Optimo Financial Pty Ltd is committed to protecting the privacy of the personal information that we collect and complying with the Privacy Act 1988(Cth) (“the Privacy Act”).
What is your personal information?
The term “personal information” has the meaning given to it in the Privacy Act. Personal information includes information or an opinion about an identified individual, or an individual who is reasonably identifiable from the information or opinion. In summary, personal information is any information about you that can be linked to you.
What personal information do we collect and hold?
The personal information collected may consist of your name, address, telephone number, email address, age, birthdate, unique site access id, contact information, financial information, job applications, details of services you have used or enquired about or other information about you. We provide various enquiry forms on the Optimo Site on which some detail is requested. The personal information collected from these forms is only used to allow us to respond directly to you unless otherwise set out in a form. No contact information given in this way is provided to other companies or individuals.
Personal information is also collected from a variety of sources including Optimo Financial’s customers, but only where Optimo Financial has assurances about the source’s compliance with the Privacy Act. The databases maintained by Optimo Financial for customers contain information about both individuals (personal information) and corporate entities. The type of personal information held depends on the hosted software service used by our customer and how the customer uses it, and will typically include name, address, contact details and some financial information.
Sensitive information is a specific category of personal information. Such information includes membership of a trade union, profession, trade association, health information, criminal record and the like. We may need to collect, hold and disclose sensitive information about you in relation to your engagement with us. If we do we will get your specific consent to the collection and use of this information.
We may collect some information that is not personal information because it is not linked to you or any other identifiable person.
How do we collect and hold your personal information?
We collect your personal information directly from you unless it is unreasonable or impracticable to do so.
We may also collect personal information from third parties including:
· Our service providers,
· Business affiliates,
· Other third parties such as employers and persons nominated by you as referees or credit agencies or government agencies; and
· Our customers, who are mostly financial institutions and financial advisers, use our software products and services under contractual arrangements. When using our software products and services, our customers will collect solicited personal information from their customers (end customers). Where we provide our customers with hosted software services, the personal information about their end customers is held in related databases on infrastructure and data servers owned by Optimo Financial and are kept at an internal secure data centre.
For what purposes do we collect, hold and disclose your personal information?
We collect personal information about you if you are engaged by us, use our website or so that we can perform our business activities.
We collect, hold and disclose your personal information for the following purposes;
· To provide our services to you, send communications requested by you, answer queries and provide information about existing or new services;
· To provide your updated personal information to related bodies corporate, our contractors or service providers if such disclosure is required to administer our business functions or to provide our products or services to you or our customers;
· To keep our records and your records up to date;
· To process and respond to any complaint made by you;
· To manage and service our customer and business relationships. We collect, hold and use solicited personal information for the primary purpose of providing our software products and/or services to our customers, providing hosted software services, supporting our customers in their use of our products and/or services and communicating with customers and/or financial product or service providers as required to adequately service our customers in accordance with contractual arrangements. The type of personal information held depends on the hosted software service used by our client and how the customer uses it. Where we hold personal information about end customers, the personal information is under the customer’s control and we may use or disclose this information to the associated customer at any time, including for the purpose of dealing with an enquiry or complaint about the personal information.
· To perform statistical analysis of the Optimo Website’s user behaviours; and
· To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any country.
We will not intentionally disclose (and will take commercially reasonable steps to prevent the accidental disclosure of) your personal information to third parties other than as listed above, whether for such third parties marketing purposes or otherwise, except where we believe we are under a legal duty to do so e.g. with the consent of the individual, in emergencies, or where required by law.
If we are unable to collect or hold your personal information, we may be unable to fulfil some or all of the purposes listed above. In particular we may be unable to provide our services to you or our customers or provide you with full access to the Optimo Site.
Do we disclose your personal information to anyone outside of Australia?
We do not disclose information to any corporations, customers or third party suppliers located overseas. Our customers may access the Optimo Financial website from outside Australia. The customers are required to accept terms and conditions that include assurances that any personal information will not be dealt with inconsistently with the Privacy Act. Cross-border disclosure of personal information by a customer using the Optimo Financial software is addressed by the privacy policies and procedures of the customer. The same applies to outsourced infrastructure & data centre functions which support our financial services software.
How can I access, change and/or delete information?
You may request access to any personal information we hold about you that is in our control at any time by contacting us. Where we hold information you are entitled to access, we will try and provide you with a suitable means of accessing it (for example by mailing or emailing it to you). We will not charge for making a request but reserve the right to make a reasonable charge for the cost of providing the information. To do so please contact the General Manager on the contact details below. Requests must be made in writing with sufficient identification, to ensure that we do not give your details to someone else. There may be times where we cannot give you access to the personal information we hold. For example, if access would interfere with the privacy of others or if it would result in a breach of confidentiality or law, we will not be required to grant you access. We will let you know if this is the case.
We will take such steps as are reasonable in the circumstances to correct personal information in our control which is identified to be inaccurate, out of date, incomplete, irrelevant or misleading. Where this is requested by the individual, we will respond to the request within a reasonable period after the request is made and will not charge the individual for the making of the request, for correcting the personal information or for associating the statement with the personal information (as the case may be). In some cases, requests for correction will need to be referred back to the original collection source of the information, to ensure that any inaccuracies do not simply re-appear when we next receive updates. Referral will also help to ensure that any inaccuracies are also drawn to the attention of other organizations that receive the same data. Where relevant, Optimo Financial will take such steps as are reasonable in the circumstances to notify third parties of the correction, unless it is impracticable or unlawful to do so.
While requests for correction are being sorted out with sources, or where we disagree with an individual’s assertion, we may ‘flag’ the information concerned to ensure that any users are aware that the quality of the information has been challenged. Where we decline to make corrections, we will provide the individual with an explanation.
You may also have your personal information deleted. You should be aware that we required by law to retain certain personal information (such as payroll records); such information will not be deleted. We will let you know if we cannot delete your personal information for legal or other reasons.
We take precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction. We protect electronic data using a variety of methods including password access, data back-up and firewalls. Our site is deployed with a number of enterprise encryption standards including SSL/TLS encryption, securing web traffic between the visitor’s web browser and our servers.
Our software products are hosted by secure in-house maintained servers located in Australia.
Links to other sites
Please note that the Optimo website may have links to other websites. We make no representations or warranties in relation to the privacy practices of any third party website. We encourage you to review and understand the privacy policies of the relevant third parties before providing any information to them.
We will treat your requests or complaints confidentially subject to our obligations to customers who may have provided us the information. We will contact you within a reasonable time after receipt of your request or complaint to discuss your concerns and outline options regarding how they might be resolved.
General information about privacy may be found via http://www.privacy.gov.au and http://www.oaic.gov.au