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Privacy Policy


Privacy Policy V1.1 Mar14

Privacy Policy

Complete Super Solutions Pty Ltd (CSS) is committed to providing you with the highest levels of client service.
We recognise that your privacy is very important to you. Privacy Amendment (Enhancing Privacy Protection) Act
2012 sets out a number of Australian Privacy Principles (APPs). Our aim is to both support and ensure that we
comply with these principles. Further information on privacy in Australia may be obtained by visiting the website
of the Office of the Australian Information Commissioner at http://www.privacy.gov.au.

CSS believes that this Privacy Policy discloses how the personal information you provide to us, and our
representatives, is collected, used, held, disclosed and disseminated. In order to provide investment and
superannuation administration services to you, we are required to collect certain personal information from you.
We encourage you to check our website regularly for any updates to our Privacy Policy.

Your Personal Information
Personal information held by CSS may include the following information:
– Your name, date of birth, current addresses, telephone and mobile numbers, fax numbers, email address;
– Your SMSF/PAS assets and liabilities (current and future), income, expenses;
– Your life insurance details;
– Your pin codes and electronic access codes; and

If you choose not to provide certain personal information or provide incorrect information, the administration
service we provide to you may be inappropriate or inadequate.

How we collect Personal Information
CSS collects personal information in a number of ways, including:
– Directly from you;
– Directly from you via an email or the internet; and
– Directly from your financial planner, fund managers, accountant, life insurance companies, banks and other
product issuers once you have provided authorisation. You have a right to refuse us authorisation to collect
information from a third party.

How we use your Personal Information
Primarily, your personal information is used in order to provide a superannuation and/or portfolio administration
service to you. From time to time, we may provide you with direct marketing material. This will include articles
and newsletters that may be of interest to you. If, at any time, you do not wish to receive this information any
further, you may contact us with this request. We will endeavour to meet your request within two weeks. We
maintain a register for those individuals not wanting direct marketing material
In providing our services to you now or in the future, it may be necessary for us to forward personal information to
relevant overseas third party service providers i.e. superannuation administration service providers. It is not
practicable to list every country in which such recipients are located but it is likely that such countries will include
India. Please let us know if you have any objections to such transfers.

When do we disclose your Personal Information
We may disclose your personal information to organisations outside CSS. The organisations to which we
disclose information may include:
– Temporary staff to handle workloads during peak periods;
– Mailing houses;
– Your professional advisers, including your solicitor, financial planner or accountant as authorised by you;
– Information technology service providers to manage our IT systems;
– Government and regulatory authorities and other organisations, as required or authorised by law;
– A potential purchaser/organisation involved in the proposed sale of our business for the purpose of due
diligence; and
– A new owner of our business that will require the transfer of your personal information.
In addition, our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of
Privacy Policy V1.1 Mar14 any personal information held by CSS. This is covered in our contractual agreements with these parties.

How We Store and Secure Your Personal Information
At all times your personal information is treated as confidential and any sensitive information is treated as highly
confidential in the following way:
– We keep your personal information in your client file;
– These files are accessible to authorised personnel only and are appropriately secured out of hours;
– Your personal information will also be held on our computer database;
– All computer based information is protected through the use of access passwords;
– Data is backed up regularly and stored securely off site.

We are committed to keeping the data you provide to us secure and we will take all reasonable precautions to
protect your personally identifiable information from loss, misuse or alteration.
It is a legislative requirement that we keep all personal information and records for a period of seven years.
Therefore, if you are no longer a client of CSS, we will maintain your personal information on or off-site in a
secure manner for seven years. After this, we will ensure it is destroyed in a secure manner.

Ensure Your Personal Information Is Correct
CSS takes all reasonable precautions to ensure that the personal information we collect, use and disclose is
accurate, complete and up to date. To ensure we can maintain this level of accuracy and completeness, we
recommend that you:
– Inform us of any errors in your personal information as soon as possible; and
– Update us with any changes to your personal information as soon as possible.

Unsolicited personal information
We don’t usually collect unsolicited personal information. Where we receive unsolicited personal information, we’ll
determine whether or not it would have been permissible to collect that personal information if it had been
solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we’ll
destroy or de-identify that personal information as soon as practicable.

Access to Your Personal Information
You have a right to access your personal information, subject to certain exceptions allowed by law. Access to the
requested personal information may include:
– Providing you with copies;
– Providing you with the opportunity for inspection; or
– Providing you with a summary.
We ask that you provide your request for access in writing (for security reasons) and we will (subject to certain
exceptions) provide you with access to that personal information. Please address your request to our Privacy
Officer. In some cases a fee may be involved in providing the information.
We will not provide you with access to your personal information if:
– Providing access would pose a serious threat to the life or health of a person;
– Providing access would have an unreasonable impact on the privacy of others;
– The request for access is frivolous or vexatious;
– The information related to existing or anticipated legal proceedings between us and would not be
discoverable in those proceedings;
– Providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice
those negotiations;
– Providing access would be unlawful;
– Denying access is required or authorised by or under law; or
Privacy Policy V1.1 Mar14
– Providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an
enforcement body requests that access not be provided on the grounds of national security.
In the event we refuse you access to your personal information, we will provide you with an explanation for that

Our Website
We understand that our clients are concerned about the privacy afforded to their information collected via the
A cookie is a piece of information that an Internet website sends to your browser when you access information at
that site. Cookies can be used to record what parts of a website your computer is visiting although they do not
identify individual users they do allow identification of the type of browser used and the Internet Service Provider
(ISP) used. CSS’s website only makes use of session cookies which are destroyed when you quit your browser,
no personal information is maintained which might identify you should you visit our website at a later date. Our
website may provide links to third party websites which are not within our control and we cannot accept
responsibility for the use of your information by these organisations.

Collection of Personal Information Online
We are committed to providing our clients with a high level of privacy in relation to the personal information that is
collected by us whilst the client is online at our website. This includes your name, address, telephone number,
facsimile number email address payment details.
The Internet Service Provider for our website also records and collects the following information for statistical
purposes each time you visit our website:
– Your server address;
– Your top level domain name (for example .com, .gov.au, etc);
– The date and time of your visit to the site;
– The pages you accessed and documents downloaded;
– The previous site you have visited; and
– The type of browser you are using.
We do not use or disclose your personal information collected to any third party without firstly gaining your
consent, or unless it is required by law.
Your email address is recorded when you send an email message to us which together with any other personal
information that we collect will only be used for the purpose for which it has been provided to us. Information may
be used for secondary related purposes in circumstances where you would reasonably expect such use or
disclosure. Under no circumstances will your email address be added to a mailing list or used for any other
purpose without your consent or unless the law requires it. Users should be aware that there are inherent risks
transmitting information across the Internet.

Spam is a generic term used to describe electronic ‘junk mail’- unwanted messages sent to a person’s email
account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.
‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but not cover
normal voice-to-voice communication by telephone.

We comply with the provisions of the Spam Act when sending commercial electronic messages. Equally
importantly, we make sure that our practices are in accordance with the National Privacy Principles in all activities
where they deal with personal information. Personal information includes our clients contact details.

The three key steps CSS follows:
– Consent – Only commercial electronic messages are sent with the addressee’s consent – either express or
inferred consent.
– Identify – Electronic messages will include clear and accurate information about the person and CSS that is
responsible for sending the commercial electronic message.
– Unsubscribe – We ensure that a functional unsubscribe facility is included in all our commercial electronic
messages and deal with unsubscribe requests promptly.

Promotional Material
If you have registered to receive email communications from us and later change your mind, you may contact us to
have your name removed from our distribution lists. A company register is also maintained for individuals not
Privacy Policy V1.1 Mar14
requiring direct marketing material.
1. You can send an email to our Privacy Officer.
2. You can send written advice to our Privacy Officer.

Complaints Resolution
Please contact our Privacy Officer if you wish to complain about any breach or potential breach of your privacy
rights. Your complaint will be responded to within seven days. If you are not satisfied with the outcome of your
complaint, you are entitled to contact the Office of the Privacy Commissioner.
If you have any concerns regarding your privacy rights, you may contact us as follows:
The Privacy Officer
Complete Super Solutions Pty Ltd
58 Tope St, South Melbourne, VIC 3205
Telephone: 03 9584 5999
Email: brett@completesupersolutions.com

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