Privacy

We, the FSP Group, are committed to protecting your privacy, whether any personal information that we collect from and about you is provided in written form, verbally or over the internet. The FSP Group is FSP Group Pty Limited and its subsidiaries.

In collecting and handling your personal information, we abide by the National Privacy Principles ("NPPs") established under the Privacy Act 1988 (Cth). You can obtain information about the NPPs and your privacy rights at the Privacy Commissioner's website at www.privacy.com.au.

Please read the following to understand how we will treat your personal information.

What personal information do we collect?

The precise information collected depends on which service or product you request and which FSP Group company is providing that service or product. In general, we only collect personal information required to enable the relevant company to provide you with the relevant product or service you have requested and to manage and administer that product or service. This will usually include at least your name, address and contact details and may also include:

- for FSP Portfolio Administration Limited (“FSPPA”) and FSP Super Pty Limited (“FSPS”) bank account details, tax file number ("TFN") which they are authorised to do by the Income Tax Assessment Act 1936 and, in the case of FSPS, the Superannuation Industry (Supervision) Act 1993. It is not compulsory for you to provide your TFN, but if you don't, under taxation law you may have tax deducted from your income at the highest marginal rate, or you may be required to pay more tax on your benefits than you would otherwise have to, or a surcharge may become payable on your superannuation contributions;

- for FSPS: If you wish to apply for insurance through FSPS, personal and sensitive information such as details of physical characteristics, occupation, health and medical history is collected, but only with your express consent.

How do we collect personal information?

We primarily collect your personal information via particular forms, such as investment applications, TFN Notifications, Direct Debit Requests, Transfer Requests, Personal Reviews and other such forms which we generally either receive directly from you or via your financial adviser or accountant. Occasionally, we collect information through telephone or e-mail enquiries about our products or services. We may also receive notice from your financial adviser or accountant of changes to the personal information that we hold which we use to update that information.

If you are rolling over your superannuation to the FSP Super Fund, FSPS may receive personal information from the trustee of that superfund.

For what purposes do we collect personal information?

We ask you for personal information that is necessary for us to adequately provide to you the products or services you have requested. This may include, depending on the relevant FSP Group company:

- processing your product application forms
- managing and administering your products (including providing distributions and reporting)

We may use your contact details to let you know about other products or services we offer, or about developments within or affecting the companies in the FSP Group. If you do not wish to receive such communications, you can let us know by e-mailing or telephoning us at the address or number below.

Unless you provide an e-mail address in the course of your visit to an FSP Group company web site, that company cannot identify you.

To whom do we disclose personal information?

As FSPS and FSPPA respectively outsource the administration of the FSP Super Fund, FSP Prestige Plus and other products, they need to disclose the personal information provided on application forms for these products to the Administrator named in the relevant Product Disclosure Statement, or Guide.

If you have applied for insurance, FSPS will pass your application forms and any other related personal information to the insurance provider, as named in the current offer document for FSP Super Fund.

Other types of persons to whom an FSP Group company may disclose your personal information include, depending on the company, your financial adviser, your accountant, the Australian Taxation Office pursuant to the Superannuation Contributions Tax (Assessment and Collection) Act 1997 (in order to assess any surcharge), or another superannuation fund or retirement savings account provider. If you have applied for insurance, FSPS will disclose your health or sensitive information to the insurance provider named in the current offer document for FSP Super Fund (who assesses your insurance application and provides the insurance), and may disclose that information to medical professionals and investigation authorities for the purpose of an investigation or assessment of any claim.

To assist in administration, including tasks like monitoring, regulatory compliance auditing and complaints handling, a company within the FSP Group may share personal information with another FSP Group company.

Limitations on use and disclosure of personal information

No FSP Group company will use or disclose your personal information for any purpose other than as set out above, except if the information is not sensitive information, for a related purpose in circumstances where you would reasonably expect such use or disclosure, or where you have consented to such use or disclosure, or in circumstances otherwise authorised by the NPPs.

Accessing information online

The usage of the Investor Access and FSP Link areas of this Site may be monitored and this information may be provided to your adviser or their related parties or members of the FSP Group. Personal information is only provided as set out in the User Agreement for these areas.

Cookies

The web sites of FSP Group companies use cookies which allow them to identify your browser while you are using their site. Cookies do not identify you; they simply allow tracking of usage patterns so that the level of interest in various areas of a site can be measured. Most web browsers are set up to accept cookies. You can re-set your browser to refuse all cookies or to receive a warning message with each cookie which you can then refuse by turning it off in your browser. Your internet service provider should be able to assist you to set your preferences.

The security of your personal information

FSP Group will take reasonable commercial steps to ensure that all information we collect, use or disclose is stored in a secure environment accessed only by authorised persons. We will, where commercially practicable and permitted by law, destroy or permanently de-identify personal information that is no longer needed.

How you can correct your personal information

If you believe that the personal information we hold about you is inaccurate, incomplete or not up-to-date please let us know.

How you can access your personal information

On request, you may have access to your personal information held by FSP Group, except in circumstances where access may be denied under the Privacy Act or other law. If personal information is provided to you as the result of a request, you may be charged a fee for costs incurred in providing that information such as photocopying, administration and postage. If access is denied we will provide you with reasons for our decision.

Will this privacy policy change?

We reserve the right to change this privacy policy at any time by publishing the varied privacy policy on our Site. You accept that by doing this, FSP Group has provided you with sufficient notice of the variation and agree you will be provided with no separate notification.

Making a complaint

If you have a complaint about the treatment by an FSP Group company of your personal information, you should contact the relevant person set out below. Depending on the complexity of your complaint, your complaint should be considered and respond to within 7-30 days. We will use our best endeavours to resolve any complaint to your satisfaction. However, if you are not satisfied with our response, you are entitled to contact the Office of the Privacy Commissioner who may investigate your complaint further.

Contacting us about privacy and your personal information

FSP Group Pty Limited and all its subsidiaries
The Privacy Manager
Level 34, Australia Square, 264-278 George Street,
Sydney, NSW, 2000
Phone (02) 9253 8500
Fax (02) 9253 8616
E-mail info@fspgroup.com.au