For the purposes of this Privacy Policy the words “CSS”, “we”, “our” and “us” refer to Complete Super Solutions Pty Ltd (ACN 115 304 482), and the Instead+ software platform, comprising of the database, system, materials and services delivered on or through our cloud based Instead+ technology (“Software”).

This Privacy Policy should be read carefully by users of the Software and those (you, your employees, co-workers and other members of your organisation) who receive the Services (as that term is defined below) and by persons who are granted access to the Software to view their financial and other personal information uploaded by their professional adviser (“you”) prior to accessing or using the Information and Services available through the Software or by otherwise using our Services.

This Privacy Policy pertains to your access to the Software for your own use and / or information and is also available to and should be read carefully by any third parties whose personal information you are duly authorised to upload to and manage through the Software (“your clients”).

By providing us with personal, sensitive and protected information (“Information”) for the provision of our Services to you and/or your clients, you agree to our collection, use and disclosure of you and your clients’ Information, as described in this Privacy Policy. Each time you use the Software you will be deemed to accept the practices outlined in this Privacy Policy.

1.                  Our commitment to your privacy

CSS, subject to its terms and conditions, provides a database system utilising cloud technology which is designed to provide accountants, financial advisors and trustees of self-managed super funds (“SMSFs”) with a personally controlled records management and administrative system and associated services which allows you to manage clients’ SMSFs and investment portfolios (“Services”). These Services are generally provided through the Software.

CSS takes your privacy seriously, and strictly adheres to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) ("APPs") and other laws relating to privacy, and the collection, use and disclosure of personal, sensitive and protected information. We will only collect Information that is necessary for us to provide you with the Services that we offer through our Software.

This Privacy Policy outlines our practices relating to the collection, use, disclosure and storage of your Information. Unless you give us explicit consent or direction otherwise, we will act in accordance with this Privacy Policy with regard to our collection and use of your Information.

2.                  The information we collect

We will only collect Information that is reasonably necessary for us to provide you with, or is directly related to, the functions that we offer through our Software, and Services that you have requested from us.

We collect Information from you when you interact with the Software, which could include when you register with us or when a professional adviser registers your details with us, or when you use the features available on the Instead+ site or when you otherwise interact with us.

We also collect all Information that is sent to CSS by you, your clients or other third parties which is relevant to the Services provided on the Software. We act as a mail clearing house for all post and electronic communications received which will immediately be uploaded by us onto the Software and filed into defined categories.

Advisers

The Information in relation to you which CSS may collect and upload into the Software includes, without limitation, details of your organisation including employees, address, telephone number, email, the services you use through the Software or any other Information necessary to provide the functions and Services requested.

Clients

The Information in relation to clients of an adviser using the Software which CSS may collect and upload into the Software includes, without limitation, details of your clients and their SMSFs and investment portfolios including names, dependants’ and spouses’ names, postal addresses, email addresses, telephone numbers, credit card details, tax file numbers, ABN and ACN details, direct debit details, SMSF documents and financial records, including but not limited to, bank statements, trust statements, investment summaries, dividend statements, BAS statements or any other Information necessary to provide the functions and Services requested.

CSS will collect Information only by lawful and fair means and not in an unreasonably intrusive way. CSS may collect Information directly from you, directly from your clients or from related third parties. CSS will only upload, disclose, obtain or otherwise request personal information of clients upon receipt of their prior written consent to do so.

3.                  How we use your information

We will only use you, or your clients’ Information for the provision of our Services to you, and for any other purpose which we state at the time of the collection permitted by law and/or as required to provide the functions and Services you request or require as permitted by law.

We may also use Information you provide to directly market to you or provide you with relevant information or alerts. If we market to the public (such as through an advertising campaign), we will only use aggregated information on a purely anonymous basis with your Information removed. You can opt out of marketing activities at any time. By providing email, telephone numbers and other personal contact information to us you are deemed to have consented to being marketed to via these methods.

When you access our Software, our servers automatically record certain information. These server logs may include information such as your web request, your interaction with a Service, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser or your account.

We may also collect Information about you and how you interact with the Software, by using or storing cookies on your computer. You can delete cookies from your computer at any time via your internet browser. However doing so may limit your use of some of the Software’s features.

4.                  Sharing your information

Your clients’ information will be accessible using the Software only to parties who are authorised and responsible for management of your clients’ SMSFs and investment portfolios. CSS will first obtain written confirmation from owner of the SMSF authorising access to their details or disclosure of their details by their adviser or any third party.

We will only disclose you and your clients’ Information to third parties in the following circumstances:

·                    When we have your consent, and in the case of your clients’ information when you have their duly authorised consent.

·                    To third parties where necessary for us to provide our Services to you, or where you have expressly asked us to do so for the purposes of them or us providing further Services. These third parties may include, without limitation, service providers, government departments, social services, community services and commercial services.

·                    Banks, payment processors or payment service providers.

·                    To Government bodies, research institutions, not for profit organisations or other third parties (“Researchers”) for the purpose of research and development and only where we determine live data is needed for those research and development activities. We will only disclose your Information to the Researchers if they have signed a confidentiality agreement agreeing not to disclose your Information to any other third party.

·                    To our related bodies corporate, and their respective directors, officers, agents, and employees for the purpose of processing Information on our behalf.

·                    We may from time to time engage service providers to help us deliver our Services to you. These service providers may be located in Australia and/or overseas. In these instances, we may disclose your Information to these third parties in order to help deliver Services to you.

·                    To comply with any law enforcement agency, judicial proceeding, court order, or legal process in any jurisdiction that is investigating any breach or suspected breach of any law in any jurisdiction regarding your identity or other Information provided by you to us.

·                    Where disclosure is reasonably necessary to enforce our agreements with you or any rights we have, including investigation of potential violations, or to detect, prevent, or investigate a matter relating to security, fraud, citizen protection or other technical issues.

·                    Where disclosure is reasonably necessary to protect CSS’s rights or intellectual property or to protect the safety of CSS’s employees, users or the public as required or permitted by law.

·                    Where we consider disclosure is necessary for the protection and wellbeing of a person, including your clients.

·                    Where we are otherwise permitted by law to disclose your Information.

Upon opting in to receive notifications from us, these will be sent to you directly by us. We will only send communications to people who have opted to receive them. You can unsubscribe from receiving these notifications at any time.

In the event CSS goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, you or your clients’ personally identifiable information may be among the assets transferred. We will ensure the confidentiality of any Information involved in such transactions.

5.                  How you may access your information

We provide you with easy access to the Information stored in the Software. Your level of access to the Information will depend on whether you are an adviser or a client. Clients will be granted limited access to the Software and the Information collated and stored by us and will only be permitted to update certain details. You may only change, access and download Information which is entered into the Software if you have the requisite access authorisation.

Copies of other Information which we hold may be reasonably requested by contacting us via email at support <at> completesupersolutions <dot> com or by calling us in Australia on 03 9520 2977. We may charge you a reasonable fee for complying with any such request.

We may refuse, in our sole discretion, to provide you access to your Information which we hold, where such refusal is permitted by the Privacy Act 1988 (Cth), the APPs or any other law.

If you no longer wish to receive email communications or notifications from us, you can unsubscribe at any time by using the link on the emails we send you, or informing us via support <at> completesupersolutions <dot> com and we will do it for you.

6.                  How we protect your information

We will act to protect your Information in accordance with the APPs. We are committed to keeping the Information you provide to us secure. We take all reasonable precautions to protect the Information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.

While we take all due care in ensuring the privacy and security of your Information, the possibility exists that this Information could be unlawfully intercepted while in transit over the internet, while stored on the Software’s systems or by human error. We disclaim all liability to you to the greatest extent pursuant to law should this occur.

We will take reasonable steps to destroy or permanently de-identify Information if it is no longer needed for the purpose for which the information was disclosed.

7.                  How we store your information

Once Information is uploaded onto the Software, it will be contained on a local server. The server will then transfer some of the Information, such as images of financial documents, to the server of Amazon Web Services (“AWS”), a company which provides cloud storage services located in Sydney, to store on our behalf.

8.                  Access to the Software outside Australia & Cross Border Disclosure

CSS does not represent or warrant that the Software complies with the laws of any country outside of Australia. If you access the Software from outside Australia, you do so at your own risk.

Unless you advise us otherwise, you will be taken to consent to any necessary cross-border disclosure of you and your clients’ Information to enable the Software to provide the Services to you. By providing your consent, you acknowledge that CSS does not need to take any steps to ensure that an overseas recipient of your Information treats your Information in accordance with this privacy policy.

9.                  Quality & Correction Information

We obtain Information from you, your clients or other third parties which we then store in the Software. We depend on you to ensure that the Information you or they provide is accurate, up-to-date, complete and relevant. It is your responsibility to update any of your Information via the Software. If, for whatever reason, you are unable to amend the Information then please contact us, and we will make those amendments for you.

If you cease to be a user of the Software, CSS may retain you and your clients’ Information to comply with its record keeping obligations under law.

10.               Other websites

The Software contains links to websites which are not maintained or controlled by CSS or its related companies. Once you transfer from the Software to a third party website, we are not responsible for the conduct or practices of those websites, as they are not under our control. When you transfer to a third party website you should check the applicable privacy policy of that site.

11.               Contacting us

If you have any queries in relation to this Privacy Policy, or if you would like to request access to your Information or have a complaint about a breach of privacy, then please contact us at support <at> completesupersolutions <dot> com or by calling us in Australia on 03 9520 2977.

12.               Changes to this Privacy Policy

CSS intends to develop and enhance the Software continuously, by adding new features and Services. As we add features we may update this Privacy Policy from time to time as required. We will also keep prior versions of this Privacy Policy archived. You should periodically visit this page to review the current Privacy Policy.

For more information about privacy issues in Australian and protecting your privacy, visit the Federal Privacy Commissioner’s website.

This Privacy Policy was last modified on 18 April 2016.