Privacy Policy
Privacy Policy
This Privacy Policy applies to CFG Advice Pty Ltd ABN 62 621 016 055, Australian Financial Services Licence No. 501857, and its representatives, including Cranage Private Wealth Pty Ltd ABN 97 007 009 903, Corporate Authorised Representative No. 260866. It explains how we collect, hold, use and disclose personal information. We are bound by the Privacy Act 1988 (Cth), the Australian Privacy Principles and applicable privacy laws.
Why we handle personal information
- Provide financial products, financial advice and related services.
- Understand your circumstances, objectives and needs.
- Verify identity and comply with legal, regulatory and record-keeping obligations.
- Administer client relationships, fees, complaints, audits, training and business operations.
- Arrange services provided by product providers, platforms, software providers, paraplanners, administrators and professional advisers.
- Protect clients, systems and our business from fraud, misuse and cyber threats.
- Communicate about services that may be relevant to you, subject to applicable marketing laws and your opt-out rights.
Information we may collect
The information collected depends on the service and may include your name, contact details, date of birth, family information, employment, residency and citizenship status, financial circumstances, assets, liabilities, income, expenses, taxation information, investment and superannuation details, insurance information, objectives, preferences and instructions.
Where reasonably necessary and permitted by law, we may collect sensitive information, including health and lifestyle information relevant to insurance advice. We may also collect government-related identifiers where authorised or required by law or needed to verify identity.
How we collect information
We usually collect information directly from you through meetings, telephone calls, email, secure portals, forms, identification processes, financial planning tools and documents you provide. We may also collect information from a person you authorise, your adviser or broker, product providers, platforms, accountants, solicitors, medical professionals, public sources and other organisations involved in providing services to you.
If you do not provide information
You may choose not to provide personal information. However, we may be unable to verify your identity, provide appropriate advice, implement recommendations or provide requested services. In some circumstances, we must decline to provide a service if required information is unavailable.
Anonymity and pseudonymity
You may deal with us anonymously or using a pseudonym where lawful and practicable. Financial advice, identity verification and other legal obligations will often require us to know your identity.
Use and disclosure
Where we refer you to another service provider, we will not disclose your personal information to that provider unless you have authorised the disclosure or the disclosure is otherwise permitted or required by law.
We use and disclose personal information for the purpose for which it was collected, for related purposes you would reasonably expect, with your consent, or where required or authorised by law. Recipients may include:
- CFG Advice Pty Ltd representatives and related bodies corporate involved in providing or supporting services.
- Financial product providers, platforms, insurers, banks and payment organisations.
- Financial planning software providers, secure document and identity-verification providers, paraplanners and administration providers.
- Auditors, compliance consultants, information technology and cybersecurity providers, legal advisers, insurers and dispute-resolution bodies.
- Government agencies, regulators, courts and law-enforcement bodies where required or authorised by law.
- A new Australian Financial Services Licensee or servicing entity in connection with an adviser or business transition, where permitted by law and following any required notice, consent or other process.
Overseas access and disclosure
Our administration and paraplanning service providers may operate in, or access personal information from, the Philippines. Our other approved technology and service providers are located in Australia. Whether information is accessed remotely or stored overseas depends on the relevant provider and service arrangement.
Before using an overseas provider, we take reasonable steps appropriate to the circumstances to assess privacy and security arrangements and to require confidentiality, access controls and appropriate handling of personal information. Your adviser may use other overseas providers and, where required, will provide additional information about relevant countries or seek consent.
Technology, automation and artificial intelligence
We may use approved technology, automation and artificial intelligence tools to support administrative work, meeting records, document preparation, quality assurance and service delivery. Use of these tools is subject to access controls, privacy and security requirements, and human oversight.
We do not use automated systems to provide personal financial advice or to make decisions that could reasonably be expected to significantly affect your rights or interests.
Direct marketing
We may use your contact details to provide information about services that may be relevant to you where permitted by law. You may opt out at any time by contacting us or using an unsubscribe facility.
Access and correction
You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond within a reasonable period. We may charge reasonable costs for providing access, but not for making a request or correcting information. If access or correction is refused, we will generally give written reasons and explain how to complain, where required by law.
Security and retention
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include multi-factor authentication, access restrictions, encryption, secure portals, endpoint and network security, monitoring, staff training, vendor due diligence, confidentiality obligations, incident response and data breach response procedures.
We retain records for the periods required by law and for legitimate business purposes. When information is no longer required, we take reasonable steps to destroy it or permanently de-identify it, unless retention is required or authorised by law.
Website and cookies
When you use our website, we may collect technical information through cookies, log files, web beacons and similar technologies. This may include IP address, device and browser information, referring pages, pages visited, date and time, and approximate country location. We use this information for website operation, security, analytics, troubleshooting and service improvement. You can manage cookies through browser or website settings, although disabling some cookies may affect functionality.
Data breaches
We maintain procedures for responding to suspected or actual data breaches. Where we suspect an eligible data breach may have occurred, we will carry out a reasonable and expeditious assessment and take reasonable steps to complete the assessment within 30 days. If an eligible data breach has occurred, we will notify the Office of the Australian Information Commissioner and affected individuals as soon as practicable, unless an exception applies.
Privacy questions and complaints
We will acknowledge your privacy complaint promptly, investigate it fairly and provide a response within a reasonable period. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner. Where the complaint also concerns financial services provided by us, you may have the right to complain to the Australian Financial Complaints Authority.
Mail Privacy Officer, PO Box 534, Flinders Lane VIC 8009
Phone 03 9097 6000
Email info@cfgadvice.com.au
Website www.cranagegroup.com.au
OAIC 1300 363 992 | enquiries@oaic.gov.au | www.oaic.gov.au
AFCA 1800 931 678 | info@afca.org.au | www.afca.org.au