Praemium's Privacy Statement

Praemium Limited, ABN 74 098 405 826 and all its related entities may collect and use your personal information in operating this website and in providing services to you.

The Praemium privacy policy is aligned with the Privacy Act 1988 and the Australian Privacy Principles (APPs).

Introduction

Praemium provides financial services, online portfolio administration and CRM services to our customers, who are intermediaries such as financial advisers, accountants, stockbrokers and investment or superannuation administrators, (“Advisers”).

The Praemium services and products include:

  • V-Wrap: a non-custodial investment service portfolio administration
  • SMA: a managed investment scheme
  • SuperSMA: Praemium acts as the sponsor of a superannuation fund
  • WealthCraft: a software application providing CRM and financial planning tools.
  • Personal information we collect from others
  • Generally, Praemium collects or holds personal information about you from Advisers who use the services.

Personal information includes the following:

  • Name, residential address, email address and your other contact details
  • Date of birth
  • Client ID
  • Gender
  • Source of funds, beneficiaries/control structures and politically exposed persons’ details
  • Details of investments and investment transactions
  • Bank account number
  • Other details or notes that an Adviser may record in respect to giving financial product advice or administering your investment portfolio
  • Other details an Adviser may collect to manage your financial affairs, such as risk profiling or financial goals
  • Tax File Number (TFN), an individual’s tax residency status, an ABN
  • Information we collect
  • If your Adviser provides you with a login to Praemium’s applications we may collect information about your IP address or activity using Cookies.

We may collect or hold information about you that is publicly available, for example, data on the ASIC database.

Why do we collect and hold this information?
Praemium collects or holds this information in order to provide our services to you or to enable your adviser to perform various functions and services on your behalf.  We are also required by law to conduct customer due diligence checks under the AML CTF Act. Praemium cannot provide services to you or your adviser unless this information is collected.

Sensitive information
Praemium does not collect ‘sensitive information’ as defined in the Privacy Act.

Dealing with personal information

Using your personal information

Investors

Personal information is required to provide a service to you, such as:

  • To perform administrative and operational tasks
  • To consider certain concerns or complaints you may raise
  • To prevent or investigate suspected or actual fraud, misconduct or unlawful activity
  • To identify you
  • To comply with the Corporations Act, the AML CTF Act, Tax Act and the Privacy Act
    Advisers

We may disclose personal information we collect for the purpose of:

  • Meeting our AFS licence requirements
  • Collecting overdue payments
  • Providing information to any service providers we engage
  • Marketing material. (Unless you advise otherwise, Praemium may use your personal information for our marketing purposes. This includes contacting you by telephone, email or mail.)
  • Disclosing your personal information overseas
  • We may disclose information to related overseas entities for the purpose of providing internal support for our service and product offering. These entities are currently located in the United Kingdom, China, Hong Kong and Armenia and comply with Australian privacy requirements.  

As a backup, data may be hosted and stored in Microsoft cloud facilities located in Ireland and the Netherlands.

The Foreign Account Tax Compliance Act (FATCA) requires Praemium to collect and provide information about US investors who have investments in our SMA. This is lodged with the Australian Tax Office which may ultimately pass over to the US Government’s Internal Revenue Service.

Government related identifiers (GRI)

Praemium may collect or hold government related identifiers to provide its products and services to customers and investors. These include:

  • Tax file numbers
  • Driver licence numbers
  • Australian passport numbers
  • Praemium is permitted to use or disclose a GRI for an individual if we believe that it is reasonably necessary for one or more enforcement-related activities conducted by or on behalf of a body such as ASIC, Austrac or the Australian Federal Police.

Keeping personal information secure
Praemium has no reason to store hard copy documents, except for SMA investor instructions (including applications). All hard copy documents held by Praemium are stored securely and access is restricted.

Praemium protects personal information from misuse, interference, loss or unauthorised access; however, Praemium cannot be responsible for user access that an Adviser may permit or manage.

We use trusted third parties and our security safeguards include:

System security

  • All transmitted data is encrypted on secure networks.
  • Firewalls, intrusion detection systems and anti-malware/anti-virus tools.

Building security

  • Physical security measures are in place, including cameras and smartcards.

Staff education

  • Induction, training in policies and procedures (including clean desk).

Destroying data

  • We only keep information as long as we are legally bound to and use secure destruction processes.

Unsolicited information

  • We destroy or de-identify any unsolicited information.

Accessing your personal data
Where Praemium holds data, we create appropriate system access for your Adviser to keep your personal information accurate and up to date. For non-SMA products, your Adviser may also grant you access to update your data.

Where Praemium collects data for SMA we expect that an investor will generally ask their Adviser to correct inaccurate personal information. In rare cases this may not be appropriate and Praemium will respond promptly to requests for correcting personal information or supplying personal data after identifying you.

Making a privacy complaint
In the event an investor believes their privacy has been compromised, they should contact their Adviser first.

However, if you believe your privacy has been compromised by an action undertaken by Praemium, you can contact our client service team at [email protected] or by telephone on 1800 571 881.

If you feel that your complaint is not satisfactorily resolved, you should follow Praemium’s complaint procedure which is published on our website at www.praemium.com/guide-to-making-a-complaint.

Data Disclaimers & Copyright

Third Party Data Provider Disclaimers and Copyright Notices

This Service incorporates information sourced from Third Party Data Providers. Set out below are disclaimer and copyright notices of Third Party Data Providers that apply to their information. Not all end users of this Service will have access to information or data provided by all of the Third Party Data Providers listed below.

All Third Party Data Providers have exclusive proprietary rights in their respective information and data.

Third Party Data is provided by third parties beyond our control and we do not take responsibility for its content or for any delays, interruptions or errors in it.

General
The data is provided to end users of the Service on an "as is" basis. The Technology Owner, the Licensor, the Third Party Data Providers and any other third party involved in or related to the making or compiling of any of the data make no representations or warranties of any kind, either express or implied, with respect to the data (or the results to be obtained by the use thereof) including, without limiting the generality of the foregoing, any and all warranties of originality, accuracy, timeliness, completeness, non-infringement, merchantability and fitness for any particular purpose.

Each user of the Service assumes the entire risk of any use the end user may make of the data. In no event shall the Technology Owner, the Licensor, the Third Party Data Providers and any other third party involved in or related to the making or compiling of any of the data, be liable to the end user, or any other person, for any direct or indirect damages, including, without limitation, any lost profits, lost savings or other incidental or consequential damages arising out of this agreement or the inability of the customer to use the data, regardless of the form of action, even if licensee, any of its information providers, or any other third party involved in or related to the making or compiling of any of the data has been advised of or otherwise might have anticipated the possibility of such damages.

You shall not use or permit anyone to use the data for any unlawful or unauthorised purpose. You are not authorised or permitted to provide the data to any person or firm for reuse or retransmission without the prior written approval of the source of the data.

Access to the data is subject to termination in the event that any agreement between the Licensor and a provider of information or software distributed through the data is terminated in accordance with its terms. Set out below are specific disclaimers, limitations and copyright notices relating to specific Third Party Data Providers.

ASX Limited / ASX Operations Pty Ltd
Some of the material incorporated in the Service is copyright and is reproduced under licence by ASX Limited ACN 008 624 691 or its related companies. ASX Limited, its related companies and their officers employees are not associated with, and should not be construed as endorsing, promoting or expressing any opinion about, nor bear any liability for any loss arising in connection with the Licensor or the contents of the Service (or the contents of any other website to which one can link from the Service) or any of the Licensor's products or services.

ASX Limited, its related companies, their officers and employees shall not be liable in any way for any loss or damage, howsoever arising (whether in negligence or otherwise) and of or in connection with the contents of and/or any omission from this communication except where a liability is made non-excludable by legislation.

The ASX Logo, "All Ordinaries ASX®' and 'ASX®' are registered trademarks of ASX Operations Pty Limited.

Aspect Huntley
If you are a 'retail client' (as that term is defined in the Corporations Act 2001) and you access information provided by Aspect Huntley you are hereby informed that information regarding Huntley's Investment Information Limited ABN 95 090 665 544 / AFSL 240892 (the providers of the Aspect Huntley Information) can be found on its website: www.aspecthuntley.com.au.

You acknowledge and agree that the information compiled and owned or licensed by Huntley's Investment Information Limited incorporated into the reports provided by it (the "Aspect Huntley Products") do not constitute the provision of 'personal advice' as that term is defined in the Corporations Act 2001 and the Corporation's regulations and that to the extent that is deemed to be 'general advice' under the same provisions, you acknowledge that (a) the information has been prepared without taking into account the objectives, financial situation or needs of any individual; (b) before making any investment decision, an individual should consider the appropriateness of the advice to their circumstances, and obtain specific financial, legal and taxation advice; and (c) all potential investors should obtain a Product Disclosure Statement (PDS) relating to the relevant investment product and consider the PDS before making any decision to invest.

You acknowledge and agree that all information, documents, software, materials, records, data or databases, ratings, concepts, inventions, conclusions, formulations designs, processes, frameworks, diagrams, thinking structures, protocols, models, branding, know-how and analyses which relate to or are derived from the business activities of Huntley's Investment Information Limited or the Aspect Huntley Products

Huntley's Investment Information Limited will not be liable to any person for any loss, damage, cost, expense or other claim (including consequential damages and loss of profits) in relation to Products including, without limitation: (a) any use or reliance on the Aspect Huntley Products by the person (including the form and content of errors in and/or omissions from any information contained in a product); (b) any delay, interruption or other failure in the provision of a product; or (c) any change in the form or content of the products.

Dow Jones
Data that is provided by Dow Jones & Company, Inc ("Dow Jones") is provided "as is". Neither the Licensor, Dow Jones or any third party shall be liable to you or any third party for any loss or damage, direct, indirect or consequential arising from (a) any inaccuracy or incompleteness in, or delays, interruptions, errors or omissions in the delivery of the data or any other information supplied to you through our Services; (b) any decision made or action taken by you or any third party in reliance upon the data. Nor shall we, Dow Jones or any third party be liable for loss of business revenues, lost profits or any punitive, indirect, consequential, special or similar damages whatsoever, whether in contract, tort or otherwise, even if advised of the possibility of such damages incurred by you or any third party.

You may only use the data and information provided by Dow Jones for your own personal and non-commercial purposes while accessing our Services. You may not copy, distribute or redistribute the data, including by caching, framing or similar means or sell, resell, re-transmit or otherwise make the data retrieved from our services available in any manner to any third party. You may not store the data for the purposes of creating a historical database or historical data product. You may not use any of the data in connection with the issuance, trading, marketing or promotion of investment products (e.g., derivatives, structured products, investment funds, investment portfolios, etc. where the price, return and/or performance of the investment product is based on or related to the data) without a separate written agreement with Dow Jones.

NASDAQ
You acknowledge and agree that the NASDAQ Companies have (a) proprietary rights in the information and data that originates on, derives from or relates to markets that are regulated, operated or administered by one or more of the NASDAQ Companies, in the information and data that relates to individuals and entities that are regulated by one or more of the NASDAQ Companies, and in the information and data that relates to activities that are regulated or operated by one or more of the NASDAQ Companies; (b) compilation or other rights in information and data gathered from other sources. All information provided by any NASDAQ Company, including without limitation any and all intellectual property rights inherent therein or appurtenant thereto, shall, as between the parties, be and remain the sole and exclusive property of NASDAQ. You shall not, by act or omission, diminish or impair in any manner the acquisition, maintenance, and full enjoyment by NASDAQ, its licensees, transferees and assignees, of the proprietary rights of NASDAQ in that information.

Nikkei
You acknowledge and agree that any and all intellectual property rights and any other rights in and to the Nikkei Indices are solely owned by Nikkei Inc ("Nikkei") and distributed by Nikkei Digital Media, Inc ("NDM"). "© Nikkei Inc."

You must not make any deletion, addition, alternation or any other changes to and from the content or format of the Nikkei Indices.

The Licensor, Nikkei and/or NDM do not warrant the accuracy and completeness of the Nikkei Indices.

The Licensor, Nikkei and/or NDM shall not be liable to you for any decision made or action taken by you in reliance upon the Nikkei Indices. You shall indemnify and hold harmless the Licensor, Nikkei and NDM from and against any damages or troubles arising out of your usage of the Nikkei Indices

Reuters
Reuters content is the intellectual property Reuters. Any copying, republication or redistribution of Reuters content, including by caching, framing or similar means, is expressly prohibited without the prior written consent of Reuters. Reuters is not liable for any errors or delays in content, or for any actions taken in reliance on any content. Data is provided for information purposes only and is not intended for trading purposes. The RIC or Reuters Instrument Code set has been developed and maintained by Reuters and is the intellectual property of Reuters. Reuters and Reuters sphere logo are trademarks or registered trademarks of the Reuters group of companies around the world. For additional information on other Reuters services, please visit the Reuters public website and www.reuters.com.

Standard & Poor's (for GICS)
The Global Industry Classification Standard (GICS) was developed by and is the exclusive property of Morgan Stanley Capital International Inc. and Standard & Poor's. GICS is a service mark of MSCI and S&P and has been licensed for use by the Technology Provider for incorporation in the Service.

Standard and Poor's Australia Index Alert
Select data is provided by Standard and Poor's a division of The McGraw-Hill Company, Inc. Copyright 2007, all rights reserved. Either the Licensor, Standard and Poor's, their affiliates or third-party licensors have exclusive proprietary rights in the data, any information and software received. Such data is for your internal use only.

Copyright ©2007, Standard and Poor's, a division of the McGraw-Hill Companies, Inc. Standard & Poor's including its subsidiary corporations ("S&P") is a division of The McGraw-Hill Companies Inc. Reproduction of S&P Australia Index Alert in any form is prohibited except with the prior written permission of S&P. Because of the possibility of human or mechanical error by S&P's sources, S&P or others, S&P does not guarantee the accuracy, adequacy, completeness or availability of any information and is not responsible for any errors or omissions or for the results obtained from the use of such information. S&P GIVES NO EXPRESS OR IMPLIED WARRANTIES, INCLUDING, BUT NOT LIMITED TO ANY WARRANTIES OR MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE. In no event shall S&P be liable for any indirect, special or consequential damages in connection with subscriber's or others' use of S&P Australia Index Alert 2007.

Hang Seng
The information referred to in this section is provided by Hang Seng Indexes Company Limited. Neither Hang Seng Indexes Company Limited nor any of its holding companies and subsidiaries nor the Licensor provides any warranties of any kind in relation to such Information (including, without limitation, that the Information is fit for a particular purpose) or accepts any responsibilities for its accuracy, completeness and/or consistency, or for any loss or damage whatsoever and howsoever suffered or incurred by any party. With the use of or the access to the Information referred to in this section, the subscriber or any party irrevocably and unconditionally accepts and agrees to be bound by this disclaimer.

Glossary
In these disclaimers and notices, a reference to:

the "Licensor" is a reference to Præmium Australia Pty Ltd ACN 117 611 784 which provides the Service either alone or with another provider named in the end user licence agreement between the end users of the Service and the Service Providers.

  • The "Technology Provider" is a reference to Praemium Limited ACN 098 405 826, the owner of the proprietary technology used by the Licensor to deliver the Service;
  • The "Service" is a reference to V-Wrap™, and/or any of the components of the V-Wrap Service, including but not limited to V-Wrap Adviser, and/or V-Wrap Investor whether or not distributed under the V-Wrap™ brand or any other name or branding;
  • "Data" means any data which is accessed through the use of the Service; and
  • "Third Party Data" means Data that is supplied by a person other than the Licensor, including, but not limited to ASX Limited, ASX Operations Pty Ltd, Aspect Huntley, Dow Jones, NASDAQ, Nikkei, Reuters, Standard & Poors, and Hang Seng.
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