Privacy Policy

OUR COMMITMENT

Wealthy & Wise Lifestyle Planning Pty Ltd (ABN 74 622 374 501), trading as Wealthy & Wise ("Wealthy & Wise", "we", "us" or "our"), is a Corporate Authorised Representative (No. 1259510) of Lifestyle Asset Management Pty Ltd (ABN 58 113 067 968) ("LAM"), Australian Financial Services Licence 288421. Wealthy & Wise and LAM are committed to handling personal information openly, securely and in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This policy explains the kinds of personal information we collect and hold, how we collect, use, disclose and protect it, and how you can access or correct it or make a privacy complaint. It should be read together with any collection notice, consent form or Financial Services Guide given to you when information is collected.

WHO THIS POLICY APPLIES TO

This policy applies to personal information we handle in connection with financial advice, insurance, superannuation, investment and related services. It also applies to people who visit our website, respond to our advertising or make an enquiry with us, whether or not they become clients. Where services are provided under LAM's AFSL, information may also be provided to or accessed by LAM for licensing, compliance, supervision, complaints, audit and regulatory purposes.

WHAT INFORMATION WE COLLECT

The information we collect depends on the services you ask for and your relationship with us. For financial advice, complete and accurate information is usually needed so an adviser can understand your circumstances and give advice that suits your needs and objectives. It may include:

• identity and contact details, such as your name, date of birth, address, telephone number and email address;

• financial needs and objectives, assets and liabilities, income, expenses, cashflow and taxation information;

• superannuation, investment, banking, insurance and other financial product information;

• investment preferences, risk tolerance and attitudes to investment risk;

• employment history, occupation and current employment circumstances;

• family structure, dependants, commitments, estate planning information and social security eligibility;

• identity verification information and government related identifiers where collection is authorised or required by law;

• records of communications, meetings, instructions, advice, service requests and complaints;

• if you enquire online, the details you give us on an enquiry form, booking tool or chat, such as your name, phone number, email, postcode, the topic you are interested in and your answers to any questions; and

• other information reasonably relevant to the services you request.

SENSITIVE INFORMATION

Some services require sensitive information, particularly health or medical information for life insurance advice, underwriting or claims. We generally collect sensitive information only with your consent and where it is reasonably necessary for the service, or where otherwise authorised or required by law.

HOW WE COLLECT INFORMATION

We usually collect personal information directly from you, in meetings and phone calls, by email, through fact finds, forms, online portals, questionnaires, digital signatures and other communications. From time to time we may ask you to confirm or update your information.

With your authority, or where otherwise permitted by law, we may also collect information from third parties such as product providers, superannuation funds, insurers, platforms, banks, accountants, solicitors, employers, government agencies, referral partners, LAM and service providers supporting the advice process.

If you choose not to give us information relevant to the advice or service you ask for, we may not be able to provide it, or the advice may be limited. Your adviser will explain any material limitation.

ONLINE ENQUIRIES, SOCIAL MEDIA AND OUR WEBSITE

Many people first contact us online. This section explains what happens to your information when they do.

• Facebook and Instagram. If you respond to one of our ads on Facebook or Instagram and complete a lead form, Meta Platforms collects the details you enter and passes them to us. Meta's own handling of your information is governed by Meta's privacy policy.

• Website forms, bookings and chat. If you complete a form, book a call or use the chat on our website, we receive the details you provide.

• Our CRM. Enquiry details are stored in our customer relationship management (CRM) system so we can respond to you, keep a record of our contact with you and manage any appointment.

• Cookies and tracking. Our website and advertising platforms may use cookies, pixels and similar technologies to operate the site and measure how our ads perform. You can manage cookies through your browser settings and manage ad preferences through your Meta account settings.

We use enquiry information to respond to your enquiry, arrange an initial meeting and follow up with you. We do not sell your personal information.

HOW WE CONTACT YOU, AND OPTING OUT

After you make an enquiry, we may contact you by phone, SMS or email to respond, arrange or remind you of an appointment, and follow up. Where we send marketing messages by SMS or email, we do so only with your consent or as otherwise permitted by the Spam Act 2003 (Cth). Every such message identifies Wealthy & Wise and includes a way to unsubscribe.

You can opt out of marketing at any time by:

• replying STOP to an SMS;

• using the unsubscribe link in an email;

• telling us when we call; or

• contacting us using the details at the end of this policy.

We will action an opt-out within five business days. Opting out of marketing does not stop service communications we need to send to administer your relationship with us, such as appointment confirmations or communications about advice you have received.

WHY WE COLLECT, USE AND DISCLOSE INFORMATION

We collect, hold, use and disclose personal information for the purpose for which it was collected, for related purposes you would reasonably expect, where you have consented, or where use or disclosure is authorised or required by law. Common purposes include:

• responding to your enquiry and arranging an initial meeting;

• understanding your circumstances, needs, objectives and preferences;

• preparing financial strategies, Statements of Advice, Records of Advice and other advice documents;

• providing, implementing and reviewing financial advice;

• obtaining product research, quotations, pre-assessments and underwriting outcomes;

• establishing, varying, administering or reviewing investments, superannuation and insurance arrangements;

• communicating with you, providing ongoing service and, where permitted, telling you about services that may be relevant to you;

• managing complaints, claims, remediation and dispute resolution;

• meeting legal, regulatory, licensing, professional, audit and record keeping obligations;

• identity verification, fraud prevention, information security and risk management; and

• business administration, service improvement, quality assurance, training and supervision.

WHO WE MAY DISCLOSE INFORMATION TO

Depending on the service, personal information may be disclosed to LAM and its compliance and professional standards functions; product issuers and platform providers; insurers and underwriting providers; superannuation trustees; investment managers; banks; government agencies and regulators; the Australian Financial Complaints Authority (AFCA); professional advisers; and contracted administration or paraplanning providers.

We also use service providers to run our business, including CRM, email and SMS providers, appointment booking and website hosting providers, document storage and secure cloud providers, and social media and advertising platforms. These providers handle personal information on our behalf and only for the purpose of providing their services to us. We may also disclose information where required by a court, tribunal, regulator or Australian law.

OVERSEAS DISCLOSURE

Some of our service providers store or process personal information outside Australia. Information you give through Facebook or Instagram lead forms is processed by Meta Platforms, which operates outside Australia. Our CRM, email, SMS and website providers may also store or process information outside Australia. Where personal information is disclosed overseas, we take reasonable steps under the APPs, including through contractual and licensee controls, to protect it. You can contact us for more information about current overseas arrangements.

AUTOMATED DECISIONS

We do not use computer programs to make decisions about you that could reasonably be expected to significantly affect your rights or interests. Our systems may automatically sort enquiries and send confirmations and reminders, but decisions about advice, recommendations and services are made by our advisers.

DATA QUALITY AND SECURITY

We take reasonable steps to make sure the personal information we collect, use and disclose is accurate, up to date, complete and relevant. Please tell us if your details change or you think something we hold is wrong.

Personal information is generally held in electronic client files, financial planning and CRM systems, secure document repositories and other approved business systems, and occasionally in paper records. We protect it using reasonable technical, physical and organisational safeguards, including:

• restricted, role based access to client information;

• passwords, authentication and other access controls;

• secure systems, backups and approved storage arrangements;

• confidentiality obligations for staff, advisers and contracted providers;

• staff training, supervision and information handling procedures; and

• incident response and escalation processes for suspected privacy or cyber security events.

DATA BREACHES

If we become aware of a suspected loss of, or unauthorised access to or disclosure of, personal information, the incident will be assessed and escalated under Wealthy & Wise and LAM procedures. Where an eligible data breach is identified under the Notifiable Data Breaches scheme, affected individuals and the Office of the Australian Information Commissioner (OAIC) will be notified as the Privacy Act requires.

RETENTION AND DESTRUCTION

Financial services records are subject to legal, regulatory and licensee retention requirements. Client information will generally be kept for at least seven years after the relevant advice, transaction or end of the client relationship, and longer where required for legal, regulatory, complaint, insurance, litigation or audit purposes. Enquiry information for people who do not become clients is kept only as long as reasonably needed. When information is no longer needed and there is no legal requirement to keep it, we take reasonable steps to destroy or de-identify it.

ACCESS AND CORRECTION

You may ask for access to the personal information we hold about you. We may ask you to verify your identity or authority. Subject to the Privacy Act, access may be given by copies, electronic access, inspection or an accurate summary. There is no charge to make a request. If a reasonable charge applies to providing access, we will tell you first. We aim to respond within 30 calendar days.

The Privacy Act allows access to be refused in some circumstances, for example where it would unreasonably affect another person's privacy, create a serious safety risk, prejudice enforcement activity or be unlawful. If we refuse access, we will give written reasons where required and explain your complaint options.

If you believe information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to correct it. There is no charge, and we aim to respond within 30 calendar days.

IDENTIFIERS, IDENTITY VERIFICATION AND ANONYMITY

We will not adopt a government related identifier, such as a Tax File Number or Medicare number, as our own identifier for you, except where permitted by law. We may need to verify your identity before providing certain products or services, including under anti-money laundering and counter-terrorism financing laws and product provider requirements.

Where lawful and practicable, you may deal with us anonymously or using a pseudonym, for example when making a general enquiry. This is usually not practicable for financial advice, insurance, superannuation or investment services.

PRIVACY COMPLAINTS

If you believe we, or someone acting for us, have breached this policy or the APPs, please contact us. Tell us what happened, when, the information involved and the outcome you are seeking. You may complain verbally or in writing. We will acknowledge your complaint promptly, investigate it fairly and aim to give a substantive response within 30 calendar days. If we need more time, we will tell you why and keep you informed.

If you are not satisfied with our response, or have not heard from us within a reasonable time, you can escalate your complaint:

• Australian Financial Complaints Authority (AFCA): www.afca.org.au, 1800 931 678, [email protected], GPO Box 3, Melbourne VIC 3001.

• Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au, 1300 363 992. The OAIC generally expects you to complain to us first and allow a reasonable time to respond.

CONTACT US

Privacy and Compliance Officer

Wealthy & Wise Lifestyle Planning Pty Ltd (ABN 74 622 374 501)

Level 35, One International Towers, 100 Barangaroo Avenue, Sydney NSW 2000

Phone: 1300 226 271

Email: [email protected]

You can also contact our licensee, Lifestyle Asset Management Pty Ltd (ABN 58 113 067 968), at the same address, phone and email.

POLICY REVIEW

This policy is reviewed at least annually, and earlier where our information handling practices, service providers, technology, LAM requirements or privacy law materially change. The current version is always available free of charge on our website or on request. This policy operates with the Privacy Act 1988 (Cth), the APPs, the Financial Planners and Advisers Code of Ethics 2019, applicable financial services laws and LAM's privacy, cyber security and compliance procedures.

Wealthy & Wise Lifestyle Planning Pty Ltd, ABN 74 622 374 501, trading as Wealthy & Wise, Corporate Authorised Representative No. 1259510 of Lifestyle Asset Management Pty Ltd, ABN 58 113 067 968, AFSL 288421.