LEGAL

Privacy policy

A compliant Australian Privacy Policy under the Privacy Act 1988 and the Australian Privacy Principles (APPs) typically covers:

Identification of the entity. Which legal entity (or entities) the policy covers. For Count Wealth this means clarifying the relationship between the three entities (Count Wealth Pty Ltd, Count Wealth Investment Management, Count Wealth Accounting) and whether the policy covers all three or each has its own.

Kinds of personal information collected. Categories of personal information collected (name, contact details, financial situation, tax file number where relevant, identity verification information, health information for insurance advice, sensitive information). Distinction between information collected from the individual and from third parties (employers, super funds, banks, credit reporting bodies).

How and why personal information is collected. The legal basis for collection (consent, contractual necessity, legal obligation, legitimate interests). The purposes for collection (providing financial advice, meeting AFSL/ACL obligations, meeting AML/CTF obligations, conducting credit checks for lending services, providing tax services).

How personal information is held and secured. Description of physical, technical, and organisational security measures. Reference to encryption, access controls, retention periods, secure destruction. Statement about offshore data storage if relevant (e.g. cloud service providers in other jurisdictions).

Use and disclosure of personal information. When and to whom personal information is disclosed: super funds, insurers, product providers, platforms (HUB24, AMP North, BT Panorama), credit reporting bodies, the ATO, ASIC, AUSTRAC, and other Count Group entities. Clarity on data-sharing within the Count Group is particularly important.

Direct marketing. Use of personal information for direct marketing. Opt-out mechanism. Compliance with the Spam Act 2003 and the Do Not Call Register Act 2006.

Access and correction. How individuals can access and correct their personal information. Process for handling access requests. Reference to the privacy contact officer.

Complaints and privacy contact. How to make a privacy complaint, the internal process, and the right to escalate to the Office of the Australian Information Commissioner (OAIC) or, for credit-reporting matters, the Australian Financial Complaints Authority (AFCA). Privacy contact officer name and contact details.

Cookies and website analytics. Use of cookies, analytics tools (Google Analytics, Tag Manager), and any tracking pixels. User choice on cookie acceptance.

Credit Reporting Privacy Policy. Because Count Wealth Pty Ltd operates as a Credit Representative under AFG's ACL, a separate Credit Reporting Privacy Policy may be required, or the credit-reporting-specific obligations need to be addressed within the main Privacy Policy. Compliance team to confirm.