1. What This Policy Is About
This privacy policy explains how Ascendancy Planning ("the Firm", "we", "our" or "us") collects, uses, stores, and shares your personal information. We are a financial advisory firm based in Queensland, Australia.
We take your privacy seriously. We handle your personal information in line with the Privacy Act 1988 (Cth) ("Privacy Act") and the thirteen Australian Privacy Principles ("APPs") set out in that Act. We also follow the obligations that apply to us under the Corporations Act 2001 (Cth) ("Corporations Act"), including the best interests duty and record-keeping requirements set by the Australian Securities and Investments Commission ("ASIC").
Where the Financial Planners and Advisers Code of Ethics 2019 ("Code of Ethics") sets standards that relate to handling your information, we follow those too.
2. Who This Policy Applies To
This policy applies to all persons and entities who interact with the Firm. This includes individuals (also referred to as "natural persons"), companies, trusts, partnerships, and any other type of entity.
If you are acting as a representative of an entity — for example, a director of a company or a trustee of a trust — this
policy also covers the personal information you provide to us in that capacity.
It applies whether you are a prospective client who has made an enquiry, a person referred to us by a third party, or an existing client who has formally engaged our services.
3. What Kind of Information We Collect
We may collect a range of personal information depending on the nature of our engagement with you. Personal information is any information that can identify you or could reasonably be used to identify you.
Identity information: This includes your full name, date of birth, residential address, postal address, telephone numbers, and email addresses.
Financial information: This may include details about your income, expenses, assets (such as property, investments, and superannuation balances), liabilities (such as loans and debts), insurance policies, tax file number, and bank account details.
Employment and business information: This may include your occupation, employer details, business interests, and professional qualifications.
Personal circumstances: Depending on the advice you seek, we may collect information about your family situation, health, estate planning arrangements, and retirement goals.
Identification documents: We may collect copies of documents such as your driver's licence, passport, Medicare card, or other government-issued identification for the purpose of verifying your identity.
Technical information: When you visit our website or use our digital client portals, we may collect your Internet Protocol ("IP") address, browser type, device information, and details about how you interact with our online resources.
In some cases, we may collect sensitive information as defined under the Privacy Act — for example, health information that is relevant to an insurance application or financial plan. We will only collect sensitive information with your consent, or where we are required or permitted to do so by law.
4. How We Collect Your Information
We collect your information in several ways. In most cases, we collect information directly from you. This can happen through the following channels:
In writing: Through email correspondence, online forms, fact-finding questionnaires, and documents you provide to us.
By phone or video call: During telephone calls or video conferences. Please be aware that we may record phone and video calls for quality assurance, training, or compliance purposes. Where we do so, we will take reasonable steps to let you know.
In person: During face-to-face meetings, whether at our offices or another agreed location.
Through our websites and digital tools: When you use our website, client portals, or other digital resources, certain technical information may be collected automatically.
We may also collect information about you from third parties, including:
Referral partners: If you have been referred to us by an accountant, solicitor, mortgage broker, or another professional, they may share relevant information about you with us to help us understand your needs.
Government and public databases: We may obtain information from official sources such as the Australian Securities and Investments Commission ("ASIC"), the Australian Taxation Office ("ATO"), land titles registries, company registers, and other public records.
Financial product providers: We may collect information from superannuation funds, insurance companies, banks, and other product providers that hold your financial products.
When we collect your information from a third party, we will take reasonable steps to make sure you are aware that we have done so.
5. Why We Collect and Use Your Information
We collect and use your personal information for purposes that are directly connected to providing our services to you. The main reasons we collect your information are:
To scope and assess your needs: When you first make contact with us or are referred to us, we need to understand your financial situation and goals so we can work out how we can help you.
To provide financial advice and services: We use your information to prepare Statements of Advice, Records of Advice, financial plans, and other documents that form part of the services you have asked us to provide.
To carry out research and analysis: As part of preparing advice, we may need to research financial products, model different scenarios, and analyse your financial position.
To meet our legal and regulatory obligations: We are required to comply with obligations under the Corporations Act, the Privacy Act, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) ("AML/CTF Act"), and other laws that apply to our business. This includes meeting our best interests duty and our record-keeping obligations.
To communicate with you: We use your contact details to keep you informed about your financial affairs, to send you relevant updates, and to respond to your enquiries.
To manage our business: We may use your information for internal purposes such as training, quality assurance, complaint handling, and improving our services.
6. Verifying Your Identity and Your Information
We may need to verify your identity before we can provide services to you. This is both a regulatory requirement and a professional obligation. Under the AML/CTF Act and our obligations as an Australian Financial Services ("AFS") licensee, we must take reasonable steps to confirm who you are.
Identity verification may involve asking you to provide original or certified copies of documents such as a passport, driver's licence, or other government-issued identification. We may also use electronic verification services.
In addition, as part of scoping, processing, or otherwise discharging our professional duties, we may verify information you have provided to us about your financial position. This may include verifying details related to properties, assets, liabilities, superannuation balances, or other financial matters that you have told us about. We do this to make sure the advice we give you is based on accurate and up-to-date information.
7. Information From Your Use of Our Websites and Digital Tools
When you visit our website or log in to a client portal, we may collect certain technical information automatically. This can include your IP address, the type of browser you are using, the pages you visit, the time and date of your visit, and how long you spend on each page.
We may use cookies or similar technologies to help us understand how people use our website and to improve your experience. A cookie is a small data file that is stored on your device when you visit a website.
You can adjust your browser settings to refuse cookies or to alert you when a cookie is being sent. However, some parts of our website or client portal may not work properly if you disable cookies.
8. How We Store and Protect Your Information
We take the security of your personal information seriously. We use a combination of physical and electronic security measures to protect your information from misuse, loss, unauthorised access, modification, and disclosure.
Your information is stored in secure systems, which may include cloud-based platforms and digital storage services operated by trusted providers. Where we use third-party services to store information, we take reasonable steps to satisfy ourselves that those providers have appropriate security measures in place and comply with relevant Australian privacy requirements.
Access to your personal information within the Firm is restricted to staff and professionals who need it to carry out their duties.
9. How Long We Keep Your Information
We keep your personal information for as long as it is reasonably needed for the purpose for which it was collected, and for any period required by law.
As a financial advisory firm, ASIC requires us to keep records of personal advice provided to retail clients for a minimum of seven (7) years after the day the advice was provided. This obligation is set out in ASIC Corporations (Record-Keeping Requirements for Australian Financial Services Licensees when Giving Personal Advice) Instrument 2024/508 and the Corporations Act.
Other records, such as those relating to our AFS licence obligations and general financial records, must be kept for at least seven (7) years under the Corporations Act.
Once information is no longer required, we will take reasonable steps to destroy it or ensure it is de-identified, in line with Australian Privacy Principle 11.2.
10. Sharing Your Information With Others
We will not sell your personal information to anyone. We may share your information with third parties only in the following circumstances:
Related business entities: We may share your information with related business entities, when the provision of services you sought or contracted with us requires actions (such as approvals), activities (such as compliance audits) or services from one or more other legal entities within the legal and commercial relations of Ascendancy Planning Pty Ltd. Such entities includes, but is not limited to, Bluewater Financial Advisors (Australian Financial Services License No. 411846).
We endeavour to pass on only the information necessary for the provision of our services and discharge of our contractual agreement with you.
Service providers: We may share relevant information with financial product providers, platform administrators, or other service providers in order to carry out the services you have asked us to provide.
Professional advisers: With your consent, we may share information with your accountant, solicitor, or other professional advisers to help coordinate your affairs.
Regulatory bodies: We may be required to share information with ASIC, the ATO, the Australian Financial Complaints Authority ("AFCA"), the Office of the Australian Information Commissioner ("OAIC"), or other regulatory authorities, where required by law.
Legal requirements: We may disclose your information where we are required to do so by an Australian law, a court order, or a tribunal.
Where we are required to share your information with a (unrelated) third party, we seek your express, written consent to do so, in advance. We take reasonable steps to ensure that the third party handles your information in accordance with the APPs.
11. Your Rights Regarding Your Information
Under the Privacy Act, you have the right to:
Access your information: You can ask us what personal information we hold about you and request a copy. We will respond to your request within a reasonable time.
Correct your information: If you believe that any personal information we hold about you is inaccurate, incomplete, or out of date, you can ask us to correct it.
Make a complaint: If you believe that we have breached your privacy, you can make a complaint to us. We will investigate and respond to your complaint in a timely manner. If you are not satisfied with our response, you may lodge a complaint with the OAIC.
To exercise any of these rights, please contact us using the details provided at the end of this policy.
12. Data Breaches and Information Security
In the event that a data breach occurs that is likely to result in serious harm to any individual whose information is involved, we will comply with our obligations under the Notifiable Data Breaches ("NDB") scheme set out in Part IIIC of the Privacy Act. This means we will notify the affected individuals and the OAIC as soon as practicable.
13. Changes to This Policy
We may update this policy from time to time to reflect changes in the law, our business practices, or the technology we use. Changes may be made without prior notice.
However, where changes are material, we will take reasonable steps to inform existing clients and persons we are engaged with, through common communication channels such as email.
The most current version of this policy will always be available on our website or upon request.
10. How to Contact Us
If you have any questions about this privacy policy or how we handle your personal information, please contact us or call 1300 317 437.