2478
PO Box 151
BALLINA NSW 2478
Telephone: (02) 6681 1911
Email: james@evolutionfinancial.com.au
18. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our business practices, technology, service providers or legal and regulatory obligations.
The current version will be published on our website and will show the date it was last updated.