Privacy Policy

Dated: 28th August 2026 Version 1.3

Protecting your personal information matters to us. We recognise the trust you place in IMFG when you share information with us, and we take our responsibility to protect that information seriously. We handle personal information in accordance with the Australian Privacy Principles and other applicable privacy laws, and we are committed to managing it carefully, securely and transparently.

In this Privacy Policy, “IMFG”, “we”, “us” and “our” mean IMFG Pty Limited and, where relevant to the services provided to you, its authorised representatives and related service providers identified in this Privacy Policy.

This Privacy Policy explains how we collect, hold, use and disclose personal information, how you may access and correct personal information we hold about you, and how you may make a complaint about our handling of your personal information.

“Personal information” and “sensitive information” have the meanings given to those terms in the Privacy Act 1988 (Cth).

We review this Privacy Policy periodically and may update it where our practices, technology, service providers or legal obligations change. The current version will be made available on our website.

COLLECTING YOUR PERSONAL INFORMATION

Your personal information will be collected and held by your adviser and Identity McIntyre Pty Ltd, Specialist Advice Pty Ltd, Star Financial Services Pty Ltd, Financial Equilibrium Pty Ltd, Arete Wealth Strategists Australia Pty Ltd who are authorised representatives of IMFG Pty Limited, an Australian Financial Services Licensee, for the purposes of:

·        providing you with the advisory services that you have requested;

·        managing our relationship with you, including management and administration tasks such as answering your requests and concerns, conducting market research and taking any required legal action;

·        completing documentation and forms, including identifying you or verifying your authority to act on behalf of a customer;

·        to protect our business and other clients from fraudulent or unlawful activity;

·        to comply with relevant laws, regulations, and other legal obligations;

·        to help us improve the products and services offered to our clients, including contacting you about products and services in which you may be interested; and

·        for any purpose for which you have given your consent.

To provide financial advice and related services to you, we need to understand your relevant personal and financial circumstances. This enables us to assess your circumstances, provide advice and services appropriate to your needs, implement agreed recommendations, administer our relationship with you and comply with our legal and regulatory obligations. This includes:

·            your name, contact details and date of birth;

·            employment details and history;

·            financial details including information about your financial needs and objectives, your current financial circumstances including your assets and liabilities, income, expenditure, insurance cover and superannuation;

·            details of your investment preferences and risk tolerance;

·            family circumstances and social security eligibility; and

·            any other information that we consider necessary.

If you don’t provide some of the personal information we request, we may not be able to provide you with the advice, products or services you request.

The personal information collected may include sensitive information such as health information and memberships of professional or trade associations.

1.                     ‘Health Information’: We collect your health information where we offer you products with an insurance component or in assessing certain claims, including hardship. We do not use of share that information any purpose other than the underwriting or administration of your policy, claim or account, or as otherwise notified to you at the time we collect you information.

2.                     ‘Sensitive Information’: Some of the personal information we collect may be sensitive information. Sensitive information may include information about your health, racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or practices, criminal record, genetic information and certain biometric information.

We will generally only collect sensitive information where:

·        you consent to the collection; and

·        the information is reasonably necessary for one or more of our functions or activities,

unless the Privacy Act otherwise permits or requires us to collect the information.

We may collect health information where it is relevant to financial advice, insurance advice, an insurance application or claim, superannuation, hardship arrangements or another service you have asked us to provide.

We will only use or disclose sensitive information for the purpose for which it was collected, for a directly related secondary purpose that you would reasonably expect, with your consent, or where otherwise permitted or required by law.

If it is reasonable and practicable we will only collect your personal information from you.

Generally your personal information will be collected when you meet with your adviser in person, provide your adviser with information over the telephone or with written material. We may need to collect personal information from third parties, such as your accountant.

Unsolicited personal information

We may sometimes receive personal information about you that we did not request.

Where we receive unsolicited personal information, we will determine whether we could have collected that information under the Australian Privacy Principles if we had requested it.

If we could not have collected the information and it is lawful and reasonable to do so, we will destroy or de-identify the information as soon as practicable. If we are permitted to retain the information, we will handle it in accordance with this Privacy Policy and the Australian Privacy Principles.

HOW YOUR PERSONAL INFORMATION IS HELD

Your personal information is generally held in client files or a computer database. Your personal information may also be held in a secure archiving facility.

We take reasonable steps to ensure that the personal information that we hold is protected from misuse and loss and from unauthorised access, modification and disclosure. Some of the measures that we have adopted are having facilities for the secure storage of personal information, having secure offices and access controls for our computer systems.

We use technical and organisational measures that are appropriate to the nature and sensitivity of the information we hold and the circumstances in which it is held. These measures may include access controls, authentication measures, information-security policies and procedures, staff training, supplier and service-provider controls, secure storage arrangements, system monitoring and processes for responding to information-security incidents.

No method of electronic transmission or storage is completely secure. We therefore review and adapt our security controls having regard to changes in technology, threats, our business operations and the sensitivity of the information we hold.

We will also take reasonable steps to destroy or permanently de-identify personal information that we no longer need for any purpose for which it may be used or disclosed under the Australian Privacy Principles.

USING AND DISCLOSING YOUR PERSONAL INFORMATION

Your personal information may be disclosed for purposes related to the provision of the financial advice you have requested. The types of service providers that may be provided with your personal information are:

·            other financial advisers and organisations involved in providing the financial advice you have requested (which may include ongoing service) such as fund managers who assist us in providing financial advice and paraplanners;

·            insurance providers, superannuation trustees and product issuers in connection with the provision to you of the financial advice you have requested;

·            organisations that assist in operating a financial planning business such as those that provide administrative, financial, accounting, insurance, research, legal, computer or other business services;

·            your representatives or service providers such as your accountant, solicitor, tax agent, stockbroker or bank;

·            organisations involved in a business restructure or a transfer of all or part of the assets of our business or the due diligence procedures prior to any such sale or transfer;

·            government authorities and other organisations when required by law; and

·            organisations that you have consented to your personal information being disclosed to.

We will generally use or disclose your personal information for the primary purpose for which it was collected.

We may also use or disclose personal information:

·            for a related secondary purpose that you would reasonably expect us to use or disclose the information for;

·            in the case of sensitive information, for a directly related secondary purpose that you would reasonably expect;

·            where you have consented to the use or disclosure;

·            where the use or disclosure is required or authorised by Australian law or a court or tribunal order; or

·            in any other circumstances permitted by the Australian Privacy Principles.

Where we engage third-party service providers, we take reasonable steps appropriate to the circumstances to ensure that personal information provided to them is appropriately protected.

We may disclose your personal information to third parties who provide services to us, in which case we will seek to ensure that the personal information is held, used or disclosed consistently with the Australian Privacy Principles.

Direct marketing

We may use your personal information to tell you about products, services, information or events that we reasonably believe may be of interest to you where permitted by law.

You may ask us at any time not to use or disclose your personal information for direct marketing. You may also use any unsubscribe facility included in an electronic marketing communication.

We will not charge you for making an opt-out request. Where the Spam Act 2003 (Cth) applies, we will action an unsubscribe request within the period required by that Act.

You may also ask us to identify the source of personal information we have used for direct marketing. We will respond to such a request as required by the Australian Privacy Principles.

We will not use sensitive information for direct marketing without your consent.

Retention of personal information

We retain personal information for as long as it is reasonably required for the purposes for which it was collected, to provide services to you, to manage our legal and commercial obligations, and to comply with applicable record-keeping requirements.

Financial services laws may require us to retain certain records for specified periods after advice or other services are provided.

When personal information is no longer required for any purpose permitted under the Australian Privacy Principles, and we are not required by law or a court or tribunal order to retain it, we will take reasonable steps to destroy the information or ensure that it is de-identified.

Organisations outside Australia

We may disclose personal information to organisations located outside Australia where this is reasonably necessary to provide our services or operate our business. These organisations may include technology, cloud-storage, administration, paraplanning and other service providers.

The countries in which overseas recipients are currently likely to be located include::

·                   Singapore

·                   Philippines

·                   United States of America

Before disclosing personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, unless an exception under the Privacy Act applies.

In some circumstances, an act or practice of an overseas recipient may be treated under the Privacy Act as an act or practice of IMFG.

Different requirements may apply where:

·            we reasonably believe the overseas recipient is subject to a law or binding scheme that provides substantially similar privacy protections and you can take action to enforce those protections;

·            you expressly consent to the overseas disclosure after we have informed you of the consequences of giving that consent; or

·            another exception under the Privacy Act applies.

We periodically review the overseas locations used by our service providers and will update this Privacy Policy where those arrangements materially change.

Accessing your Personal Information

You may request access to personal information that we hold about you by contacting us using the details below.

We will respond to your request within a reasonable period and will generally provide access in the manner you request where it is reasonable and practicable to do so.

The Privacy Act permits us to refuse access in certain circumstances. If we refuse to provide access, or refuse to provide access in the manner requested, we will give you written notice setting out, where reasonable, the reasons for our decision and the mechanisms available to you to complain about the refusal.

We may need to verify your identity before providing access to personal information.

Correcting Your Personal Information

We take reasonable steps to ensure that personal information we hold is accurate, up to date, complete, relevant and not misleading, having regard to the purpose for which the information is held.

If you believe personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to correct it.

We will respond to a correction request within a reasonable period and will not charge you for making the request or for correcting the information.

If we correct personal information that we have previously disclosed to another Australian entity, you may ask us to notify that entity of the correction. We will take reasonable steps to do so unless it would be unlawful or impracticable.

If we refuse to correct personal information, we will, where reasonable, provide written notice setting out the reasons for the refusal and the mechanisms available to you to complain about the refusal.

If requested, we will take reasonable steps to associate with the information a statement that you consider the information to be inaccurate, out of date, incomplete, irrelevant or misleading.

Automated decision-making

We may use computer programs or automated systems to process personal information in connection with the provision, administration or review of our services.

Where required by the Privacy Act, this Privacy Policy will identify the kinds of personal information used by a computer program to make, or substantially and directly assist in making, a decision that could reasonably be expected to significantly affect your rights or interests, and the kinds of decisions involved.

Data breaches

We maintain processes for identifying, assessing and responding to suspected or actual breaches involving personal information.

Where we have reasonable grounds to believe that an eligible data breach has occurred, we will comply with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

We may also take other steps reasonably necessary to contain, investigate and remediate a data breach and reduce the risk of harm to affected individuals.

PRIVACY ENQUIRIES AND COMPLAINTS

If you have a question about this Privacy Policy, our handling of your personal information or wish to make a privacy complaint, please contact:

Privacy Officer
IMFG Pty Limited
Telephone: 02 9002 0570
Email: info@imfg.com.au

Please provide sufficient information for us to understand and investigate your concern.

We will acknowledge your complaint, investigate the circumstances and provide you with a response within a reasonable period. We will generally aim to respond to a privacy complaint within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Telephone: 1300 363 992

Depending on the nature of the complaint and the financial service involved, you may also be entitled to complain to the Australian Financial Complaints Authority:

Australian Financial Complaints Authority
Website: www.afca.org.au
Telephone: 1800 931 678
GPO Box 3
Melbourne VIC 3001

AFCA's jurisdiction does not extend to every privacy complaint. Where appropriate, we will tell you whether AFCA may be available in relation to your complaint.

*The Australian Financial Complaints Authority or ‘AFCA’ is a new external dispute resolution (EDR) scheme to deal with complaints from consumers in the financial system.