Privacy Policy

Aspen Corporate's Privacy Policy Statement

Aspen Corporate Pty Ltd, trading as Aspen Corp, is committed to providing you with the highest level of service. This includes protecting your privacy. We are bound by the Privacy Act 1988 (Cth) ("the Act") and must comply with the Australian Privacy Principles. You can find more information about the Act and the Australian Privacy Principles at the Office of the Australian Information Commissioner's website at: www.oaic.gov.au.

This Privacy Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws and how you can access the personal information we hold and how to have that information corrected. This is outlined in our Privacy Policy below.

Aspen Corp will update this Privacy Statement as required. Any changes will be published on our website so that you are aware of the sort of information we collect, how the information may be used, and under what circumstances it may be disclosed by Aspen Corp.

Please note that if at any time Aspen Corp is required by law to release information about you or your organisation, Aspen Corp must cooperate fully. This Privacy Policy does not apply to acts or practices of Aspen Corp that are directly related to employee records of current or former employees.

For more details on Aspen Corp's approach to privacy generally, please contact Eujanie Papandreou, our Privacy Officer.

What Personal Information does Aspen Corp collect?

Personal Information is any information or opinion from which an individual's identity may be ascertained.

The kinds of personal information which we collect and hold may generally include the following:

• Your individual or your entities identity details such as: Names, Addresses, (including email addresses), Telephone and fax numbers, Date of birth, Occupation and Employer, Gender;
• Financial Information;
• Share portfolio information;
• Creditor information; and
• Information as required by taxation law

If you choose not to provide personal information, we may not be able to provide you with the services you or your organisation requires, or the level of service on which we pride ourselves.

How does Aspen Corp collect information?

Aspen Corp only collects information that is necessary to assist us in providing our services. We strive to maintain the reliability, accuracy, completeness and currency of the personal information we hold and to protect its privacy and security.

We keep personal information only for as long as it's reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

We do not collect personal information unless we first ask you for it, you provide it to us, or the information is publicly available. We will collect your personal information only by lawful and fair means; will be used for a lawful purpose and not in an unreasonably intrusive way.

Aspen Corp collects personal information about you (individuals and entities) in a number of ways including:

• Directly from you when you engage our firm so that we may provide you with financial planning (through a separate legal entity Aspen Corporate Financial Planning Pty Ltd), tax consulting, business services, audit, specialist services advice; and
• Collects information from external sources with prior consent from you. Our external sources include: Australia Security and Investments Commission (ASIC), Fund Managers, Australia Taxation Office (ATO).

We ensure that external sources are permitted under the Australian Privacy Principles to disclose the information to us, or have received the prior consent from the individual to release the information to us.

When you email us:

• We will use your email address for the purpose for which you provided it and to raise awareness about recent developments that may be of relevance or interest;
• Your email address will not be added to a commercially available mailing list; and
• We will not disclose it without your consent

Consent is obtained from you when we are appointed by you as your:

• Tax agent;
• Accountant;
• Business Advisor;
• Financial Planner (through a separate legal entity Aspen Corporate Financial Planning Pty Ltd);
• Registered office for a  company or;
• Agent for other purposes (example power of attorney).

Our appointment is confirmed in writing with you when you sign an engagement letter.

What may happen if you do not provide Aspen Corp with information?

If you do not provide us with the information we request, our ability to provide our high standard may be compromised.

• Our advice may be inaccurate or incomplete;
• We may be unable to provide certain services to the individuals concerned;
• The provision of some of our services may be delayed; and/or in certain circumstances failure to provide some information may result in documents being submitted to the ATO, ASIC or other statutory bodies late and possibly incurring penalties.

Why does Aspen Corp collect the information and how is your information used by us?

Aspen Corp collects information to provide you with a specific service. We may use the information you provide to us for a number of purposes such as:

• ATO reporting requirements;
• Managing your financial portfolio (through a separate legal entity Aspen Corporate Financial Planning Pty Ltd);
• ASIC requirement s;
• Provide other services you require;
• Administrator and manage those services, including charging, billing and collecting debts;
• Inform you of ways the services provided to you could be improved;
• Advising clients of event, business opportunities and service provision available to them;
• Gain an understanding of your information and financial needs in order for us to provide you with a better service;
• Providing you with news and information relevant to you;
• Research and develop our services; and
• Maintain and develop our business systems and infrastructure.

Your personal information is also collected to promote and market other services which we consider may be of interest to you.

You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

Aspen Corp does not collect sensitive information such as an individual's religion, race, political opinion, membership of a political association, religious beliefs or affiliations, sexual preferences or practices, criminal records or health information. There may be exemptions to this rule, such as where collection is required by any law.

Disclosure of personal information

Aspen Corp will not sell, exchange, trade or otherwise supply third parties any personal information obtained from you without your prior consent.

Aspen Corp, with prior consent, may disclose information about you to various organisations and or parties in order to fulfil our client's services. These organisations include:

• Australian Tax Office (ATO);
• Australian Securities and Investment Commission (ASIC);
• Institute of Chartered Accountants in Australia (ICAA) Quality Control;
• CPA Australia Quality Control;
• Banking and Financial institutions;
• Superannuation authorities;
• Fund managers;
• Government and statutory bodies; and
• Auditors

When your personal information is no longer used by Aspen Corp as set out above, we will destroy or permanently de-identify personal records. Our ability to destroy information is limited by legislative and insurance requirements that require us to retain records for a period of time.

Overseas recipients

We may disclose your Personal Information to third parties but only for the purposes of providing our Services and for those contemplated by your use of our website.

These third parties may include:

• technology services and platform-providers for our business
• our clients, agents or contractors (worldwide);
• email marketing providers (worldwide);
• data collection and marketing providers (worldwide);
• our related entities; and
• our professional advisers.

When we disclose your Personal Information with a third party, we will require the third party to handle your Personal Information in accordance this Privacy Policy and the Australian Privacy Principles.

Aspen Corp conducts a due diligence process before entering into an agreement with these third parties and will take all reasonable steps to ensure that your information is not used in a manner inconsistent with the Australian Privacy Principles.

Web traffic information is disclosed to Google Analytics when you visit our Site. Google stores information across multiple countries. When you communicate with us through a social network service such as Facebook or Twitter, the social network provider and its partners may collect and hold your personal information overseas.

Using Our Website and Cookies

We may collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

Cookies are pieces of information that a website can transfer to an individual's computer hard drive for record keeping. Cookies can make web sites easier to use by storing information about your preferences on a particular web site. The information remains on your computer after the internet session finishes. Parts of Aspen Corp web site may use cookies to store basic statistical data. The information collected may be used by Aspen Corp to help us improve the service by understanding how it is used. There is no attempt made to identify individual users in any way.

On each use, a session cookie may be temporarily placed on your computer, which is used to maintain navigation information during your site visit. These session cookies are automatically deleted from your computer at the end of each internet session. Most internet browsers are pre-set to accept cookies. If you prefer not to receive cookies, you can adjust your internet browser to refuse cookies or warn you when cookies are being used.

How will Aspen Corp keep your personal information secure?

Aspen Corp intends to protect the quality and integrity of personal information kept about you. We have implemented appropriate industry standard techniques, technological and organisational measures to protect against loss, misuse and/or alteration of the information under our control.

These measures include:

• Server enforced patch management with notifications enabled
• Computer firewalls and intrusion detection;
• Virus scanning tools to stop viruses and unauthorised access to our systems;
• Internal wireless secured using EAP security and LDAP authentication.
• Guest wireless network using WPA2 authentication and has no physical access to the internal network;
• Computer password authentication;
• Offsite data backup encrypted using AES256 encryption;
• Destroy and de-identify data when it is no longer required;
• Audit trail of access to client data;
• Confidentiality clauses in employment agreements;
• Bound by the rules of Ethical Conduct of the IAAC and CPA;
• Computer, Internet and Email policy;
• Building security;
• Restricted access to firm premises; and
• Unique client identifiers
• train our staff about how to keep your information safe and secure;

Aspen Corp will review security arrangements from time to time as we deem appropriate.

We take reasonable steps to ensure that any personal information transmitted via our website is stored securely. Transmissions sent to or from our website are routinely monitored for quality control and systems administration. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. While we strive to protect your personal information from misuse, loss and unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from our online products or services. Once we receive transmission, we make our best effort to ensure its security.

Other websites that may be accessed through our site may collect personally identifiable information about you. The information practices of those third-party web sites linked to Aspen Corp are not covered by this privacy statement.

Help us to ensure we hold accurate information

Aspen Corp holds personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. Aspen Corp's policy is to take reasonable steps to:

• Make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
• Protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

However, the accuracy of the information we hold depends to a large extent on the information you provide. That is why we recommend that you:

• Let us know if there are any errors in personal information and
• Keep us up-to date with changes to personal information such as your name and address

You have a right to access your personal information (subject to the Act), subject to some exceptions allowed by law. If you would like to do so, please let us know by contacting your advisor or our Privacy Officer. You may be required to put your request in writing for security reasons. If you think that any information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected. We will not charge you for responding to such a request, unless we incur costs in providing the information.

Use of government related identifiers

Aspen Corp's policy is to not:

• use a government related identifier of an individual (such as a Tax File or Medicare number or driver's license number) as our own identifier of individuals
• otherwise use or disclose such a government related identifier; and
• unless this is permitted by the Act (for example, where the use or disclosure is required or authorised by or under an Australian law or a court or tribunal order).

Complaints

Should you have any complaints about our treatment of your personal information please direct this by email to our Privacy Officer at advisor@aspencorp.com.au. We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously and will investigate any breach of which we become aware - including how it occurred and how best to prevent such a breach occurring again.

If you believe that we have not adequately addressed your complaint, you may complain to the Office of the Australian Information Commissioner.

Retention of Documents

• We retain the personal information that you or your agents provide to us. At the conclusion of your matter we will return original documents and retain copies for our records unless otherwise agreed in writing.
• The information we retain includes your contact and financial details as well as other information or documentation relating to your matter(s).
• We predominantly retain information and documentation in electronic format.
• We maintain the electronic information on secure, local computers and offsite (e.g. 'cloud') third-party servers usually located within Australia. Those local computers and third-party servers are protected by encryption, firewalls and anti-virus technologies. Those third-party servers are backed-up daily, and those electronic backups are held off-site at a secure location.
• Electronic documents maybe periodically archived. Archived material is also electronically maintained on secure, offsite servers usually located within Australia.
• Physical copies of documents are (originals are returned) kept in our office or in offsite storage facilities.
• Our employees may access your personal information in order to maintain your matter.
• You may access any personal information we hold about you relating to your matter.
• We release your original source documents on completion of your work or when requested by you if retained by us for some reason.
• You may request that we amend your personal information in writing.
• We retain your personal information for a minimum of 10 years. After 10 years the documents may be destroyed.

How to contact us.

For any complaints regarding a possible breach of privacy, or if you have any questions or feedback in relation to privacy, contact Eujanie Papandreou our Privacy Officer.

Contact details:

Phone: 08 9228 0700
Email: advisor@aspencorp.com.au 
Web: www.aspencorp.com.au
Address: PO Box 8262 Perth Business Centre Stirling Street Perth WA 6849
Office Hours are 8:30am to 5:00pm Monday to Friday
Effective: December 2018