Privacy
Policy

This Privacy Policy applies to Viridian Financial Group Ltd (ABN 67 605 994 741) and its controlled entities including Viridian Advisory Pty Ltd Viridian Private Wealth Pty Ltd, Infinity Capital Solutions Pty Ltd, Infinity Asset Management Pty Ltd, Infinity Portfolio Management Pty Ltd and Infinity Capital Finance Pty Ltd (the Viridian Group, Viridian, us, we, our).

This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (Privacy Act). Viridian also seeks to comply with the Spam Act 2003 (Spam Act) that is aimed at reducing the number of unsolicited and commercial messages that you receive. This Privacy Policy applies to the collection, storage, use and dissemination of your personal information.

The Viridian Group is a provider of portfolio management, lending and wealth advisory services. We are committed to maintaining a policy of strict confidence concerning your (you, your) personal information (Privacy Policy).

Viridian may collect, hold and store personal and business details of you when you engage with us directly; however, we may also collect information about you from other people and organisations including when you:

  • enquire about, or use our products or services
  • contact us to make an enquiry or give feedback
  • visit our website or use our digital services
  • participate in other activities we offer such as surveys or seminars
  • visit one of our offices
  • talk to us or do business with us.

By engaging with us, you accept the terms of this Privacy Policy.

1.
Collecting Personal Information

Why do we collect personal information?

We collect personal information (meaning information or an opinion about an identified individual or an individual who is reasonably identifiable) in order to:

comply with our legal obligations, such as verifying your identity,

  • promote and provide the products and services offered by the Viridian Group,
  • manage communications and promotional activities in respect of our clients and prospective clients,
  • enhance and improve your use of the website, our products and services,
  • respond to any questions, comments, queries or complaints,
  • disperse marketing materials and keep you informed about new products, initiatives, and opportunities,
  • for internal business purposes, for example, to research and develop the website, digital portals, our other products and services, record keeping, data analytics, auditing, or training, and
  • as required or authorised by law, including under the Australian Privacy Principles.

Can you deal with us without identifying yourself?

When contacting us, you have the option to either not identify yourself or to use a pseudonym. However, this will not apply if it is impracticable for us to communicate with you that way, or if we are required or authorised under Australian law (or a court or tribunal order) to only deal with individuals who have identified themselves.

Whose personal information do we collect?

We collect or hold personal information about individuals who are:

  • prospective, current, and former clients, and
  • our service providers, agents or affiliates and their staff.

What personal information do we usually collect?

We collect a wide range of personal information relevant to assist in the delivery of products and services to you. The type and amount of information depends on the particular business context and where it is relevant to the service being provided. For example:

  • When you apply for products or services, we may ask for identification information. This could include your name, address, contact details and date of birth. We may also collect your tax file number if it is relevant to the services we are providing, if we are authorised to collect it and if you choose to supply it.
  • In some circumstances the law requires us to obtain and verify details of photographic and non-photographic identification documents.
  • When you interact with us digitally, we may collect information such as cookies as you browse our website (cookies gather and store information about the way you use that website).
  • Throughout the life of your product or service, we may collect and hold additional personal information about you. This could include transaction information or making a record of queries or complaints you make and, if you make an insurance claim, collecting additional information to assess the claim.
  • For making employment decisions and managing our staff, we also collect information about our employees and prospective employees.
  • For the safety of our staff and clients, we use camera surveillance, such as CCTV, to monitor our offices. When entering our offices, the personal images of staff and clients may be collected by Viridian in connection with the management and security of those offices. Should an incident occur, the footage may be provided for law enforcement purposes. Your information will not be given to any other person or agency unless authorised or required by law.

Do we collect sensitive information?

  • If you apply for insurance, we may collect information about what is being insured, your nominated beneficiaries, and your health and financial situation, depending on the type of insurance. This also may include information about your health and other medical information, lifestyle information that relates to insurance, occupational information, and criminal history. This type of information may be considered sensitive information and therefore we would not collect it unless we have your informed consent, or the use of the information is otherwise permitted under the Privacy Act.
  • We may also collect voice or biometric information to verify your identity or authorise transactions.

How do we collect personal information?

We collect personal information by various means and mediums, depending on the services we are providing and our client needs.

We will generally collect personal information directly from an individual client, service provider, agent, or affiliate, unless it is unreasonable or impracticable to do so. We may also collect personal information from third parties such as your representatives or external data suppliers. When we have collected personal information about you, we will notify you at the point of collection, or as soon as practicable, to ensure that you are aware of such collection and its purpose.

If someone other than you provide us with personal information about you, for example our third-party insurance partner provides us with personal information for the purposes of performing any services we are engaged to perform, the notification will usually be provided to you via that third party.

What if we receive unsolicited personal information?

If we receive or are provided with personal information that we did not ask for and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable. However, this notice will not be provided if doing so would be a breach of an obligation of confidence. If we could not have collected this personal information, we will lawfully de-identify or destroy the personal information.

2.
COOKIES

When you visit our website or use any of our digital services, the server may attach a “cookie” to your computer’s memory. A “cookie” assists us to store information on how visitors to the Site use it and the pages that may be of most interest. If you choose, you are able to configure your computer so that is disables “cookies” or does not accept them.

Our servers may record other information about or relating to you, such as the time and date of your visit or the IP address assigned to the computer you are using to access the Site. In many cases, we cannot and do not use this information to identify you personally. Rather, we simply use this information for the operation of the Site, to maintain quality of the Site, and to provide general statistics regarding the use of the Site.

3.
Use and disclosure of information

Where we collect personal information to deliver our products and services, we may also use and disclose the information for another purpose that is related to the delivery of those products and services (or that is directly related to that purpose in the case of sensitive information). Your personal information may be disclosed by us to the following third parties:

  • other companies within the Viridian Group
  • our agents, contractors, and external service providers (for example, mailing houses, payment systems operators, identification verification providers and technology service providers)
  • authorised representatives and credit representatives who provide products and services on our behalf
  • insurers, re-insurers, health care providers and other organisations, who in conjunction with us, provide the products or services
  • other financial services organisations, including banks, superannuation funds, stockbrokers, custodians, fund managers and portfolio service providers
  • debt collectors for debt collection activity
  • our financial advisers, legal advisers, or auditors
  • your representatives (including your legal adviser, accountant, mortgage broker, financial adviser, executor, administrator, guardian, trustee, or attorney)
  • fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct were authorised by law
  • external dispute resolution schemes, and
  • regulatory bodies, government agencies and law enforcement bodies in any jurisdiction.

To protect personal information, we use reasonable efforts to enter into contracts with our service providers that require them to comply with the Privacy Act and cyber accreditation ISO29001:2021. These contracts oblige them to only use the personal information we disclose to them for the specific role we ask them to perform. Generally, we disclose personal information to organisations that help us with our business.

We may also disclose your personal information to others outside the Viridian Group where:

  • we are required or authorised by law or where we have a public duty to do so,
  • you may have expressly consented to the disclosure, or the consent may be reasonably inferred from the circumstances, or
  • we are otherwise permitted to disclose the information under the Privacy Act 1988.

How will your information be used for direct marketing purposes and how can I opt out?

We may use personal information about prospective, current, and past clients for the purpose of direct marketing of our products, events and services that may be of relevance to you. Direct marketing communications may be sent via post, e-mail, telephone, social media sites or other means. However, we will give you the opportunity to opt out of receiving further direct marketing communications and you can unsubscribe at any time by notifying us that you wish to do so.

4.
Access to and accuracy
of your information

We take reasonable steps to ensure that the personal information held by us is accurate, complete, and up to date. If you believe that any of your personal information is inaccurate, please contact us and we will take reasonable steps to correct it.

If you request access to the personal information, we hold about you, we will respond to your request within a reasonable period of time and, where reasonable and practicable, give access to the information in the manner you request. You have a right to access the personal information we hold about you subject to any exemptions allowed under the Privacy Act. You may request this information by contacting our Privacy Officer. If you request your entire file, and it is particularly complex or requires a detailed searching of our records, we may charge a reasonable fee for providing that information.

5.
Transfer of information overseas

We disclose your personal information to third parties overseas who provide services to us. The countries in which they are located include the Philippines, Nepal, and Croatia. We will use reasonable efforts to ensure that the recipient company is subject to a law or scheme that protects your information in a way that is substantially similar to our Privacy Policy and Australian law.

6.
Your consent

By engaging with us and using our products and services, you consent to the collection and use of the information you have provided to us for the purposes described in this Privacy Policy. Our website uses cookies, you consent to the use of cookies and other tools unless you choose not to accept our cookies or delete this data from your device.

7.
Storage and Security

Much of the information we hold about you will be stored electronically in secure data centres which are located in and owned by either the Viridian Group or our external service providers. Some information we hold about you will be stored in paper files. We use a range of physical and electronic security measures to protect the security of the personal information we hold. For example:

  • access to information systems is controlled through identity and access management
  • employees are bound by internal information security policies and are required to keep information secure
  • all employees are required to complete training about information security, and
  • we regularly monitor and review our compliance with internal policies and industry best practice.

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or securely store your personal information in accordance with our document retention policy.

8.
Variation and consent to variation

We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy so that you are aware of any variations made to this Privacy Policy. You will be deemed to have consented to such variations by your continued use of our website or our services following such changes being made.

9.
Complaints and further information

If you are concerned about how your personal information is being handled or if you have a complaint about a breach by Viridian of the Australian Privacy Principles, please contact us using the details below:

The Privacy Officer
Level 17, 120 Collins Street
Melbourne, Victoria, 3000
Phone: (03) 8559 3301
Email:

We will acknowledge your complaint as soon as we can after receipt of your complaint and will aim to resolve the matter quickly and fairly within 30 days.

If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

The Commissioner can be contacted at:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: www.oaic.gov.au

You can also lodge a complaint about Privacy with the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers.

Australian Financial Complaints Authority
GPO Box 3
Melbourne VIC 3001
Phone: 1800 931 678 (free call)
Email:

View Whistleblower Policy