At LGT Crestone Wealth Management Limited (ABN 50 005 311 937) (LGT Crestone Wealth Management), we are committed to safeguarding the Personal Information that we collect and use in the course of our business operations.
This Privacy Statement (Statement) describes how we manage our obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), which regulate the way which we manage your Personal Information.
Capitalised terms in this Statement are defined in section 4. References to LGT Crestone, we, us and our are to LGT Crestone Wealth Management and its affiliates. References to you and your are to you as a recipient of the financial products and services we provide, and as an individual from whom we collect Personal Information.
This Statement should be read in conjunction with:
Note: Refinitiv is a third party who we engage from time to time to conduct screening on our behalf in order to comply with our anti-money laundering and counter-terrorism financing obligations, as described further in sections 2.3 and 2.4 below.
If you are a customer or potential customer
If you are a customer or a potential customer of LGT Crestone, we collect information about you to provide you with services and otherwise facilitate your dealings with us. The types of Personal Information that we may collect and hold will include information used to identify you, your financial position and any other related information necessary or incidental to the advice, financial products and services which we provide or propose to provide to you. This may include, but is not limited to, your:
In addition, we are required to collect and hold certain types of Personal Information in order to comply with our obligations under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), the Foreign Account Tax Compliance Act 2010 (USA) and the Tax Laws Amendment (Implementation of the Common Reporting Standard) Act 2016 (Cth), which in certain circumstances may include Sensitive Information or government related identifiers (GRIs). We will only collect your Sensitive Information and GRIs with your consent or as otherwise permitted by law.
We may also collect personal information about other people, directly from you (e.g. about your spouse, partner, dependents, business representatives, company directors and/or shareholders, if appropriate and necessary). We rely on you to inform these individuals that their personal information is being provided to us, and that they can contact us directly for further information.
The Personal Information that you provide to us will be information which enables us and our strategic partners and other service providers to perform our functions or activities. If you do not provide any of the Personal Information we request or do not consent to the use, holding or disclosure of your Personal Information in accordance with this Statement, we may not be able to provide you with the products or services you require.
If you do business or have other dealings with us
If you, or your employer, does business with us or has other dealings with us, we may collect Personal Information about you to facilitate those arrangements. This information may include your name, position, contact details, and any other information you provide.
If you are an employee or prospective employee/applicant
If you are an employee or a job applicant, we collect Personal Information about you to administer your employment or process your application. This may include qualification and identification information (including your home address, phone number, emergency contact details and passport / drivers licence details), residency / visa status information, medical records and health information, psychological testing results and results from records checks. If you are offered a position, we may also collect details such as your tax file number, bank account number, superannuation and union membership details.
Directly from you
We will, in most cases, collect Personal Information from you directly. For example, if you provide us with information in order for us to supply you with wealth management services, this may be through phone, email or online through our website. This may also include recording telephone calls that we have with you. We may also collect Personal Information from you when you work with us, or apply for a job with us.
We may also collect Personal Information generated from your use of our website and systems.
From our strategic partners and other third parties
In some circumstances, we may also collect Personal Information about you from our strategic partners or other third parties. The partners and third parties from whom we may acquire Personal Information include, but are not limited to, information service providers, credit agencies, financial advisers, fund managers and intermediaries.
Additionally, if you apply for an employment position with us, we may collect Personal Information about you from a recruitment partner, your previous employers, referees, other CV checking agencies or others who may be able to provide information to assist us with our recruitment decision.
Should a third party provide us with your Personal Information, we will assume that you have provided your consent for that third party to do so, unless you tell us otherwise. If you have any problems or queries with us obtaining Personal Information about you from a third party, or if you would like to correct the Personal Information we hold about you, you should contact us and the relevant third party to address your problems or queries – see more contact information in section 3.
Collection through other means
We may also collect Personal Information about you through other means, for example from publicly available information sources, third party search engines and from your representatives and associates (e.g. your spouse, partner or dependants).
The purposes for which we will use Personal Information will depend on the relationship we have with you and the nature of the products and services that you require from us. We collect, hold, use and share your Personal Information in order for us to undertake our business operations and activities. For example, we may use and disclose your Personal Information to:
We may share your Personal Information, for the purposes described in this Statement, with:
We take reasonable steps and measures to ensure that the parties we share your Personal Information with are bound by equivalent privacy obligations as set out this Statement.
We may disclose your Personal Information to our related bodies corporate and other third party service providers outside of Australia, who perform functions on our behalf or assist us to undertake our business operations and activities. These overseas entities may be located in, or have personnel that may access your information from, jurisdictions including: Austria, Belgium, Brazil, Canada, China, Denmark, Finland, France, Germany, Hong Kong, India, Indonesia, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Malaysia, Mexico, Netherlands, New Zealand, Norway, Philippines, Portugal, Russia, Singapore, South Africa, South Korea, Spain, Switzerland, Taiwan, Thailand, United Arab Emirates, United Kingdom and United States of America.
Our website may also contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Statement, so we encourage individuals to read them before using those websites.
We generally hold Personal Information in our electronic databases but also store Personal Information in hard copy form and in various third party databases. All Personal Information will be held in a secure environment—either in writing, electronically or both. We have security measures in place which are intended to protect Personal Information that we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Personal Information will only be available to our employees on a need-to-know basis in order to perform their duties.
The key methods of securing the Personal Information we hold will include but are not limited to:
You can request to access the Personal Information we hold about you, at any time, by contacting your investment adviser or our privacy officer. We have included the contact details for our privacy officer at section 3.
We will respond within a reasonable time period of receiving a request from you. Where possible we will provide you with a copy or details of your personal information in the manner you requested. We may charge a reasonable fee for access to your Personal Information.
Sometimes we may be unable to provide you with access to all of your personal information. Where this is the case, we will tell you why.
We take reasonable steps to ensure that the Personal Information we collect, use and disclose is accurate, complete, up to date and relevant. If you believe that your Personal Information is outdated, incorrect or incomplete, you may request to have the Personal Information corrected. We will respond within a reasonable period of receiving your request and we will promptly update our records accordingly.
If we refuse to comply with your correction request, we will tell you why.
If you have any questions regarding our compliance with the Privacy Act or if you wish to make a complaint about our handling of your Personal Information, we encourage you to contact us. Relevant contact details can be found in section 3.
Complaints should first be made in writing to us, and should include your name, email address and/or telephone number and clearly describe your complaint. We will endeavour to respond to a complaint within a reasonable time period of receiving the complaint.
If you are not satisfied with our response to a complaint, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For further information regarding how to make a complaint to the OAIC, you can visit oaic.gov.au/privacy/making-a-privacy-complaint.
You may also lodge a complaint directly with the Australian Financial Complaints Authority which can be contacted as follows:
Address: GPO Box 3, Melbourne VIC 3001
Telephone: 1800 931 678
This Statement does not apply in respect of any of our acts and practices that are directly related to an employee record of a current or former employee. These are captured in the LGT Crestone human resources policies and procedures.
We reserve the right at our discretion to modify or remove any part of this Statement at any time. You should review this Statement from time to time so that you are updated on any changes.
You can contact our privacy officer by post or email, using the following contact details:
LGT Crestone Wealth Management Privacy Officer
Level 32, Chifley Tower 2 Chifley Square
Sydney NSW 2000
|AFS Licence||Australian Financial Services Licence|
|APPs||Australian Privacy Principles|
|ASIC||Australian Securities and Investments Commission|
|LGT Crestone||LGT Crestone Wealth Management and its affiliates|
|LGT Crestone Wealth Management||LGT Crestone Wealth Management Limited|
|GRI||Government related identifier. Has the meaning given in the Privacy Act and includes an identifier of an individual that has been assigned by a government agency or authority, including their agents.|
|OAIC||Office of the Australian Information Commissioner|
Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
Common examples of Personal Information are an individual’s name, signature, address, telephone number, date of birth, bank account details and commentary or opinion about a person.
|Sensitive Information||Has the meaning given in the Privacy Act and includes information about an individual’s racial or ethnic origin, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, criminal record, or health information.|