Privacy Policy

1. Introduction

Bombora Advice Pty Ltd (“Bombora”, “we”, “our”, “us”) is bound by the Privacy Act 1988, including the Australian Privacy Principles (APPs), and recognises the importance of ensuring the confidentiality and security of your personal information. All third parties (clients, suppliers, sub-contractors, agents) who access or use personal information collected and held by Bombora must abide by this Privacy Policy. This Privacy Policy is available free of charge and can be downloaded from our website.

Definitions

• Disclosure of information: Providing information to persons outside Bombora.
• Personal information: Information or an opinion relating to an individual that can identify that individual.
• Privacy Officer: The contact person for privacy concerns or complaints.
• Sensitive information: Includes racial or ethnic origin, political opinions, religion, union membership, sexual preferences, criminal record, and health information.
• Use of information: Use of information within Bombora.

2. What Kind of Personal Information Do We Collect?

• Name
• Address
• Phone numbers
• Email addresses
• Occupation
• Bank account details
• Driver’s licence details
• Financial information including investments, insurance, estate planning, tax, and health data
• Covid check-in information

3. How Do We Collect Personal Information?

We collect information directly from you or via third parties such as verification services or marketing agencies. Website traffic may be analyzed anonymously using cookies. We do not collect sensitive information without consent unless permitted by law. Anonymous or pseudonymous dealings are not available due to practical and legal constraints.

4. Unsolicited Personal Information

We destroy or de-identify unsolicited personal information unless it is relevant to our purposes. If combined with other required data, we retain it securely.

5. Who Do We Collect Information About?

• Clients
• Potential clients
• Service providers or suppliers
• Prospective employees, employees, and contractors

6. Website Collection

We collect data via completed forms on our website and use third-party analytics tools. Data collected is anonymous. The Privacy Policy is available through our website’s privacy link.

7. Why Do We Collect and Hold Personal Information?

• To provide and improve services
• Review ongoing needs
• Send relevant information or marketing
• Comply with legal obligations
• Assist in providing financial and risk services

8. Who Might We Disclose Information To?

• Related entities
• Agents, contractors, and service providers
• Legal and regulatory bodies
• Financial institutions and product issuers
• Any authorised party or as required by law

9. Sending Information Overseas

We may disclose information to service providers located in:

• Philippines
• South Africa
• Japan
• Malaysia
• Vietnam

We take reasonable steps to ensure overseas recipients comply with Australian privacy standards. If not, we obtain your consent prior to disclosure.

10. Management of Personal Information

We secure personal information via passwords, restricted access, physical and electronic protections, and remote work protocols including two-factor authentication, storage restrictions, and disclosure policies.

11. Direct Marketing

We may use your information for direct marketing if you would reasonably expect it and it is not sensitive information. You can opt-out at any time. We also inform you of the source of information upon request.

12. Identifiers

We do not adopt government-issued identifiers for our internal purposes unless allowed by law.

13. Keeping Personal Information Accurate

We aim to keep your information accurate and up to date. You may request updates and corrections, and we will notify third parties where applicable. No fee applies for corrections.

14. Accessing Your Personal Information

You may request access to your personal information by contacting our Privacy Officer. Access is typically granted within 30 days, and we may charge an administrative fee for physical copies.

15. Updates to This Policy

This policy may be updated due to changes in law or business operations. Updates will be made available on our website.

16. Responsibilities

Management is responsible for informing and training employees and third parties on this Privacy Policy. Non-compliance may result in disciplinary action.

17. Non-Compliance and Disciplinary Actions

Privacy breaches must be reported. Ignorance is not an excuse. Disciplinary action may apply for non-compliance.

18. Complaints Handling

To lodge a privacy complaint, contact:

• Mail: The General Manager, Bombora Advice Pty Ltd, PO Box 5154, Laburnum Vic 3130 (mark “Privacy Policy Concerns”)
• Email: info@bomboraadvice.com.au

If unsatisfied, contact the Office of the Australian Information Commissioner:

• Phone: 1300 363 992
• Mail: GPO Box 5218, SYDNEY NSW 2001
• Online: Submit a complaint online

19. Contractual Arrangements with Third Parties

We ensure third-party agreements include privacy obligations, such as limiting access, using data securely, and only disclosing to approved organisations.

20. Your Rights

This Privacy Policy explains how:

• You may access and correct your personal information
• Alternative identity verification methods are available
• You can lodge a privacy complaint
• We handle privacy complaints