Prime Partners Financial Advice Pty Ltd ABN 50 158 705 358 (“Prime Partners”, “we”, “us”, “our”) holds an Australian Financial Services Licence (AFSL No. 45893) and is committed to protecting the privacy of our clients, prospective clients, and all individuals whose personal information we hold.
This Privacy Policy explains how we collect, use, disclose, store, and manage your personal information in connection with the provision of financial planning and advisory services. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act. Although our annual turnover is below $3 million, we voluntarily comply with the Privacy Act and the APPs in their entirety given the sensitive nature of the financial information we hold.
We are also subject to obligations under the Corporations Act 2001 (Cth), the Australian Securities and Investments Commission Act 2001 (Cth), the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), and other applicable legislation governing the provision of financial services in Australia. This Policy should be read alongside our Financial Services Guide (FSG) and any other disclosure documents we provide.
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true, and whether or not it is recorded in a material form. Sensitive information is a subset of personal information and includes financial details, government identifiers such as Tax File Numbers, health information, and other matters that attract a higher standard of protection under the Privacy Act. We treat all sensitive information with heightened care and only collect it where it is necessary for the provision of our services.
Depending on the nature of your engagement with us, we may collect the following categories of personal information:
We collect personal information:
Where practicable, we collect personal information directly from you. If we collect it from a third party, we will take reasonable steps to notify you.
We collect, hold, use, and disclose your personal information for the following primary purposes:
We will only use your personal information for purposes other than those listed above where you have provided your consent or where it is otherwise permitted or required by law.
We may disclose your personal information to the following categories of third parties:
We do not sell your personal information to third parties. We do not disclose your personal information to third parties for their own marketing purposes without your explicit consent.
In the course of delivering our services, some of your personal information may be transmitted to or accessible from overseas locations, primarily as a result of our use of cloud-based technology platforms and AI-assisted tools whose infrastructure is hosted internationally. Countries where your data may be processed include, but are not limited to, the United States of America and other jurisdictions depending on the technology providers engaged.
Before disclosing personal information to overseas recipients, we take reasonable steps to ensure that those recipients do not breach the APPs in relation to your information. Where Australian Privacy Principle 8.1 applies, we will either obtain your consent to the overseas disclosure or satisfy ourselves that the overseas recipient is subject to substantially similar protections. Please note that where consent is obtained under APP 8.2(b), we may not be accountable under the Privacy Act for the overseas recipient’s subsequent handling of your information.
Prime Partners uses a range of third-party technology platforms and services to support the efficient and compliant delivery of financial services. These include practice management systems, cloud-based productivity and communication tools, investment platforms, compliance systems, and artificial intelligence (AI)-assisted drafting and research tools. We are committed to responsible and transparent use of all technology in our practice and take steps to protect your personal information when engaging with such services.
The table below summarises the categories of technology we currently use and the purposes for which your information may be engaged:
| Technology Category | Purpose | Data Location |
| Practice Management Software | Client record keeping, advice workflow management, SOA and ROA generation, and compliance documentation | Australia (domestic cloud or on-premises hosting) |
| Cloud-Based Productivity and Communication Tools | Email, document preparation, internal collaboration, file storage, and staff communications | Australia and/or international data centres (varies by provider) |
| AI-Assisted Drafting and Research Tools | Supporting the preparation of advice documents, research summaries, strategy notes, and internal workflow processes. AI tools are used as drafting aids only; all outputs are reviewed by a licensed adviser. | Primarily international (including United States-based servers) |
| Financial Product and Investment Platforms | Implementation of financial advice, portfolio administration, transaction processing, and reporting | Australia and/or international (varies by provider) |
| Compliance and Regulatory Reporting Systems | Fee disclosure, consent management, regulatory reporting, and breach management | Australia |
The specific providers engaged within each category may change from time to time as we review and update our technology arrangements. This policy will be updated accordingly when material changes are made and we encourage you to review it regularly. A current register of technology providers is available upon request.
We use AI-assisted tools to support tasks such as drafting financial advice documents, summarising research and strategy notes, reviewing documentation quality, and managing internal workflows. The following safeguards apply to our use of AI tools:
Clients who wish to opt out of having their information engaged in AI-assisted processes should contact our Privacy Officer using the details in Section 12. We will endeavour to accommodate such requests where operationally practicable, though this may affect the efficiency with which we can deliver certain services.
We may be required to collect your Tax File Number (TFN) in connection with the financial services we provide, including matters relating to superannuation, investment accounts, and tax-related advice. TFNs are collected under the authority of the Income Tax Assessment Act 1936 (Cth) and are handled strictly in accordance with the Tax File Number Guidelines 2011 issued by the Australian Information Commissioner.
You are not obliged to provide your TFN. However, without it we may be unable to establish certain financial products on your behalf, or you may be subject to higher withholding tax rates. Your TFN will not be disclosed to third parties except as authorised by law, and will be stored securely with access limited to authorised personnel.
We take the security of your personal information seriously and implement reasonable physical, electronic, and administrative safeguards to protect it from unauthorised access, misuse, loss, modification, or disclosure. Our security measures include:
Despite these measures, no method of electronic data transmission or storage is entirely secure. We cannot guarantee the absolute security of your information and encourage you to contact us promptly if you have concerns about how your information is being handled.
We retain personal information for as long as it is required to fulfil the purposes for which it was collected, or as required by law. Under the Corporations Act, financial advice records must generally be retained for a minimum of seven years. When personal information is no longer required, we take reasonable steps to destroy or de-identify it securely.
We are committed to compliance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). If we become aware of a data breach that is likely to result in serious harm to an individual whose personal information is involved, we will:
We maintain an internal data breach response plan which is reviewed regularly to ensure it remains effective.
Under the Privacy Act, you have the right to request access to the personal information we hold about you and to request its correction if it is inaccurate, out of date, incomplete, irrelevant, or misleading. To make an access or correction request, please contact our Privacy Officer using the details set out in Section 12.
We will respond to your request within a reasonable timeframe, generally within 30 days. In some circumstances we may be required by law to decline access to certain information, or we may charge a reasonable fee for providing access. If we refuse to provide access or correct information, we will provide you with written reasons and advise you of your right to complain to the OAIC.
Our website may use cookies and similar tracking technologies to improve your browsing experience and to analyse website traffic. A cookie is a small text file placed on your device when you visit our website. We use cookies for the following purposes:
You may configure your browser to refuse or delete cookies. Please note that doing so may affect the functionality of our website. Our website may also contain links to third-party websites, for which we are not responsible. We encourage you to review the privacy policies of any third-party sites you visit.
If you have a question, concern, or complaint about how we handle your personal information, or wish to make an access or correction request, please contact our Privacy Officer:
Privacy Officer
Prime Partners Financial Advice Pty Ltd
Email: [email protected]
Post: Locked Bag 5030 Gladesville NSW 2111
Phone: 02 9879 7005
We will acknowledge your complaint promptly and aim to resolve it within 30 days. If we are unable to resolve the matter to your satisfaction, we will advise you of available external complaint avenues.
If you are not satisfied with our response, you may contact:
We review and update this Privacy Policy regularly to ensure it remains current and compliant with applicable law, including any changes to our technology arrangements, regulatory obligations, or business practices. The most current version is available on our website and will be provided to you upon request. We will notify existing clients of material changes in writing or by email where practicable. Continued engagement with our services following notification of an update constitutes acceptance of the revised Policy.
This Privacy Policy is governed by the laws of Australia, including the Privacy Act 1988 (Cth) and the Corporations Act 2001 (Cth). Any disputes arising in connection with this Policy will be subject to the jurisdiction of Australian courts and tribunals.
