We respect your privacy and this notification explains how we handle your information. This notification covers Menninger Capital Pty Ltd ABN 71 160 992 450, Menninger Investment Management Pty Ltd ABN 29 600 624 173, Menninger Advisory Pty Ltd ABN 29 160 992 709 and all its related companies (the ‘Group’), which include banking, financing, funds management, financial planning, superannuation, insurance, broking and e-commerce organisations.
How we collect your information
We’ll collect your information from you directly whenever we can. Sometimes we collect your personal information from third parties, and you may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
How we collect your information from other sources
Sometimes we collect information about you from other sources. We do this only if it is necessary. Instances of when we may need to do this include where:
- we can’t get hold of you, and we rely on publicly available information to update your contact details; and
- at your request, we exchange information with your legal, accounting or other representatives.
When the law authorises, or requires us to collect information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial service providers, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth anti-money laundering laws.
What do we collect via your website activity?
If you’re a client of ours, we monitor your use of the Menninger Capital Client Portal to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
We also know that some clients like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However for all confidential matters, we’ll ensure we interact with you via a secure forum.
To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our mobile banking applications is secure.
We also collect de-identified information if you use one of our Group calculators or other programs. Although the information collected does not identify an individual, it does provide the Group with useful statistics so that we can analyse and improve our web services.
Cookies are small files we send that are stored on your web browser. Different types of cookies are used for different purposes. There are cookies that are active for a single session which, for example, help you finish an application forms or surveys. Then there are the persistent cookies which are stored on your device and help websites remember your information and settings when you visit them in the future.
- To allocate an identification number to your Internet browser (you cannot be identified by this number).
- To see if your browser has previously visited the website and, if so, remember your settings/preferences.
- To track and report on website usage.
- To identify other pages or third parties’ websites your browser accesses.
- To personalise your experience and make it easier for you to do what you want on our websites. For example, we'll provide customised content, support and advertising that may be relevant to your interests and needs.
- To provide enhanced security and fraud detection.
You can change your browser’s cookie settings via your browser privacy settings.
How we use your information
We use your information to provide you with the product or service you asked for, and for other purposes including:
- giving you information about a product or service;
- considering whether you are eligible for a product or service;
- processing your application and providing you with a product or service;
- administering the product or service we provide you, which includes answering your requests and complaints, varying products and services, taking any required legal action, and managing our relevant product portfolios;
- identifying you or verifying your authority to act on behalf of a client;
- telling you about other products or services that may be of interest to you, (this can be via email, telephone, SMS, iM, mail, or any other electronic means including via social media forums) unless you tell us not to (which you can do at anytime)
- allowing us to run our business and perform administrative and operational tasks, such as:
- training staff;
- developing and marketing products and services;
- risk management;
- systems development and testing, including our website;
- undertaking planning, research and statistical analysis;
- determining whether a beneficiary will be paid a benefit;
- preventing or investigating any fraud or crime, including any suspected fraud or crime;
- as required by law, regulation, or codes binding us or any legal reasons; and
- any purpose for which you have given your consent.
You can let us know at any time if you no longer wish to receive direct marketing offers from the Group. We will process your request as soon as practicable.
What happens if you don’t provide your information to us?
If you don’t provide your personal information to us, we may not be able to:
- provide you with the product or service you want,
- manage or administer your product or service;
- verify your identity or protect against fraud; or
- let you know about other products or services that might better meet your financial needs.
Sharing Your Information
We may share your information with other organisations for any purposes for which we use your information.
Sharing with the Group
We may share your personal information with other Group members. This could depend on the product or service you have applied for and the Group member you are dealing with.
Sharing with your representatives
We may need to share your personal information with your representative or any person acting on your behalf (for example, financial advisers, lawyers, settlement agents, accountants, executors, administrators, trustees, guardians, brokers or auditors).
Sharing with third parties
We may disclose your personal information to third parties outside of the Group, including:
- authorised representatives of the Group who sell products or services on our behalf;
- those involved in managing or administering your product or service;
- superannuation and managed funds organisations, and their advisors;
- other financial institutions, such as banks;
- brokers or referrers who refer your application or business to us;
- fraud reporting agencies (including organisations that assist with fraud investigations to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime or misconduct or a serious nature);
- government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
- our accountants, auditors, lawyers and external advisors;
- organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
- mailing houses and telemarketing agencies who assist us to communicate with you;
- our joint venture partners that conduct business with us;
- organisations involved in a corporate re-organisation or transfer of Group assets or business;
- organisations that assist in our product planning, research and development;
- other organisations involved in our normal business practices, including our agents and contractors; and
- where you have given your consent.
Sharing outside of Australia
We run our business in Australia and generally we will not need to share your information with organisations outside Australia. However, where we are obliged to provide information overseas, we might need to ask you before this happens. For example, some nations have enacted laws to prevent tax evasion by their citizens or permanent residents, requiring us to report certain financial information to relevant overseas taxation bodies.
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
If your personal information is shared with organisations outside Australia, those organisations may be required to disclose that information under a foreign law. In such circumstances, we will not be responsible for that further disclosure.
Accessing or Correcting your Information
- Contacting your Menninger Capital Advisor or
- Investor Services Team on +61 7 4728 8000: or
- Writing to:
PO Box 3265
Hermit Park QLD 4812