We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.  “We”, “us” and “our” means Soar Asset Management Pty Ltd ACN 636 887 084 of Level 8, 56 Pitt St, Sydney NSW 2000 (Soar).  You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.

What is personal information?

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.

What personal information do we collect and hold?

We collect information about you and your interactions with us, for example, when you purchase or use any of our products or services, call us or otherwise visit our website. The information we collect from you may include your name and date of birth, your contact details including your address, phone number(s) and email, your identity documents (including driver’s license, passport or other), information required by product issuers (e.g. occupation, mother’s maiden name), your Tax File Number, your bank account details, your holdings of term deposits or other cash products and details of enquiries or complaints you make, provided to Soar by telephone, by email or otherwise.

We may collect information about how you access, use and interact with the website.  This information may include:

• The time and the date that you visited;
• General usage and including any information or documentation that you have downloaded;
• Information input directly;
• Your browser type.

We use cookies on the website. A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser.  However, please note that if you do this, you may not be able to use the full functionality of the website.

Why do we collect, hold and use your personal information?

We collect, hold and use your personal information so that we can:

• provide you with products and services, and manage our relationship with you;
• contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
• comply with our legal obligations and assist government and law enforcement agencies or regulators; or
• identify and tell you about other products or services that we think may be of interest to you.

If you do not provide us with your personal information we may not be able to provide you with our services, communicate with you or respond to your enquiries.

How do we collect your personal information?

We will collect your personal information directly from you whenever you interact with us.

We may collect information from third parties such as:

1. Third parties you refer us to and authorise us to talk to;
2. Information that is publicly available; and
3. Product issuers which may include banks, credit unions and non-bank financial institutions.

In some circumstances we may access mailing lists to obtain information to conduct market research. We use reputable mailing list companies who are also bound by the Privacy Act. We do not keep a record of any information about you from those lists unless you contact us. The information on those mailing lists remains the property of the company by whom the list was provided.

How do we store and hold personal information?

We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.

We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.

These processes and systems include:

• the use of identity and access management technologies to control access to systems on which information is processed and stored;
• requiring all employees to comply with internal information security policies and keep information secure;
• requiring all employees to complete training about information security; and
• monitoring and regularly reviewing our practise against our own policies and against industry best practice.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

Who do we disclose your personal information to, and why?

We may transfer or disclose your personal information to our related companies.

We may disclose personal information to external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others (outside our group of companies) where:

• we are required or authorised by law to do so;
• you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
• we are otherwise permitted to disclose the information under the Privacy Act
• Information may be disclosed to third party electronic verification providers for the purpose of identifying you, in which case the information will be limited to your identity particulars;
• To evaluate, effect, manage and administer the services provided by us;
• To inform you of other products and services offered by other entities that provides services on our behalf. This includes marketing and promotion by way of direct mail, telemarketing, email, SMS and MMS messages. However, you may at any time “opt out” of receiving direct marketing;
• When engaging third party providers to perform services for Soarwhich involves third parties handling personal information;
• To research, develop and improve our services, including testing and improving systems for the management of the services provided;
• For security and audit purposes, service monitoring, internet traffic monitoring, trouble shooting, maintenance, to protect against and identify security breaches, inappropriate behaviour, fraud and unauthorised access to the IT systems of Soar;
• For communication purposes where contact details are received by us because you sent these to enable us to respond to your request;
• To conduct our business and perform other management and administration tasks;
• To manage any legal actions concerning Soar;
• To consider any concerns or complaints an individual may have;
• To help us improve the services offered to our client, and to enhance our overall business;
• To product issuers for which we may act as agents for the purpose of complying with anti-money laundering and counter terrorism financing laws.

If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.

Do we use your personal information for marketing?

We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

Access to and correction of your personal information

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.

Complaints

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact details

If you have any questions, comments, requests or concerns, please contact us during business hours, Monday to Friday at:

Phone: 02 9807 9258

Post: Level 8, 56 Pitt St, Sydney NSW 2000

Soar Asset Management Pty Ltd

E-mail: info@soaram.com

Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.

Terms of Use

Thank you for visiting our website. This website is owned and operated by Soar Asset Management Pty Ltd ABN 95 636 887 084 (CAR #001284204 AFSL 260038) as authorised representative. By accessing and/or using this website and related services, you agree to these Terms and Conditions, which include our Privacy Policy (Terms). You should review our Privacy Policy and these Terms carefully and immediately cease using our website if you do not agree to these Terms.

In these Terms, ‘us’, ‘we’ and ‘our’ means Soar and our related bodies corporate.

Use of this website

You are responsible for all of your activity in connection with accessing and using this Website.

You must not use this Website for any activities that breach any laws, infringe any party’s rights or breach any standards, content requirements or codes promulgated by any relevant authority.  You must not distribute through this Website any inappropriate communication or any virus or other disabling code in any form.

You must not bypass any security mechanisms imposed by this Website, or tamper with, hinder the operation of or make unauthorised access or modifications to this Website.

Certain parts of this Website may be restricted to certain users, and other terms of use may apply to the use of these other parts of this Website (Other Terms).  To the extent of any inconsistencies between these Terms and the Other Terms, the Other Terms will prevail.

Security

We take reasonable steps to protect the information that you transmit using this Website.  However, we cannot guarantee the security of any information that you transmit to us using this Website.  Therefore, any information you transmit using this Website is transmitted at your own risk.  When using this Website, you must take precautions to ensure that you are not exposed to the risk of viruses, malicious computer code or other forms of interference which may damage your own computer system. We do not accept responsibility for any such interference or damage to your systems which arises in connection with your use of this Website.

Collection notice

We collect personal information about you in order to provide you with financial services and for purposes otherwise set out in our Privacy Policy.

We may disclose that information to third parties that help us deliver our services (including information technology suppliers, communication suppliers and our business partners) or as required by law. If you do not provide this information, we may not be able to provide all of our services and products to you.

Our Privacy Policy explains: (i) how we store and use, and how you may access and correct your personal information; (ii) how you can lodge a complaint regarding the handling of your personal information; and (iii) how we will handle any complaint. If you would like any further information about our privacy policies or practices, please contact us at info@soaram.com.

By providing your personal information to us, you consent to the collection, use, storage and disclosure of that information as described in the Privacy Policy and these Terms.

Accuracy, completeness and timeliness of information

The information on our website is not comprehensive and is intended to provide a summary of the subject matter covered. While we use all reasonable attempts to ensure the accuracy and completeness of the information on our website, to the extent permitted by law, including the Australian Consumer Law, we make no warranty regarding the information on this website. You should monitor any changes to the information contained on this website.

We are not liable to you or anyone else if interference with or damage to your computer systems occurs in connection with the use of this website or a linked website. You must take your own precautions to ensure that whatever you select for your use from our website is free of viruses or anything else (such as worms or Trojan horses) that may interfere with or damage the operations of your computer systems.

We may, from time to time and without notice, change or add to the website (including the Terms) or the information, products or services described in it. However, we do not undertake to keep the website updated. We are not liable to you or anyone else if errors occur in the information on the website or if that information is not up-to-date.

Linked sites

Our website may 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 do not endorse and are not responsible for the content on those linked websites and have no control over or rights in those linked websites.

Intellectual property rights

Unless otherwise indicated, we own or license from third parties all rights, title and interest (including copyright, designs, patents, trademarks and other intellectual property rights) in this website and in all of the material (including all text, graphics, logos, audio and software) made available on this website (Content).

Your use of this website and use of and access to any Content does not grant or transfer any rights, title or interest to you in relation to this website or the Content. However we do grant you a license to access the website and view the Content on the terms and conditions set out in this Agreement and, where applicable, as expressly authorised by us and/or our third party licensors.

Any reproduction or redistribution of this website or the Content is prohibited and may result in civil and criminal penalties. In addition, you must not copy the Content to any other server, location or support for publication, reproduction or distribution is expressly prohibited.

All other use, copying or reproduction of this website, the Content or any part of it is prohibited, except to the extent permitted by law.

Unacceptable activity

You must not do any act that we would deem to be inappropriate, is unlawful or is prohibited by any laws applicable to our website, including but not limited to:

• any act that would constitute a breach of either the privacy (including uploading private or personal information without an individual’s consent) or any other of the legal rights of individuals;
• using this website to defame or libel us, our employees or other individuals;
• uploading files that contain viruses that may cause damage to our property or the property of other individuals;
• posting or transmitting to this website any non-authorised material including, but not limited to, material that is, in our opinion, likely to cause annoyance, or which is defamatory, racist, obscene, threatening, pornographic or otherwise or which is detrimental to or in violation of our systems or a third party’s systems or network security.

If we allow you to post any information to our website, we have the right to take down this information at our sole discretion and without notice.

Warranties and disclaimers

To the maximum extent permitted by law, including the Australian Consumer Law, we make no warranties or representations about this website or the Content, including but not limited to warranties or representations that they will be complete, accurate or up-to-date, that access will be uninterrupted or error-free or free from viruses, or that this website will be secure.

We reserve the right to restrict, suspend or terminate without notice your access to this website, any Content, or any feature of this website at any time without notice and we will not be responsible for any loss, cost, damage or liability that may arise as a result.

Liability

To the maximum extent permitted by law, including the Australian Consumer Law, in no event shall we be liable for any direct and indirect loss, damage or expense – irrespective of the manner in which it occurs – which may be suffered due to your use of our website and/or the information or materials contained on it, or as a result of the inaccessibility of this website and/or the fact that certain information or materials contained on it are incorrect, incomplete or not up-to-date.

Jurisdiction and governing law

Your use of the website and these Terms are governed by the law of New South Wales and you submit to the non-exclusive jurisdiction of the courts exercising jurisdiction in New South Wales.