Praemium's Privacy Statement
Praemium Limited, ABN 74 098 405 826 and all its related entities may collect and use your personal information in operating this website and in providing services to you.
Praemium provides financial services, online portfolio administration and CRM services to our customers, who are intermediaries such as financial advisers, accountants, stockbrokers and investment or superannuation administrators, (“Advisers”).
The Praemium services and products include:
- V-Wrap: a non-custodial investment service portfolio administration
- SMA: a managed investment scheme
- SuperSMA: Praemium acts as sponsor of a superannuation fund
- WealthCraft: a software application providing CRM and financial planning tools.
Personal information we collect from others
Generally, Praemium collects or holds personal information about you from Advisers who use the services.
Personal information includes the following:
- Name, residential address, email address and your other contact details
- Date of birth
- Client ID
- Source of funds, beneficiaries/control structures and politically exposed persons’ details
- Details of investments and investment transactions
- Bank account number
- Other details or notes that an Adviser may record in respect to giving financial product advice or administering your investment portfolio
- Other details an Adviser may collect to manage your financial affairs, such as risk profiling or financial goals
- Tax File Number (TFN), an individual’s tax residency status, an ABN
Information we collect
If your Adviser provides you with a login to Praemium’s applications we may collect information about your IP address or activity using Cookies.
We may collect or hold information about you that is publicly available, for example, data on the ASIC database.
Why do we collect and hold this information?
Praemium collects or holds this information in order to provide our services to you or to enable your adviser to perform various functions and services on your behalf. We are also required by law to conduct customer due diligence checks under the AML CTF Act. Praemium cannot provide services to you or your adviser unless this information is collected.
Praemium does not collect ‘sensitive information’ as defined in the Privacy Act.
Dealing with personal information
Using your personal information
Personal information is required to provide a service to you, such as:
- To perform administrative and operational tasks
- To consider certain concerns or complaints you may raise
- To prevent or investigate suspected or actual fraud, misconduct or unlawful activity
- To identify you
- To comply with the Corporations Act, the AML CTF Act, Tax Act and the Privacy Act
We may disclose personal information we collect for the purpose of:
- Meeting our AFS licence requirements
- Collecting overdue payments
- Providing information to any service providers we engage
- Marketing material. (Unless you advise otherwise, Praemium may use your personal information for our marketing purposes. This includes contacting you by telephone, email or mail.)
Disclosing your personal information overseas
We may disclose information to related overseas entities for the purpose of providing internal support for our service and product offering. These entities are currently located in the United Kingdom, China, Hong Kong and Armenia and comply with Australian privacy requirements.
As a backup, data may be hosted and stored in Microsoft cloud facilities located in Ireland and the Netherlands.
The Foreign Account Tax Compliance Act (FATCA) requires Praemium to collect and provide information about US investors who have investments in our SMA. This is lodged with the Australian Tax Office which may ultimately pass over to the US Government’s Internal Revenue Service.
Government related identifiers (GRI)
Praemium may collect or hold government related identifiers to provide its products and services to customers and investors. These include:
- Tax file numbers
- Driver licence numbers
- Australian passport numbers
Praemium is permitted to use or disclose a GRI for an individual if we believe that it is reasonably necessary for one or more enforcement-related activities conducted by or on behalf of a body such as ASIC, Austrac or the Australian Federal Police.
Keeping personal information secure
Praemium has no reason to store hard copy documents, except for SMA investor instructions (including applications). All hard copy documents held by Praemium are stored securely and access is restricted.
Praemium protects personal information from misuse, interference, loss or unauthorised access; however, Praemium cannot be responsible for user access that an Adviser may permit or manage.
We use trusted third parties and our security safeguards include:
- All transmitted data is encrypted on secure networks.
- Firewalls, intrusion detection systems and anti-malware/anti-virus tools.
- Physical security measures are in place, including cameras and smartcards.
- Induction, training in policies and procedures (including clean desk).
- We only keep information as long as we are legally bound to and use secure destruction processes.
- We destroy or de-identify any unsolicited information.
Accessing your personal data
Where Praemium holds data, we create appropriate system access for your Adviser to keep your personal information accurate and up to date. For non-SMA products, your Adviser may also grant you access to update your data.
Where Praemium collects data for SMA we expect that an investor will generally ask their Adviser to correct inaccurate personal information. In rare cases this may not be appropriate and Praemium will respond promptly to requests for correcting personal information or supplying personal data after identifying you.
Making a privacy complaint
In the event an investor believes their privacy has been compromised, they should contact their Adviser first.
However, if you believe your privacy has been compromised by an action undertaken by Praemium, you can contact our client service team at firstname.lastname@example.org or by telephone on 03 8622 1222.
If you feel that your complaint is not satisfactorily resolved, you should follow Praemium’s complaint procedure which is published on our website at www.praemium.com/au/guide-to-making-a-complaint.