Privacy Policy

Introduction

MLCM Advisory Pty Ltd, ABN 54 656 993 994 (MLCM, we, us and our) is committed to ensuring that your personal information is adequately protected. It is our policy to respect the confidentiality of information and your privacy. We are bound by the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). The Privacy Policy (Policy) explains in detail the types of data we may collect about you and what we do with your personal information. It also sets out what we do to keep your personal information secure, as well as your rights in relation to the personal information we hold about you.

What personal information do we collect about you?

Personal details such as your name, gender, address, date of birth, telephone number, and email address.
Copies of documents you provide to prove your age or identity. For example, government issued ID, passport, driver’s licence, birth certificate and utility bill.
Copies of documents you provide to prove your sources of funds. For example, your bank statements, tax returns, management accounts and financial statements.
Information we collect about you when you use our services or contact our team
Details of the transactions you carry out when using our services.
In relation to our websites, we will log your internet protocol (IP) address so that it is recognised next time you visit.

We will update the information we hold about you when you provide it to us during our communications with you. However, whenever possible, you should contact us if the personal information we hold about you needs updating or is no longer accurate.

When do we collect personal information about you?

When you visit any of our websites.
When you make an enquiry about our services or use our services.
When you have given a third-party permission (for example, a referring partner) to share with us your personal information.
When you report a problem, make a query or issue a complaint about our services.
During correspondence with MLCM employees (or persons acting on our behalf) over telephone, online, email, post or in person.

How do we use your personal information?

We may process your personal information for the following purposes, depending on how you interact with us.

To complete the delivery of our services. Without your personal information, we would not be able to provide you with our services.
As part of our onboarding process, we will provide you with an engagement letter and our terms and conditions.
At the beginning of the relationship and throughout, MLCM may call or email you to discuss your needs and the provision of our services to you.
Throughout the relationship, we will share your personal information with funds and lenders, for the purposes of providing you with our brokerage, debt advisory and other services.
Throughout the relationship, MLCM may also be required to send you communications known as ‘service messages’ in order to inform you about changes to the services we provide you. For example, changes to our offer documents and/or this Policy or changes to our fees and bank account details. These service messages will not include any promotional content and cannot be unsubscribed from.

To respond to your queries and complaints

Without your personal information, we would not be able to effectively respond and handle your queries or complaints. We may keep a record of our correspondence to demonstrate how we communicated with you throughout. We will do this on the basis of our legitimate interests and our legal and regulatory obligations.

To comply with our legal and regulatory obligations

In order to meet our legal and regulatory obligations, we are required to carry out regulatory checks in order to prevent and detect fraud, identity theft, other crimes and also to keep records of our services rendered to you. We are also required to send you communications known as ‘service messages’ in order to inform you about changes to the services we provide you. For example, changes to our engagement documents and changes to this Policy.

To analyse, test and improve our systems and databases

We may use your personal information to ensure that our systems are tested thoroughly. This ensures that the systems we maintain can cope with comparable volumes of information, that a wide range of realistic scenarios are covered and that the test will reflect all the possible combinations that occur in the real environment. In addition, to ensure that personal information is not compromised, we carry out various risk assessments, and have implemented safeguards to ensure data security.

To develop new and improved products and services, including conducting market research and product analysis

For this purpose, we may use cookies to personalise your next visits to our websites and to measure volumes and patterns of website usage.

For training and quality purposes

We are continually reviewing the quality of the services we provide in order to improve your experience with MLCM.

To keep you informed

We will keep you informed about relevant products, special offers and market news up until you tell us otherwise (i.e., until you opt-out). You are free to opt out of receiving marketing communications from us at any time through one of the options set out in the “Managing your marketing preferences” section of this Policy.

Telephone and email recording

Telephone calls made and received by MLCM may be recorded and internally monitored for the purposes of:

ensuring that MLCM complies with its regulatory and legal obligations;
evidencing your use of our services;
investigating complaints;
gathering evidence in disputes; and
improving MLCM’s services (training and quality control).

We may also maintain a record of all emails sent by us for the same purposes

Who do we share your personal information with?

We may share your personal information with the following entities for the purposes described in this Policy:

MLCM’s sister companies, parent companies, subsidiaries and affiliates;
third party services providers, including:
- agencies who provide credit referencing, identity & verification checks and fraud prevention services;
- auditors and other professional advisers such as lawyers, accountants and consultants;
- banks, non-bank lenders, funds and other financial services providers who facilitate our transactions;
- companies who host, support and maintain our website, databases, archives and other business systems;
- companies who provide off-site hard copy information management facilities;
- companies who provide MLCM with its customer relationship management application;
- companies who perform functions on our behalf in the areas of IT development, IT support, back office, compliance and accounting;
- companies that provide our email archiving and backup system;
- contractors who supply services to us;
- companies that provide our recording systems and tracking analysis software;
- companies who assist with providing our multi-factor authentication security process;
- companies that enable MLCM to collect customer reviews of its services; and
- companies that provide MLCM with its appointment scheduling software,

public authorities, law enforcement and regulatory bodies – in response to their lawful requests to meet national security, public interest and/or our legal and regulatory obligations; and
referring partners – if you have been referred to MLCM by a third party who you and MLCM both have a separate direct relationship with (e.g. an independent financial adviser, lawyer or other consultant), we may provide such third party with your personal information relating to you (name and email address or phone number) in which they are interested in by virtue of MLCM’s agreement with them (e.g. for commission purposes and tracking success of referrals) and where your interests and privacy rights do not override those interests.

With your express consent only, we may pass your data to a third party for their direct marketing purposes. We will not sell your personal information to any third party.

In the event we sell or propose to sell, our business (or divisions of our business), we may disclose your personal information to prospective purchasers and their advisers for their evaluation purposes.

Please note our websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility for them. Please check these privacy policies before you submit any personal information to these websites.

How do we protect your personal information

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Whether we interact with you via phone, mail, email, over the internet, or via another electronic medium, we endeavour to safeguard the privacy of your information. We may hold your personal information in a combination of secure computer storage facilities, cloud-based systems and in hard-copy. Irrespective of the medium, we will take such steps as reasonably necessary to ensure that your personal information is protected from misuse, unauthorised access, loss interference, modification or disclosure.

These measures include:

staff data protection training;
building security infrastructure;
internal policies and procedures to be utilised in the event of a data breach, such as our business continuity plan;
data back ups and ongoing anti-virus and software patching;
secure handling and storage of your information; and
system security in all of our websites and platforms, including virus scanning tools, encryption, multi-factor authentication measures and intrusion detection.

How long will we keep your personal information

In accordance with our legal and regulatory obligations, for example, the Corporations Act 2001 (Cth), we will retain your personal information for a period of seven (7) years from the end of your business relationship with us.

At the end of the retention period, your personal information will either be anonymised (so that it can be used in a non-identifiable way for statistical analysis, business planning), made inaccessible or unintelligible (for system integrity purposes) or deleted completely. However, we may retain your information beyond this retention period if we have a legitimate business interest to do so or we can rely on another lawful purpose to do so.

Unsolicited personal information

If you provide us with personal information that we have not requested, then we will only keep so much of that information as necessary for us to hold, in connection with the products and services we provide to you.

However, where we are entitled or otherwise required to retain this surplus unsolicited personal information, then we will hold that information in the same manner (and subject the same security and protection measures) as the balance of your personal information.

Your data protection rights

Right to access

You have a right to request a copy of the personal information we hold about you. In some circumstances, we may be unable to comply with your right to access for legal, regulatory or administrative reasons, which we will notify you of (if we can).

Please note that you will have to verify your identity and make a request to us before we can provide you with the personal information we hold about you. In accordance with the APPs, we will respond to your requests for access within 30 days, and in the manner of your choosing, if practicable.

We will not charge you for requesting access to your personal information.

Right to transfer

Where reasonably requested, you have a right to receive information that you have provided us in a format of your choosing, and/or request that we transmit it to a third party.

Right to erasure

You have a right to request that we erase your personal information. However, we may not always be able to comply with your request of erasure for specific legal and regulatory reasons which will be notified to you, if applicable, at the time of your request.

Right to lodge a complaint

You have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC) and/or MLCM regarding our management of your personal information. Further details can be found under the “Contact Us” section of this Policy.

Right to correction

Where your personal information is inaccurate, out-of-date or incomplete, you have the right to request an amendment to it. We will not charge you for making a request to correct your personal information.

Right to withdraw consent

Where you have given us your consent to process your personal information, you have the right to change your mind at any time and withdraw that consent.

Should you wish to exercise any of these rights, please get in touch with us by using the details in the “Contact Us” section below. Please note we will ask you to verify your identity before proceeding with any request you make.

Managing your marketing preferences

You may update or stop direct marketing communications from us by:

Clicking the ‘unsubscribe’ or ‘opt-out’ link in the marketing communications that we send you; or by emailing or writing to us.

We will then stop any further emails, text messages or other marketing communications to you.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated

You may direct any questions or complaints about the use or disclosure of your personal to us at:

MLCM Advisory Pty Ltd
Email: mm@mlcmadvisory.co
Post: MLCM Advisory, Level 17, 123 Pitt St, Angel Place, Sydney NSW 2000

We value your feedback on our data protection processes and aim to resolve any and all complaints to your full satisfaction. We agree to ensure open lines of communication regarding your complaints, and that all complaints will be given an impartial internal review.

If you feel that your personal information has not been handled correctly, or you are unhappy with our responses to your requests regarding the use and disclosure of your personal information, you have the right to lodge a complaint with the OAIC at www.oaic.gov.au or on 1300 363 992.

For other non-data protection related matters, please contact your usual point of contact at MLCM.

Changes

We reserve the right to amend this Policy from time to time without notice in order to be consistent with the APPs. Where we do make significant changes to this Policy, we will take appropriate steps to bring those changes to your attention

Privacy Policy

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