Effective Date: 6 February 2024
1. We respect your privacy
Your privacy is important to us. This Policy explains how Hejaz Asset Management Pty Ltd (referred to in this Policy as “us”, “our”, or “we”) manages the personal information we collect in our role as promoter of Hejaz Islamic Super and Pension products (“Hejaz Islamic Super”). Hejaz Islamic Super is available from a division of AMG Super, ABN 30 099 320 583, where AMG Super is a regulated superannuation entity (the “Fund”). The Trustee of the Fund is Equity Trustees Superannuation Limited, a professional trustee company. The Trustee is responsible for managing the Fund and its service providers. Hejaz Asset Management Pty Ltd is a service provider to the Fund.
2. Collection of personal incormation
We will only collect personal information which is necessary for the purposes of carrying out our functions and activities as the promoter of Hejaz Islamic Super. The personal information we collect may include, but is not limited to your:
- date of birth
- Tax File Number
- employment details
- contact details
- financial information
- details of your beneficiaries
- other information necessary to provide products and services to you
- information from your dealings with our websites, products, services, content and advertising
Collection of sensitive information
We may also collect sensitive personal information with your consent, including but not limited to health information for the purposes of carrying out functions and activities as the promoter of the Hejaz Islamic Super. We will take reasonable measures to ensure the security of your sensitive personal information.
How we collect personal information
Personal information is usually provided by the person to whom the information relates to. In the case where a third party (for example, an employer) provides your personal information, or you provide a third party’s personal information (for example a nominated beneficiary), it is the responsibility of the disclosing party to notify the person and confirm that personal information has been disclosed to us.
Sensitive personal information may be collected from the person to whom the information relates or from third parties such as medical practitioners or from employers, but only after the person has given consent.
When collecting personal information, we may collect it in ways including:
- through access and use of our website;
- when you enter into promotions, competitions or respond to surveys;
- during conversations with our representatives; or
- written requests – in writing or by email.
For some types of information we request, you can choose not to provide it. However, if we are unable to collect the information, or the information provided is incomplete or incorrect, this may have consequences such as delayed processing, taxation consequences or prevent us from contacting you.
3. Direct Marketing
We may use personal information to send direct marketing communications. At any time you may opt-out of receiving marketing communications by contacting us. We will not sell your personal information to third parties for the purposes of direct marketing.
4. Use of personal information
In carrying out our superannuation fund promoter role and provider of financial products and services we may use personal information we collect about you for a range of purposes, including but not limited to:
- providing you with information, products or services that you have requested;
- establishing and verifying identity;
- displaying content that is tailored to your preferences on our website or otherwise;
- establishing membership in Hejaz Islamic Super;
- opening and managing your Hejaz Islamic Super accounts;
- the calculation and payment of superannuation benefits;
- eligibility for insurance cover;
- assessing insurance claims;
- resolving complaints;
- providing financial advice;
- sending statements and notices;
- to develop strategies to improve products and services;
- customising your experiences on our website;
- using de-identified information for the purposes of data research and reporting;
- complying with regulatory or other legal requirements including reporting obligations;
- using information including IP addresses to assist with risk management; or
- for any other use permitted by law.
5. How we hold personal information
We may hold personal information in either electronic or hard copy form. We take all reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure (other than as set out in this Policy) in accordance with the Privacy Act. Information is also held by our Customer Relationship Management (CRM) provider, Hubspot, which has risk management systems in place and is compliant with the European Union’s General Data Protection Regulation (GDPR).
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, any destruction or de-identification of personal information will be subject to our legal and regulatory obligations and other legitimate business reasons.
6. Disclosure of personal information
Disclosure of your personal information may occur in our capacity as promoter to assist us to provide services in connection with Hejaz Islamic Super, including but not limited to:
- the Trustee of Hejaz Islamic Super;
- the Administrator of Islamic Super;
- trustees or managers of your previous superannuation funds;
- issuers of insurance available to members of Hejaz Islamic Super;
- beneficiaries of death benefits;
- government bodies such as but not limited to the Australian Taxation Office (ATO), the Australian Securities and Investment Commission (ASIC) and the Australian Prudential Regulation Authority (APRA);
- any third party nominated by you;
- third party service providers in relation to Hejaz Islamic Super or the Fund;
- legal representatives or officers of the Australian Financial Complaints Authority; and
- law enforcement agencies.
7. Disclosure of personal information outside of Australia
There are some circumstances where personal information is disclosed to parties outside of Australia, including to persons in our office in Indonesia, for the purposes of providing the services you have asked us to provide.
We put in place safeguards to ensure that the recipients of personal information in our overseas offices are subject to appropriate contractual obligations to protect your personal information and comply with the Australian privacy principles.
8. Quality of personal information and correction
We rely on accurate personal information to provide the Hejaz Islamic Super products and related services. We ask you to check the accuracy of the personal information we hold about you when you are providing personal information. You have a right to request correction of your personal information if required. To submit a request, please contact us using the details in this Policy. We aim to complete correction requests within 30 days of receipt of the request. There may be circumstances where a correction is not possible, and this will be communicated to you.
Access to your personal information
Under the Australian Privacy Principles you have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request to us in writing (for security reasons) and we will provide you with access to that personal information. There may be circumstances where access is not possible, and this will be communicated to you.
9. Privacy and the internet
If you send us an email message requesting information, we will use your email address and other information you supply to respond to your request. If you choose to receive any of our updates via email we will only use the email address currently held for you on our files.
Our website may utilise software that detects the geographical location users are accessing the website from in order to provide users a tailored experience.
10. Privacy Complaints
- You can call us on 1300 043 529.
- If your complaint cannot be resolved on the call, more detailed information can be provided in writing to us by email at email@example.com, or by writing to us at PO Box 96, Flinders Lane VIC, 8009.
- We’ll investigate your complaint and try to respond more quickly than the standard 30 calendar days. If we can’t fully respond in that time, we’ll attempt to keep you informed about the progress of your complaint.
4. If you are still not satisfied with the outcome of your complaint, you can contact the Australian Information Commissioner (OAIC) on 1300 363 992 or the Australian Financial Complaints Authority (AFCA) on 1800 931 678.
11. Contact details
If you feel that our actions are contrary to this Policy or the Privacy Act, please contact:
Hejaz Financial Advisers
Suite 11.06, 2 Queen Street
Melbourne Vic 3000
Ph: 1300 043 529
You can find out more information about privacy from the Office of the Australian Information Commissioner (OAIC). The contact details are phone 1300 363 992, visit their website at www.oaic.gov.au or email at firstname.lastname@example.org.