1.1 Unified Capital Partners Pty Ltd ACN 666 560 050 (UCP) respects and acknowledges the importance of privacy. UCP complies with the Australian Privacy Principles (APP) as contained within the Privacy Act 1988 (Cth) (Act), when collecting, using, disclosing and managing your personal information.

1.2 This Privacy Policy contains information in relation to our management of your personal information in accordance with the APP.

1.3 For the purposes of this Privacy Policy, the term “personal information” has the meaning given to it in the Act.

2.1 UCP may collect and use your personal information for a variety of reasons, which may include but is not limited to the following:

(a) to collect identification information, such as an individual’s name, address and date of birth;

(b) to collect financial information including your Tax File Number, banking and other information necessary to make or receive payments for necessary transactions in financial products on your behalf;

(c) to disclose credit information to a credit reporting body to obtain credit information from the credit reporting body;

(d) to assist in achieving your investment and financial outcomes when using UCP’s products or services;

(e) to perform/execute your requested service;

(f) to process any request for an appointment with UCP;

(g) to add you to the UCP mailing list;

(h) to detect security issues and prevent fraud on the UCP website;

(i) to request feedback on your experience with UCP;

(j) to share/publish your photo on UCP social media channels (with your consent);

(k) to provide you with support in relation to the UCP website;

(l) to enable you to access and the UCP website;

(m) to complete your requested transactions, to verify the existence of and any conditions attached to your accounts or to assist with any investments and financial planning advice UCP has tailored to you;

(n) confirming your identity for the purposes of anti-money laundering and counter-terrorism laws;

(o) to manage and minimise risks and identify or investigate fraud and/or other illegal activities;

(p) responding to your enquiries which include the processing of complaints made to UCP;

(q) the resolution of disputes, collection of fees and troubleshooting problems;

(r) enforcement of our terms and conditions;

(s) deliver targeted marketing and various other notices and promotional communications based on your selected communication preferences;

(t) in the performance of data analytics to improve our website and your experience with UCP;

(u) to analyse trends in your visits to the UCP website;

(v) to gather demographic information based on the visits to the UCP website;

(w) protecting UCP and its assets (including against fraud) and selling UCP assets (including any assignment of debts);

(x) enforcing UCP’s rights (including undertaking debt collection) in connection with the UCP website;

(y) monitoring data, usage, records and statistics derived from your use of the website for the furtherance of ’s business, for general market research and to be disclosed to third parties in relation to the aforementioned;

(z) to contact you through the use of various means e.g. telephone, text (SMS) or email messaging, advertising through our website, third-party websites, mail, and/or any other means as authorised by our terms and conditions;

(aa) UCP’s business development, including sending of updates and publications;

(bb) to manage and deliver contextual and behavioural advertising;

(cc) to improve and personalise our website and to learn about your level of satisfaction to ensure client satisfaction throughout the future of the website;

(dd) auditing and managing the use of UCP’s website; or

(ee) in order for UCP to comply with legal and regulatory obligations.

3.1 UCP collects personal information through a variety of methods, which may include the following:

(a) directly from you;

(b) through your access and use of UCP’s website;

(c) through your access and use of UCP’s software or other platforms commissioned by UCP;

(d) through your access of surveys commissioned by UCP;

(e) when you subscribe to receive information from UCP;

(f) when you communicate with UCP, by email, post or otherwise;

(g) through publicly available information;

(h) financing providers from which UCP offer financing for investments and financial service providers used when processing your payments; or

(i) brokers, accountants and other financial institutions such as a credit reporting body or a public register.

3.2 In the event that UCP is unable to obtain personal information from you as outlined above, this may result in UCP being unable to provide you with access to website (including any updates) or marketing material.

4.1 The type of personal information that UCP may hold includes the following:

(a) identification information including your name, date of birth, gender, phone number, address, email address, and other contact information;

(b) financial information including your Tax File Number, banking and other information necessary to make or receive payments for necessary transactions in financial products on your behalf;

(c) your credit data, which includes obtaining credit reports, opinions about your creditworthiness and publicly available sources of information from financial product registries;

(d) registration information including an email address, username and password;

(e) your approximate physical location of the devices you use to access our website;

(f) your IP address and other device identifiers, including mobile advertising identifiers;

(g) your transaction history, including details of any services purchased from UCP, or that you have enquired about;

(h) aggregate, anonymous, or de-identified non-personal data;

(i) any other information provided by you in using UCP’s websites; and

(j) other information that helps us to identify you or helps us to provide or improve our website.

4.2 UCP may collect various financial information such as the full bank account details or credit card numbers that you link to your account with us.

4.3 The personal information referred to in clause 4.1 above may be held by UCP in both hardcopy files and also in an electronic form.

5.1 UCP may be required to disclose your personal information to the following third parties:

(a) external service providers so that the third party can carry out the service that they have been engaged by UCP for;

(b) our partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;

(c) any organisation or person that introduces you to us;

(d) third parties who have instructed us to provide investment solutions, financial planning and advisory service data;

(e) debt collection agencies and credit reporting agencies;

(f) organisations that provide applications, websites, services, goods, software, programs used by UCP;

(g) third parties that may provide UCP with marketing or analytics reports;

(h) organisations that help identify illegal activities and prevent fraud;

(i) our professional advisors, including our accountants, lawyers, business advisors, financial institutions and consultants;

(j) insurers and reinsurers as well as their claims agents and assessors;

(k) organisations and/or individuals that UCP intends on entering negotiations with for any merger, sale of assets, financing, acquisition of all or a part of UCP’s business; or

(l) any legal industry regulatory body in any of the states, territories and jurisdictions that UCP operates in.

5.2 UCP may be required to disclose your personal information in order to respond to subpoenas, court orders, or to investigate, prevent, defend against, or take action regarding violations of our terms and conditions, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, customers/users or services.

5.3 If you purchase services or make payments for financial products from UCP using our website, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your name, address, e-mail address, and financial information. UCP’s payment processors do not share your financial information with UCP, but they may share non-financial information with us related to your purchases, including your name, address, and the services or products purchased.

5.4 Where the Act permits, UCP may also disclose personal information to third party suppliers and service providers located overseas for some of the purposes listed above.

6.1 UCP may, from time to time, have affiliated offices operating in overseas. UCP may send your personal information to these offices for one or more of the purposes listed in clause 2.1. If UCP’s overseas offices are operated by ‘related body corporates’ of UCP, UCP will take such steps as a reasonably required to ensure that there is appropriate data handling of your personal information and proper security arrangements are in place

6.2 From time to time, UCP may also send your personal information overseas for the following reasons:

(a) to third party service providers who store data or operate outside of Australia;

(b) to complete a transaction involving an international financial institution; or

(c) as required by laws and regulations of Australia or another country.

6.3 Before UCP discloses personal information about you to an overseas recipient who is not a related entity of you, UCP will take such steps as a reasonably required to ensure that there is appropriate data handling of your personal information and proper security arrangements are in place.

6.4 Overseas organisations may be required to disclose information UCP shares with them under a foreign law. In those instances, UCP will not be responsible for that disclosure.

7.1 UCP may, from time to time, contact you for marketing and promotional purposes via email, mail, telephone or otherwise. The parties acknowledge that your consent is provided on an ongoing basis for such contact, unless your rights to opt out in accordance with this clause 7 have been exercised.

7.2 In the event that you no longer wish to receive any promotional or marketing mail or communication from UCP, then you may let us know and we will cease any correspondence or contact relating to these purposes.

7.3 You may opt out from receiving any electronic marketing and promotional communication by following the unsubscribe instructions within any electronic communication that you have received from UCP. Additionally, you may opt out from such communication by contacting the Privacy Officer in writing (the details of which are contained at clause 12).

7.4 Unsubscribe or opt out requests originating from electronic communications will be honoured within ten (10) business days of any such request.

7.5 Any election made to not receive promotional and marketing correspondence from UCP will not preclude UCP from any of the following:

(a) contacting you regarding your existing or past relationship with UCP;

(b) accessing and viewing your Personal Information in the course of maintaining and improving UCP’s database and internal systems; or

(c) otherwise using your Personal Information in accordance with this Privacy Policy.

8.1 Cookies are used by UCP in order to maximise and enhance our user experience.

8.2 When accessing UCP’s website, small files of data may be placed on your device that enable UCP to recognise you as a UCP customer each time you return to our website. As a result of these cookies, you avoid the need to keep inputting your information throughout a session and may have these details auto filled when you visit the website. In addition, these cookies enable UCP to ascertain information regarding what web pages you visit and how regularly, enabling us to make our websites and platforms increasingly user friendly and to target advertising to content that you may be interested in.

8.3 You are free to decline the cookies in which UCP utilises and can disable them through your web browser.

9.1 UCP will take all reasonable steps to ensure that your personal information is properly protected from misuse, loss, unauthorised access, modification or disclosure.

10.1 This Privacy Policy is publicly available, free of charge through UCP’s website.

11.1 This Privacy Policy may change from time to time as required by UCP in order to reflect legislative and other changes.

12.1 To access, seek or request personal information that UCP holds about you, please contact us at:

The Privacy Officer
[email protected]
02 8358 5372

12.2 In the event that access to personal information is requested, UCP will endeavour to respond to that request as soon as reasonably practicable if and to the extent required by the applicable law.

12.3 If UCP is unable to give you access, or if UCP declines to amend your personal information, UCP will issue a written notice that describes our reasoning for doing so. UCP notes that before providing you with any personal information UCP will be required to verify your identity.

12.4 UCP reserves the right to make an administrative charge to you if it is required, to provide you with access to personal information as outlined in clauses 12.1 and 12.2 above.

13.1 If you wish to make a complaint regarding that way in which UCP manages your personal information, or that you feel that UCP has fallen short of the required standards set by the Act, please prepare your complaint in writing and supply it to The Privacy Officer.

13.2 A written acknowledgement of your complaint will be provided within 7 days, and UCP will attempt to have your concern resolved within 30 days of receipt of your complaint.