Thank you for your interest in the Piptle Wealth Management Pty Ltd and our associated businesses initiatives. Our focus at Piptle Wealth Management Pty Ltd is to deliver education for people to assist them in upskilling themselves with a view to identifying and creating ways to establish additional income streams. This may include learning about trading of digital assets, learning about peer-to-peer lending, contributing digital assets to yield programs and much more.
For simplicity Piptle Wealth Management is referred to as “PWM” in this document and any references to websites include www.piptle.com, www.piptle.store, and www.piptle.academy, (the “Website”) which are all owned and operated by PWM.
This document and the Terms and Conditions and any other published legal notice as adopted by us from time to time and available on the PWM Platform, constitute the legal relationship between you and us in respect of your use of the PWM Platform.
Collection and Use of Personal Information
Generally, PWM will collect personal information, such as your name and contact details including home address and e-mail address and any other information, necessary to provide our services to you or to provide you with information about PWM and/or our products and services. The specific kinds of personal information we collect will depend on the context of our dealings with you. For example, when you purchase a product from us, we may collect information such as your name, residential and business address, date of birth, contact details (such as email and phone numbers), income details, asset and liabilities information, tax details (whether in Australia or overseas) and financial statements, employment details and details regarding your financial or accounting advisors, as well as information regarding your investment in the fund or product and other dealings with PWM. Where you attend seminars, briefings or other events conducted by PWM or sign up for newsletters or other similar information services of PWM, we may collect information such as your name, contact details (such as email and phone numbers) and details regarding any funds, products or services you have expressed an interest in.
PWM will not generally collect or hold sensitive information about you unless we are compelled to do so by law. Sensitive information includes information about your race, political or religious beliefs, sexual preferences, criminal record, membership of professional or trade associations or unions or health information.
The list below sets out the personal information we will or may collect depending on the circumstances.
We collect personal information including:
- Your full name, title, postal address and telephone number;
- Information to enable us to check and verify your identity, e.g. your date of birth, visa details or passport details;
- Electronic contact details, e.g. your email address, mobile phone number;
- Information necessary in relation to the provision of our services, e.g. your tax file number, employment details and financial information;
- Information about your use of our IT, communication and other systems, and other monitoring information, e.g. if you use our secure online client portals or leave a voicemail message.
Wherever practical, we provide our Privacy Statement to new customers and take care to seek consent from them before we record their personal information.
A customer may have the option not to identify themselves or to use a pseudonym to retain anonymity where the reasons for collecting their information are still able to be achieved. However, in many circumstances this will not be possible, particularly because of the anti-money laundering laws.
If a customer does not provide all the information we require we may not be able to establish and administer an account for them to provide services to them. In some cases, we may be required by obligations under the anti-money laundering laws to collect additional personal information on an application or at a later time.
When you visit our website, either we or our internet service provider will record information in relation to your visit for statistical purposes. The information collected will be your computer’s IP address, top level domain name, type of browser, and the date and time you accessed the webpage.
PWM may collect, use and disclose your personal information to inform you of products, services or offers of PWM which may be of interest to you. Where you are a customer of PWM, this may include providing you with direct marketing information regarding the other services or products of PWM.
PWM may contact and communicate with you for the purpose of direct marketing via the telephone, post, facsimile, email or SMS. If you do not want to receive this information or do not want PWM to use or disclose your personal information for direct marketing purposes, you can opt out by unsubscribing to our marketing emails or by contacting our office and letting us know that you wish to opt out of receiving this information and/or PWM using or disclosing your personal information for direct marketing purposes.
How Personal Information is Collected and your Responsibilities
PWM collects personal information in a range of circumstances including where you apply to invest in a service of PWM, request information regarding PWM or its products or services, attend seminars or other events conducted by PWM, sign up for newsletters or other similar information services of PWM or otherwise engage with PWM. Where you are an investor of PWM, PWM will collect personal information from you to process and establish that investment and also in the course of administering that investment.
Generally, PWM collects your personal information directly from you, for example, when you complete an application form or customer questionnaire, provide information to us at seminars and other events, when you submit information to us via our website, or when we speak to you directly.
There may also be occasions when PWM will collect your personal information from a third party. For example, PWM may collect your personal information from a publicly maintained record, a third-party broker, a person authorised by you (such as your accountant or financial advisor) or our agents or service providers (such as registry service providers).
In the event that PWM collects your personal information from a third party, we will take reasonable steps to inform you of certain matters, such as PWM’s identity and contact details.
Our Website, Cookies and Tracking Technology
Who we Share your Personal Information with
PWM will only share your information with external service suppliers, representatives and agents that we use to make our business more efficient. When we disclose a customer’s information to third parties, we will take all reasonable steps to ensure that those third parties are in full compliance with the Privacy Act.
We may disclose and exchange information to comply with our legal and regulatory obligations.
The types of organisations to which PWM may disclose the personal information held about you include:
• third parties the customer authorises to act on their behalf;
• other entities within PWM or other related companies of PWM (such as subsidiaries);
• any third-party service provider PWM may engage to provide custody, registry, administration, technology, auditing, mailing, printing or other services;
• Government authorities, law enforcement agencies and regulatory bodies including AUSTRAC (which may from time to time include overseas governing bodies and regulators) when and to the extent required under corporations, taxation, social security, or anti-money laundering laws; and
• PWM’s professional advisers (including administrators, lawyers, auditors, consultants and other advisers). Such disclosure will only be done on a confidential basis.
In particular we have Know Your Customer (“KYC”) obligations under the anti-money laundering laws. If certain thresholds are met during a transaction with a customer, PWM is obliged to disclose that information to the relevant government authorities such as AUSTRAC.
Disclosure to Australian recipients
When collecting a customer’s personal information, we will generally notify the customer of any recipients to whom we may likely disclose their personal information. Before disclosing the customer’s personal information to a recipient, we will take all reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information. If we cannot ensure this, we will not disclose the customer’s personal information without their consent.
Storage and Security of your personal information
PWM takes reasonable steps to keep the personal information that it holds about you secure and may hold personal information in both hard copy and electronic forms. PWM will take all reasonable steps to ensure that the personal information it holds is protected against misuse, loss, unauthorised access, use, modification or disclosure.
Personal information is held electronically on Amazon Web Services (“AWS”) servers secured by password protections or in hard copy files located in secured, access restricted environments. PWM’s employees are aware of their obligations and the importance of good information handling and security obligations. They are required to maintain the confidentiality of any personal information held by PWM.
Personal information may also, in certain circumstances, be held on behalf of PWM in hard copy or electronic forms by PWM’s service providers (such as offsite document storage providers or electronic data storage providers). PWM enters into agreements with such service providers which impose confidentiality and privacy obligations on the service provider. PWM will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes stated under this policy.
We will de-identify or dispose of a customer’s personal information in a secure manner when it is no longer required, not contained in a Commonwealth record and is not legally required to be retained.
Data breach notification
In accordance with the Privacy Act, PWM will report certain data breaches (known as Notifiable Data Breaches) to both individuals affected by the breach and the Office of the Australian Information Commissioner (OAIC) as well any applicable international bodies where required. A data breach is when personal information held by an entity is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference. Some data breaches are notifiable under the Privacy Act.
A notifiable data breach may occur where personal information held by an agency or organisation is lost or subjected to unauthorised access or unauthorised disclosure.
To be a notifiable data breach, the data breach must, depending on the circumstances, be one that may or is likely to result in serious harm to an individual whose personal information was part of the data breach. Whether the harm is serious harm to an individual depends upon a variety of circumstances but may include serious physical, psychological, emotional, economic, financial and reputational harm.
PWM has procedures in place to ensure that any identified or suspected data breaches are dealt with promptly, appropriately and escalated accordingly.
Your Rights in regard to your Personal Information
PWM will take steps reasonable in the circumstances to ensure that the personal information PWM collects, holds, uses and discloses is accurate, complete, up-to-date, relevant and not misleading. You are entitled at any time to request access to the personal information we hold about you, known as a data subject access request. You are also entitled to ask that any information we hold about you is supplemented, updated or rectified.
When PWM receives such a request it will take all reasonable steps in the circumstances to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If PWM is unable to or determines that it should not, make the correction you request it will inform you of this in writing, giving reasons for its decision and advising you about how you can complain about that decision.
If PWM refuses or is unable to correct the personal information for any reason it will, if you request, take reasonable steps to associate with the information a statement from you noting that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading in such a way as to make that statement apparent to users of the information.
If at any time you would like to request access to or correction of the personal information about you that PWM collects and holds, please contact our office at [email protected]
Please direct all privacy complaints to our office in the first instance. Privacy complaints will normally need to be made in writing. A privacy complaint relates to any concern or dispute that you have with our privacy practices as it relates to your personal information.
This could include matters such as:
(a) if you believe PWM has breached the APP’s, a binding registered APP code or any other relevant obligations under the Privacy Act with respect to your personal information;
(b) how your personal information is collected;
(c) how your personal information is stored;
(d) how your personal information is used or disclosed; or
(e) how access to your personal information is provided.
At all times, privacy complaints will:
(a) be treated seriously;
(b) be dealt with promptly;
(c) be dealt with in a confidential manner; and
(d) not affect your existing obligations to the commercial arrangements that exist between PWM and you.
We will commence an investigation into your complaint and will respond to the complaint within a reasonable period of time. You will be informed of the outcome of your complaint following the completion of the investigation. In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner (OAIC) or with your national (or in some countries, regional) data protection authority.
PWM can assist you with any enquiries, complaints or feedback you may have. Please contact our office on our email at [email protected]. We offer multilingual support in English and Chinese.
PWM will seek to respond to requests for access to or correction of personal information within 14 days of the date of the request.
If PWM refuses any request for access to or correction of personal information held, written reasons for that refusal will be provided by PWM.
Review of policy
This policy will be reviewed at least annually (or more regularly if there are changes to the legal or regulatory framework which applies to this policy) to ensure it is renewed and updated appropriately. PWM will notify any changes by posting an updated version of the policy on our websites at PWM and sending you an email notification.
Legal and regulatory framework
PWM is subject to the legal jurisdiction of Australia. PWM collection, storage, use, disclosure and other management of personal information is subject to relevant legislation, including the Privacy Act. Amongst other things, the Privacy Act sets out 13 Australian Privacy Principles, which are binding principles that PWM is required to comply with in relation to our collection, storage, use, disclosure and other management of personal information.
The Office of the Australian Information Commissioner (OAIC) is the statutory agency responsible for a number of functions in relation to the Privacy Act, including conducting investigations handling complaints and reviewing notifiable data breaches in relation to the Privacy Act and the Australian Privacy Principles.