This Policy was last updated on 9 July 2019.
This policy statement addresses the following:
We are committed to respecting and protecting the privacy of our customers, clients and users of our Website. This policy outlines our ongoing obligations to you in respect of how we collect, store, use, secure, disclose, rectify and erase your Personal Information voluntarily supplied by you to us. Where you provide Gerard Coutts Pty Ltd with your Personal Information, whether in person, via the Website, telephone, email or any other form of correspondence, we will endeavor to ensure that such information remains private and is only used in accordance with this policy.
Gerard Coutts Pty Ltd is bound by the National Privacy Principles, under the Privacy Act 1988 (Cth), which set clear standards relating to the collection, storage, usage, security, disclosure, rectification and erasure of any personal information we obtain as a result of our business operations. We have implemented stringent security measures and procedures to ensure compliance with the National Privacy Principles and to keep any personal information you provide secure. A copy of the National Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au. Use of our Website, online products and services are governed by Australian law.
2. Personal Information
The personal information we collect includes, but is not limited to, first and last names, addresses, postal codes, telephone and facsimile numbers, email address and any other personal or private information voluntarily provided by you to us.
3. Collection of Personal Information
3.1 Personal information is collected so you can take full advantage of our products, services and advice upon your request.
3.2 The methods by which we collect Personal Information include, but are not limited to, online contact forms, subscription forms, registration forms, surveys, questionnaires and by your participation in forums where our products and services are discussed.
3.3 Personal Information may be collected when customers communicate with our employees and contractors in person, by telephone and facsimile number, email or any other form of correspondence.
3.4 You are not obligated to provide any information requested by us. However, if you choose to withhold information, we may not be able to provide you with some products, services or advice that depend on the collection of this information (particularly where collection of this information is required by law).
3.5 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.
Use of “Cookies”
3.6 When you access, interact with and use the Website, non-personal information may be automatically collected through the use of ‘cookies’ or similar technologies, to assign your web browser with a ‘User ID’. Cookies contain information which enables us to identify and store information about your computer or device including, but not limited to, an IP Address, the type of browser you are using, the date and time of your visit to our Website and the pages you’ve accessed.
3.7 Cookies are used on our Website to enhance your user experience by storing session information such as your last search and registration details.
3.8 The information in cookies are collected, stored and used on our Website for research and marketing analytics such as Google Analytics, and to track web traffic on an aggregate basis. We may use the information contained in cookies to make assumptions about your interests and to provide you with focused advertising that we believe may be of interest to you via the use of applications such as Google AdWords, Pixels and Facebook marketing.
3.9 In some cases, a web page might contain more than one cookie in which case the information gathered from these cookies are used to build statistical and demographical information which does not identify you personally to advertisers or third parties. By accessing and using the Website, you consent to the storing and accessing of cookies or other information on your device where such activity occurs in connection with our online products and services.
4. Use and Disclosure of Personal Information
4.1 We may use information collected from you for the following primary purposes:
(a) to provide you with products, services or advice you have requested;
(b) to personalize and customize your experience on our Website;
(c) to help us manage and enhance the services it provides to you;
(d) to communicate with you in order to maintain our business relationship with you or respond to any queries or resolves any complaints you may have;
(e) to verify your identity before accessing, updating or disclosing your Personal Information at your request;
(f) to comply with our legal obligations;
(g) to give you the opportunity to receive information about Gerard Coutts & Associates’ news, events, promotions, competitions or offerings in respect of our products and services such as emails or ‘e-newsletters’. You will be able to unsubscribe or “opt-out” from such communications by contacting us in writing, including by email.
We may use your Personal Information for secondary purposes closely related to these primary purposes, in circumstances where you would reasonably expect such use or disclosure, or otherwise, with your consent.
Disclosure to Third Parties
4.2 We are not in the business of selling customers’ information to third parties. However, we may disclose your personal information to:
(b) another business if we merge or are acquired by another business. In this event, we may share your personal information with the new owners of the business and their advisers, but you will be notified of such an event;
(c) regulatory or law enforcement authorities if we are required to do so; and
(d) any third parties authorised by you to receive personal information held by us. Where reasonable and practicable to do so, we will collect your Personal Information only from you. However, in some circumstances where it is unreasonable or impracticable to collect information from you, we may be provided with or collect your Personal Information from third parties. For example, we may collect information from a publicly maintained record. 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.
5. Access and Maintenance the Quality of Personal Information
It is an important to us that your Personal Information is up to date and accurate. 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.
5.1 You may request access to or update the Personal Information which we hold about you by contacting our Privacy Officer at the contact details set out below. However, there are some exceptions to this right in the Privacy Act 1988 (Cth).
5.2 We may require you to verify your identity and provide further information about your request in order to access or update your Personal Information. Where we are legally permitted to do so, we may refuse your request for access to your Personal Information and we will provide reasons for doing so via a written notice detailing with the reasons for the refusal and the process for making a complaint about the refusal.
5.3 Where you request your Personal Information to be updated and there is a dispute about the facts, we will make a note on your Personal Information of such dispute.
5.4 If you request that we stop using your information and stop contacting you, we will comply with that request.
5.5 We will not charge any fee for your access request, but we reserve the right to charge an administrative fee for providing a copy of your Personal Information to you.
6.1 We are committed to protecting the Personal Information which we hold from misuse, loss, unauthorized access, modification or disclosure by various means including firewalls, password access, secure servers, back-up measures and Secure Sockets Layer (SSL) software which encrypts information you input.
6.2 While we take all reasonable steps to keep your Personal Information secure, accurate and up to date, the internet is not always an absolutely secure method of transmitting Personal Information. Accordingly, we cannot ultimately accept responsibility for the security of information you send to us or receive from us over the internet or from any events arising from unauthorized access or use of that information.
6.3 However, we will endeavor to take all reasonable steps to ensuring the security and protection of your Personal Information you transmit to us from our online products and services. Precautions we have in place to ensure this include confidentiality requirements of our employees and contractors, only providing access to Personal Information once identification has been given, implementing policies in relation to document storage and implementing security measures to our Website and electronic systems, which we review and update periodically.
6.5 When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to erase 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.
8. Contacting the Privacy Officer
If you wish to gain access to or update your Personal Information, or wish to make a complaint, or have any other enquiries or feedback regarding this policy please contact us using the details listed below.
If you believe this policy has been breached please contact us via written form, email, telephone or other correspondence. For us to get in contact with you and resolve the complaint as quickly and reasonably as possible, include your contact details and a detailed description of your complaint. If you are unsatisfied with the outcome of your complaint you may refer your complaint to the Office of the Australian Information Commissioner to be resolved.
Gerard Coutts Pty Ltd
Telephone - 03 9819 9301
Fax - 03 9819 9311