Legal and Compliance

Our Commitment to your privacy

Our Commitment
At Enva Australia we recognise that your privacy is important. We are committed to the highest standards in relation to the collection, use, accuracy and storage of your private information. We are bound by the Privacy Act 1988 which contains 13 principles known as the “Australian Privacy Principles”. Further information about the Australian Privacy Principles can be found on the website of the Office of the Australian Information Commissioner, www.oaic.gov.au.

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Collection
Our main purpose for collecting personal information is to facilitate financial planning, financial products or services, insurance policies or related services, and to update our records. At or before the time we collect personal information from you we will take reasonable steps to inform you why we are collecting that personal information, who else we might disclose that personal information to and what may happen if you do not provide personal information to us.

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Use and Disclosure
We are subject to certain legislative and regulatory requirements that necessitate us obtaining and holding detailed information that personally identifies you and/or contains information or an opinion about you. In addition, our ability to provide you with a comprehensive financial planning and advice service is dependent on us obtaining certain personal information about you, including:

• employment details and employment history;

• details of your financial needs and objectives;

• details of your investment preferences and aversion or tolerance to risk;

• details of your current financial circumstances, including your assets and liabilities (both actual and potential), income, expenditure, etc.

• information about your employment history, employment circumstances, family structure, commitments and social security eligibility;

• any other relevant information including medical history and/or reports required for the purposes of risk insurance.

As we operate throughout the world, some of these uses and disclosures may occur outside Australia. We may use the personal information collected from you for the purpose of providing you with direct marketing material such as articles that may be of interest to you. You may, by contacting us by any of the methods detailed in this policy statement, request not to receive such information and we will give effect to that request. Please allow two weeks for your request to be actioned.

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Data Quality
Pursuant to the Corporations Act, Life Insurance Code of Practice and Rules of Professional Conduct of the Financial Planning Association of Australia, we are required to collect sufficient information to ensure appropriate advice can be given in respect of recommendations made to our clients. If you elect not to provide us with the personal information you may be exposed to higher risks in respect of the recommendations made to you and this may affect the adequacy or appropriateness of advice given to you.

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Data Security
We take reasonable steps to protect the information we retain from misuse, loss and from unauthorised access, modification or disclosure. We will not retain any of your information for any longer than it is required by us, except to satisfy legal requirements. We will destroy or de-identify your personal information when it is no longer required.

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Openness
We may use and disclose personal information for the purposes for which it was provided or secondary purposes in circumstances where you would reasonably expect such use or disclosure. We may disclose personal information to third parties or external contractors carrying out functions and duties for and on behalf of Enva Australia Pty Ltd. It is a condition of our agreement with each of our external contractors that they adopt and adhere to this privacy policy. The information we collect from you may also be disclosed to third parties if the disclosure is required by or permitted by law, or pursuant to the Rules of Professional Conduct of the Financial Planning Association of Australia. In the event that we propose to sell our business we may disclose your personal information to potential purchasers for the purpose of them conducting due diligence investigations. Any such disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them. In the event that a sale of our business is affected, we may transfer your personal information to the purchaser of the business. As a client you will be advised of any such transfer.

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Access and Correction
You may access the personal information we retain and request corrections. This right of access is subject to some exceptions allowed by law. We will not provide you access to personal information which would reveal any confidential formulae or the detail of any in-house evaluative decision making process, but may instead provide you with the result of the formulae or process or an explanation of that result. Enva Australia Pty Ltd reserves the right to charge a fee for searching for and providing access to your personal information. In the event we refuse you access to your personal information, we will provide you with an explanation for that refusal. We will endeavour to ensure that at all times the personal information about you that we hold is up to date and accurate. The accuracy of the personal information is dependant to a large degree on the information you provide and you should advise us if there are any errors in your personal information.

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Identifiers
In some circumstances we are required to collect government identifiers, for example, your Tax File Number. We will not use or disclose this information other than when required to do so by law or, when consented to by you.

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Anonymity
You may deal with us anonymously where it is lawful, practicable and reasonable to do so.

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Sensitive Information
Without your consent, for example where information is provided by you for insurance and or risk purposes, we will not collect sensitive information about you. Exceptions to this include where the information is required by law, or for the establishment, exercise or defense of a legal claim.

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Privacy Complaints
If you believe we have not acted appropriately in relation to your privacy rights, you are entitled to lodge a complaint with us, initially by contacting your Adviser. If you are not satisfied with the way in which we investigate and respond to your complaint, you are entitled to lodge a formal complaint with an External Dispute Resolution Scheme of which we are a member. We are a member of Australian Financial Complaints Authority and you can contact them on 1800 931 648.

Conditions of Use - Enva Australia Website

Disclaimer Information provided on this Web Site is general in nature and does not constitute financial advice. While all reasonable care has been taken in providing this information, unless expressly stated, it should not be construed as being specific to your investment objectives, financial situation or particular needs. We will endeavour to update the Web Site as soon as practicable after changes. However, information can change without notice and we do not guarantee the accuracy of information on the Web Site, including information provided by third parties, at any particular time. This information is prepared for residents of Australia only. Any currency references are references to Australian dollars unless otherwise specified. Unless otherwise specified, copyright of information provided on this Web Site is owned by Enva Pty Ltd. You may not alter or modify this information in any way, including removing this copyright notice. This Web Site does not offer securities or other financial products, nor does it invite subscriptions for securities or other financial products to any person outside Australia. We do not guarantee the repayment of capital or any particular return from, or any increase in, the value of any products unless otherwise expressly agreed. Further, we disclaim any liability for loss, damage, cost or other expense which you may incur as a result of any information provided on this Web Site, to the extent that such liability is not excluded by law.

Code of Conduct