If you do not provide the personal information that BF&A requests, BF&A may not be able to provide products and services to you and you may not be able to use the BF&A Site. Given the nature of the products and services that BF&A provides, it will not be possible for BF&A to provide its products and services to you if you wish to use a pseudonym.
The personal information BF&A collects and holds about you will vary based on why BF&A is collecting and holding the personal information, for example, if you are a client it will depend on the products or services BF&A provides to you. Personal information BF&A may collect and hold about you includes:
- your name, date of birth, residential and business addresses, telephone numbers, email and other electronic addresses, occupation, details about your spouse and dependents (if any) and details about your business dealings;
- information about your assets, liabilities and investments;
- information about products and services BF&A or BF&A’s affiliates provide to you and other transactions you enter into with BF&A or BF&A’s affiliates, including investment performance, investment and transaction history and details about account activity and product and service use;
- government identifiers, such as your tax file number, driver’s licence number and passport number;
- the IP address of any device that you use to access the BF&A Site and other information collected by cookies on your devices, as described in section 7;
- if you apply for employment with BF&A, details of your employment history, education, professional qualifications and referees; and
- other information BF&A determines is necessary to enable BF&A to manage your relationship with BF&A, such as the name and contact details of your other professional advisers or representatives and details of your communications with BF&A.
- How does BF&A collect your personal information?
BF&A will usually collect personal information directly from you when you interact with BF&A, including for example when you complete any application form for a product or service or when you access the BF&A Site. BF&A may also collect your personal information from:
- BF&A’s business partners and affiliates;
- BF&A’s service providers;
- government agencies such as the Australian Securities & Investments Commission;
- your employer; and
- if you apply for employment with BF&A, from any persons you nominate as referees.
If it is otherwise unreasonable or impracticable to collect your personal information directly from you, BF&A may also collect that personal information from other sources.
BF&A collects, holds, uses and discloses your personal information where this is reasonably necessary for BF&A’s business functions or activities. This means BF&A collects, holds, uses and discloses your personal information for the following purposes:
- to process your requests for BF&A’s products or services;
- to provide BF&A’s products and services to you, including through BF&A’s Client Platform on the BF&A Site;
- to communicate with you on an ongoing basis about your investments and to otherwise manage BF&A’s relationship with you and to respond to your questions, inquiries and complaints;
- to provide you with educational or marketing material or other information about other investment opportunities, BF&A’s other products and services and educational or networking events;
- to provide you with information about professional services providers, such as legal, immigration, tax and accounting services providers;
- to undertake research, risk assessment, audit or report activities (including analyses and materials and information generally in relation to investments and markets);
- to research, develop and design products and services to meet your needs and the needs of BF&A’s other clients;
- to operate, develop, service and maintain the BF&A Site and Client Platform;
- to detect, prevent and investigate any matter relating to security, fraud or any breach of law;
- to enforce BF&A’s rights, including undertaking legal proceedings;
- if you apply for employment with BF&A, to assess your application for employment; and
- to meet BF&A’s legal and regulatory requirements.
- Third parties to whom personal information is disclosed
When required for or in connection with any of the purposes listed in section 5, BF&A may disclose your personal information to the following entities, who may be located outside Australia:
- entities you invest in or in which BF&A invests on your behalf;
- BF&A’s business partners, contractors and service providers, including web hosting providers, IT systems administrators, data storage providers, mailing houses, couriers, banks and payment processors, data entry service providers, electronic network administrators and debt collectors;
- BF&A’s professional advisors such as accountants, solicitors, business advisors and consultants;
- any person with whom BF&A may enter into any agreement for the merger or sale of all or part of BF&A’s business; and
- any other person or organisation notified to you.
We will not transfer your personal information outside Australia without your consent.
When you access the BF&A Site, cookies may be placed on your device. Cookies are small pieces of text stored on your device that help BF&A to identify you, determine which browser you are using, track your usage of the BF&A Site and to track your usage of other websites. Cookies also let BF&A relate your current usage of the BF&A Site to your prior usage.
You may not be able to access some parts of the BF&A Site if you choose to disable the cookie acceptance.
BF&A also logs all IP addresses of devices used to access the BF&A Site.
Your personal information may be held by BF&A in electronic form on BF&A’s systems or the systems of BF&A’s service providers and is protected by technological and procedural safeguards.
When BF&A does not need your personal information any more for the purposes for which it was collected, BF&A will delete, destroy or de-identify it unless there is a legal reason why BF&A needs to continue to hold that personal information.
BF&A may send you direct marketing communications and information about BF&A’s products and services that BF&A considers might be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with all applicable laws. If you indicate a preference for a method of communication, BF&A will endeavour to use that method wherever practicable to do so. You may opt out of receiving marketing communications from BF&A by contacting BF&A (see contact details in section 11) or by using the opt out facilities provided in the marketing communications.
You may request access to the personal information BF&A holds about you at any time by contacting BF&A (see contact details in section 11). BF&A will respond promptly to any request. There may be times when BF&A is unable to grant you access to your personal information, in which case BF&A will explain why when it notifies you that is it not able to provide that personal information.
If you believe that the personal information BF&A hold about you is incorrect, incomplete or inaccurate, you may request BF&A (see contact details in section 11) to amend its records. BF&A will respond promptly to your request. If BF&A does not agree that the personal information should be amended, BF&A will add a note to your personal information held in BF&A’s records stating your disagreement.
BF&A will not charge you for providing access to your personal information held by BF&A or for making any amendments to that personal information.
BF&A will treat any request or complaint received from you confidentially. BF&A will contact you within a reasonable time after receipt of your request or complaint. If you have made a complaint, BF&A will, when it contacts you, outline options to resolve that complaint. BF&A aims to resolve all complaints promptly and, in any event, within 30 days of receipt.
If you have a complaint regarding the treatment of your personal information by BF&A that is not resolved by BF&A, you may be able to make a complaint to the Office of the Australian Information Commissioner, see https://www.oaic.gov.au/privacy/privacy-complaints/.