Privacy Policy

Read about how Ginkgo Private Pty Ltd ABN 43 683 544 854 (us, we or our) collects, protects, uses, and shares your personal information.

Your privacy is important to us. Intergen Capital Pty Ltd and its Authorised Representatives (including Ginkgo Private) are committed to ensuring the confidentiality of your personal information in accordance with the Privacy Act 1988 and the Australian Privacy Principles (APPs).
‍
We provide a number of products and services that require us to collect, store, share, and use your personal information. This Privacy Policy applies when you use our products or services or interact with our website. It sets out how we collect information about you, how we use it, and how we keep it secure.
‍
This Privacy Policy also incorporates our Credit Reporting Policy which sets out how we use any credit information we collect.
We may change this Privacy Policy by publishing changes to it on our website. Please check our website regularly to ensure that you are aware of any changes. This policy will be reviewed every two years by the Compliance Manager or other nominated person to ensure it remains relevant to our business.

Personal information is information about you that is reasonably identifiable (i.e. name, email address, contact details).
‍
Credit information is personal information that is collected in connection with a credit application. This includes identification information, default information or repayment history information.
‍
In this Privacy Policy we use the term “personal information” to refer to both personal information and credit information.
‍
The personal information we may collect (and hold) about you includes:
• name, address, email address, date of birth, phone number(s);
• tax file number;
• information about dependents or family members;
• bank account details or credit or debit card details;
• Medicare number, pension card number;
• accounting and financial information;
• occupation, employment history and details;
• family commitments and social security eligibility;
• financial needs and objectives;
• assets and liabilities (current and future), income, expenses;
• superannuation details;
• risk profile details;
• estate planning arrangements;
• details of your interactions with us;
• any other relevant information that you give to us for the purpose of providing you with our products or services.
‍
Where the information is deemed to be sensitive (for example, estate planning arrangements), a higher level of privacy protection applies.

Information is generally collected from:
• When we ascertain from you the facts necessary to make a fair and reasonable assessment of your financial needs and objectives;
• When you complete an application form for investments;
• When you complete supplementary financial questionnaires.
‍
We collect personal information either directly from you or from other people such as:
• related entities;
• suppliers and service providers in connection with providing our products and services;
• your advisers;
• banks, financial institutions, and other financial product providers;
• your employer;
• credit reporting bodies;
• fund managers;
• superannuation funds;
• public sources.
‍
We collect information when you:
• visit our website;
• submit application forms with us;
• participate in a meeting (whether in person or via video) or phone call with us;
• email or otherwise correspond with us.
‍
If you are unable to provide us with your personal information, we may not be able to provide you with our products or services. You can nominate a representative to access your personal information (this can be revoked at any time).
‍
Intergen Capital and our Authorised Representatives may collect personal information from a third party (such as another Financial Adviser or Product Provider) or a publicly available source, but only if you have consented or it can reasonably be expected that it has been provided by you.

We will only use your personal information for the purposes for which it was collected (primary purpose) or for a purpose related to the primary purpose, if you would reasonably expect us to use the information for that purpose, or otherwise with your consent.
‍
Our primary purposes for collecting, holding, using, and sharing (disclosing) your personal information include:
• to deliver products or services to you;
• to improve our service to you;
• preparing financial plans;
• to provide financial advice to you;
• establish and manage investments and accounts;
• implement investment instructions;
• process any contributions, transfers or payments of benefits;
• monitor and report on investment performance of your account;
• reviewing financial plans;
• to provide you with future products and services you may be interested in;
• to fulfil our regulatory and legislative requirements;
• to send you information about events, products, services, and opportunities that may be of interest to you;
• to conduct market research (where we contact you for feedback on our products or services);
• to run and improve our website including your experience with our website;
• to identify and control or minimise risks to our products or services;
• to enable us to detect and prevent suspicious or fraudulent activity;
• to monitor compliance with our terms and conditions;
• to provide information to our advisers, including lawyers and accountants, to help us comply with legal, accounting, or security requirements;
• to protect our legal rights, interests, and the interests of others, including in connection with legal claims, compliance, regulatory and audit functions, and ensuring data security;
• to verify your identity pursuant to the Anti-Money Laundering and Counter-Terrorism Financing Act (AML Act);
• to comply with our legal obligations, resolve any disputes that we may have with any of our customers, and enforce our agreements with other people;
• for any purpose related to the above.

We may send you newsletters, market updates, knowledge-sharing materials and investor information that we believe may be of interest to you. You can opt out of receiving these communications at any time by contacting us.

There may be cases where we need to disclose your personal information to third parties to assist us in providing you with a product or service. This may include:
• any fund (investment administrator or superannuation trustee) to which your benefit is transferred, created or rolled over;
• employers where it relates to your employer superannuation guarantee arrangement;
• your personal representative or any other person who may be entitled to receive your death benefit;
• an external dispute resolution service or legal representative (where required or applicable);
• exchange of information with authorised financial institutions to confirm bank account details for payment;
• our related entities;
• suppliers and service providers in connection with providing our products and services;
• payment systems operators;
• banks or other financial institutions;
• fund managers;
• superannuation funds;
• financial product issuers;
• a purchaser of our business;
• specific people authorised by you to receive information held by us;
• government agencies, regulatory bodies, and law enforcement agencies, or as required, authorised or permitted by law.
‍
If required by law or a regulatory body to do so, we will comply and provide the appropriate body with the required information.
Information that we provide to other people will be handled in accordance with their privacy policy.

We do not share (disclose) your personal information outside of Australia.

We 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.
‍
Intergen Capital and our Authorised Representatives may use cookies on our websites. Cookies are text files stored on your computer when you visit a website. Their sole purpose is to identify users and possibly prepare customised web pages or to save site login information. You can purge cookies from your browser after every use.
‍
Intergen Capital and our Authorised Representatives may provide links on our web pages to external industry parties. The content and views expressed on these third party websites are not the responsibility of Intergen Capital or our Authorised Representatives.

We hold your personal information in either electronic or hard copy form.
‍
We take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel, and technical measures to protect your personal information.
‍
For example we:
• impose confidentiality requirements on our employees and train them on how to keep your information safe and secure;
• have policies and procedures in relation to document storage security and security measures to govern access to systems;
• implement firewalls and virus scanning tools to stop viruses and unauthorised access to our systems;
• destroy and de-identify data when it is no longer required.
‍
Your personal information is kept for as long as it is required to meet your financial product or service needs. For record keeping, it is generally kept for a further period of at least seven years.

Intergen Capital and our Authorised Representatives strive to ensure the security, integrity and privacy of personally identifiable information. Only those authorised to do so are able to access such information. All client information is kept in a secure location and can only be accessed by authorised personnel. This will include but is not limited to:
• locked offices;
• locked filing cabinets;
• storage via a third party online provider;
• storage via a third party online platform.

However, we cannot guarantee the security of your information. No data transmission over the internet can be guaranteed to be completely secure.

You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your information.
‍
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.
‍
Clients may be charged a small fee applicable to the collection and provision of their personal information (you will be notified of this fee prior to processing your request). Information is generally provided within 14 days of the request.

You can choose not to provide us with personal information or to use a pseudonym. However, if you do this, we may not be able to provide you with any products or services.

Electronic Identification
We are required to verify your identity under the AML Act before providing you with our services. In order to verify your identity electronically, we will ask for the following personal information:
• name;
• address;
• date of birth; and
• details of and in some cases copies of your identification documents.

You acknowledge that your personal information may be passed on to external organisations including government agencies and CRB. Your personal information may be disclosed to our agents who assist with the electronic identity verification process.

The use of your personal information for electronic identity verification does not constitute a credit check or impact your credit standing in any way.

Your details will also be submitted to the Australian Government’s Document Verification Service (DVS). More information about the DVS is available on their website.

You do not have to agree to electronic verification. You can choose for your identity to be verified in person — please just let us know if that is your preference.

We may need to collect your tax file number to provide you with a service or product (for example, managed fund investments). This information must be kept securely and will be destroyed or permanently de-identified where it is no longer required.

In the event that we or an Authorised Representative propose to sell our business, or if an Authorised Representative is no longer eligible to provide advice, we may disclose some of your personal and sensitive information to potential purchasers for the purpose of conducting due diligence investigations. Any such disclosures will be made in the strictest confidence. In the event of a sale being effected, we may transfer your personal information to the purchaser. You will be provided a notice by mail to your last known mailing address that such a transfer will be taking place. You will then have the opportunity to object to the transfer within 14 days of the date of the notice.

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and aim to respond within 45 days.

If you are not satisfied with how we have dealt with your complaint you can contact the Office of the Australian Information Commissioner using any of the following details:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
www.oaic.gov.au

For further information about our Privacy Policy or privacy practices, to access or correct your information, or make a complaint, please contact us using the details set out below:
Privacy Officer
Eric Chen
Telephone: 02 9411 6686
Email: eric.chen@intergencapital.com.au
Address: Suite 408, 10 Help Street, Chatswood NSW 2067