Privacy Policy

1. Introduction and Our Commitment

Prime Partners Financial Advice Pty Ltd ABN 50 158 705 358 (“Prime Partners”, “we”, “us”, “our”) holds an Australian Financial Services Licence (AFSL No. 458993) and is committed to protecting the privacy of our clients, prospective clients, and all individuals whose personal information we hold.

This Privacy Policy explains how we collect, use, disclose, store, and manage your personal information in connection with the provision of financial planning and advisory services. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act. Although our annual turnover is below $3 million, we voluntarily comply with the Privacy Act and the APPs in their entirety given the sensitive nature of the financial information we hold.

We are also subject to obligations under the Corporations Act 2001 (Cth), the Australian Securities and Investments Commission Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and other applicable legislation governing the provision of financial services in Australia. This Policy should be read alongside our Financial Services Guide (FSG) and any other disclosure documents we provide.

2. What is Personal Information?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true, and whether or not it is recorded in a material form. Sensitive information is a subset of personal information and includes financial details, government identifiers such as Tax File Numbers, health information, and other matters that attract a higher standard of protection under the Privacy Act. We treat all sensitive information with heightened care and only collect it where it is necessary for the provision of our services.

3. What Personal Information We Collect

3.1 Types of Information

Depending on the nature of your engagement with us, we may collect the following categories of personal information:

• Identity and contact information: full name, date of birth, gender, residential and postal addresses, telephone numbers, and email addresses
• Government-issued identification: passport, driver licence, Medicare card, or other verification documents collected for identity verification and KYC purposes
• Financial information: income, assets, liabilities, superannuation balances, investment holdings, insurance arrangements, bank account details, transaction history, and tax information
• Tax File Numbers (TFNs): collected only where required for the provision of financial services and handled in accordance with the Tax File Number Guidelines 2011
• Employment details: employer, occupation, salary, and employment status
• Family and relationship information: marital status, dependants, beneficiary nominations, and estate planning details
• Health information: where relevant to insurance or financial planning advice, such as income protection or life insurance needs analysis
• Investment objectives, risk profile, and financial goals
• Records of advice: Statements of Advice (SOAs), Records of Advice (ROAs), and associated supporting documentation
• Communications: correspondence records, meeting notes, and telephone records
• Website usage data: IP addresses, browser type, and pages visited

3.2 How We Collect Information

We collect personal information:

• Directly from you through client intake forms, fact-finds, meetings, telephone calls, email, and our website
• From third parties with your consent, including financial institutions, superannuation funds, insurers, accountants, and solicitors
• From publicly available sources such as ASIC, the Australian Taxation Office (ATO), and other government registries where appropriate
• Through automated means when you visit our website, where cookies and similar technologies may collect technical usage information

Where practicable, we collect personal information directly from you. If we collect it from a third party, we will take reasonable steps to notify you.

4. Why We Collect and Use Your Personal Information

We collect, hold, use, and disclose your personal information for the following primary purposes:

• Providing financial advice and services, including preparing SOAs, ROAs, and conducting ongoing advice reviews
• Complying with our legal and regulatory obligations under applicable Commonwealth and state legislation
• Verifying your identity and satisfying our obligations under anti-money laundering legislation
• Assessing your financial situation, goals, risk tolerance, and needs to provide appropriate advice
• Managing ongoing client relationships, including annual reviews, ongoing service agreements, and fee consent obligations
• Maintaining accurate records of the advice and services provided in accordance with our AFSL obligations
• Processing instructions and liaising with financial institutions, superannuation funds, and insurers on your behalf
• Communicating with you regarding your financial affairs, service reviews, regulatory changes, and market developments
• Improving our services, managing our business, and training staff
• Handling complaints and managing disputes through appropriate channels

We will only use your personal information for purposes other than those listed above where you have provided your consent or where it is otherwise permitted or required by law.

5. Disclosure of Your Personal Information

5.1 Who We May Share Your Information With

We may disclose your personal information to the following categories of third parties:

• Financial product providers including superannuation funds, investment platforms, managed fund administrators, insurance companies, and financial institutions, to implement advice or maintain your financial arrangements
• Other professional advisers including accountants, solicitors, mortgage brokers, and financial specialists where necessary to provide comprehensive financial planning services
• Regulatory and government bodies including ASIC, the ATO, AUSTRAC, Centrelink, and the OAIC, where required by law or regulation
• Our licensee or professional indemnity insurer as required for compliance oversight or claims management
• Third-party technology service providers engaged to support our business operations, as detailed in Section 6
• External dispute resolution bodies including the Australian Financial Complaints Authority (AFCA), if a complaint is lodged
• Successors in the event of a sale, transfer, or merger of our business, subject to the Privacy Act

We do not sell your personal information to third parties. We do not disclose your personal information to third parties for their own marketing purposes without your explicit consent.

5.2 Overseas Disclosure

In the course of delivering our services, some of your personal information may be transmitted to or accessible from overseas locations, primarily as a result of our use of cloud-based technology platforms and AI-assisted tools whose infrastructure is hosted internationally. Countries where your data may be processed include, but are not limited to, the United States of America and other jurisdictions depending on the technology providers engaged.

Before disclosing personal information to overseas recipients, we take reasonable steps to ensure that those recipients do not breach the APPs in relation to your information. Where Australian Privacy Principle 8.1 applies, we will either obtain your consent to the overseas disclosure or satisfy ourselves that the overseas recipient is subject to substantially similar protections. Please note that where consent is obtained under APP 8.2(b), we may not be accountable under the Privacy Act for the overseas recipient’s subsequent handling of your information.

6. Use of Technology and AI Tools

6.1 Our Approach to Technology

Prime Partners uses a range of third-party technology platforms and services to support the efficient and compliant delivery of financial services. These include practice management systems, cloud-based productivity and communication tools, investment platforms, compliance systems, and artificial intelligence (AI)-assisted drafting and research tools. We are committed to responsible and transparent use of all technology in our practice and take steps to protect your personal information when engaging with such services.

The table below summarises the categories of technology we currently use and the purposes for which your information may be engaged:

Technology Category	Purpose	Data Location
Practice Management Software	Client record keeping, advice workflow management, SOA and ROA generation, and compliance documentation	Australia (domestic cloud or on-premises hosting)
Cloud-Based Productivity and Communication Tools	Email, document preparation, internal collaboration, file storage, and staff communications	Australia and/or international data centres (varies by provider)
AI-Assisted Drafting and Research Tools	Supporting the preparation of advice documents, research summaries, strategy notes, and internal workflow processes. AI tools are used as drafting aids only; all outputs are reviewed by a licensed adviser.	Primarily international (including United States-based servers)
Financial Product and Investment Platforms	Implementation of financial advice, portfolio administration, transaction processing, and reporting	Australia and/or international (varies by provider)
Compliance and Regulatory Reporting Systems	Fee disclosure, consent management, regulatory reporting, and breach management	Australia

The specific providers engaged within each category may change from time to time as we review and update our technology arrangements. This policy will be updated accordingly when material changes are made and we encourage you to review it regularly. A current register of technology providers is available upon request.

6.2 Use of AI-Assisted Tools

We use AI-assisted tools to support tasks such as drafting financial advice documents, summarising research and strategy notes, reviewing documentation quality, and managing internal workflows. The following safeguards apply to our use of AI tools:

• AI tools are used as drafting and research aids only. No financial advice is generated or delivered solely by an AI tool. All outputs are reviewed, verified, and authorised by a qualified and licensed financial adviser before being provided to any client.

• We take steps to minimise the input of personally identifiable information into AI platforms where practicable. Where such information is necessary, we rely on contractual and policy obligations of the relevant provider and take reasonable steps to ensure appropriate handling.

• Data submitted to AI tools may be processed on overseas servers, primarily in the United States. Refer to Section 5.2 for further information on overseas data handling.

• We do not use AI tools to make automated decisions about your financial situation or suitability for any financial product or service without human review and oversight.

• Staff who use AI tools receive training on responsible use, the protection of client confidentiality, and the limits of AI-generated outputs in the advice process.

Clients who wish to opt out of having their information engaged in AI-assisted processes should contact our Privacy Officer using the details in Section 12. We will endeavour to accommodate such requests where operationally practicable, though this may affect the efficiency with which we can deliver certain services.

7. Tax File Numbers

We may be required to collect your Tax File Number (TFN) in connection with the financial services we provide, including matters relating to superannuation, investment accounts, and tax-related advice. TFNs are collected under the authority of the Income Tax Assessment Act 1936 (Cth) and are handled strictly in accordance with the Tax File Number Guidelines 2011 issued by the Australian Information Commissioner.

You are not obliged to provide your TFN. However, without it we may be unable to establish certain financial products on your behalf, or you may be subject to higher withholding tax rates. Your TFN will not be disclosed to third parties except as authorised by law, and will be stored securely with access limited to authorised personnel.

8. Storage and Security of Your Information

We take the security of your personal information seriously and implement reasonable physical, electronic, and administrative safeguards to protect it from unauthorised access, misuse, loss, modification, or disclosure. Our security measures include:

• Secure, access-controlled systems with multi-factor authentication for all staff

• Encryption of data in transit and at rest where technically feasible

• Role-based access controls limiting access to personal information to those staff who require it to perform their duties

• Regular review of our IT systems, third-party platforms, and security settings

• Staff training on privacy obligations, data security, and responsible use of technology

• Physical security controls for any paper-based records containing personal information

Despite these measures, no method of electronic data transmission or storage is entirely secure. We cannot guarantee the absolute security of your information and encourage you to contact us promptly if you have concerns about how your information is being handled.

We retain personal information for as long as it is required to fulfil the purposes for which it was collected, or as required by law. Under the Corporations Act, financial advice records must generally be retained for a minimum of seven years. When personal information is no longer required, we take reasonable steps to destroy or de-identify it securely.

9. Notifiable Data Breaches

We are committed to compliance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). If we become aware of a data breach that is likely to result in serious harm to an individual whose personal information is involved, we will:

• Contain the breach and conduct an assessment as soon as practicable

• Notify the Office of the Australian Information Commissioner (OAIC) where required by law

• Notify affected individuals where required and where it is practicable to do so

• Take remedial action to prevent or minimise further harm

We maintain an internal data breach response plan which is reviewed regularly to ensure it remains effective.

10. Your Rights to Access and Correct Your Information

Under the Privacy Act, you have the right to request access to the personal information we hold about you and to request its correction if it is inaccurate, out of date, incomplete, irrelevant, or misleading. To make an access or correction request, please contact our Privacy Officer using the details set out in Section 12.

We will respond to your request within a reasonable timeframe, generally within 30 days. In some circumstances we may be required by law to decline access to certain information, or we may charge a reasonable fee for providing access. If we refuse to provide access or correct information, we will provide you with written reasons and advise you of your right to complain to the OAIC.

11. Cookies and Our Website

Our website may use cookies and similar tracking technologies to improve your browsing experience and to analyse website traffic. A cookie is a small text file placed on your device when you visit our website. We use cookies for the following purposes:

• Essential functionality: required for the website to operate correctly and cannot be disabled

• Analytics: to understand how visitors interact with our website using anonymised, aggregated data that does not identify individuals

• Preferences: to remember your settings and improve your experience on return visits

You may configure your browser to refuse or delete cookies. Please note that doing so may affect the functionality of our website. Our website may also contain links to third-party websites, for which we are not responsible. We encourage you to review the privacy policies of any third-party sites you visit.

12. Contact Us and Privacy Complaints

12.1 Privacy Officer

If you have a question, concern, or complaint about how we handle your personal information, or wish to make an access or correction request, please contact our Privacy Officer:

Privacy Officer

Prime Partners Financial Advice Pty Ltd

Email: compliance@primepartners.com.au

Post: Locked Bag 5030 Gladesville NSW 2111

Phone: 02 9879 7005

We will acknowledge your complaint promptly and aim to resolve it within 30 days. If we are unable to resolve the matter to your satisfaction, we will advise you of available external complaint avenues.

12.2 External Complaint Bodies

If you are not satisfied with our response, you may contact:

• The Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au | 1300 363 992

• The Australian Financial Complaints Authority (AFCA): www.afca.org.au | 1800 931 678

• The Australian Securities and Investments Commission (ASIC): www.asic.gov.au

13. Changes to This Privacy Policy

We review and update this Privacy Policy regularly to ensure it remains current and compliant with applicable law, including any changes to our technology arrangements, regulatory obligations, or business practices. The most current version is available on our website and will be provided to you upon request. We will notify existing clients of material changes in writing or by email where practicable. Continued engagement with our services following notification of an update constitutes acceptance of the revised Policy.

14. Governing Law

This Privacy Policy is governed by the laws of Australia, including the Privacy Act 1988 (Cth) and the Corporations Act 2001 (Cth). Any disputes arising in connection with this Policy will be subject to the jurisdiction of Australian courts and tribunals.