Privacy Policy

(Effective date 27 April 2020)

At Futurity Investment Group Limited ACN 087 648 879 AFSL 236665, ACL 236665 (we or us), your privacy is important to us. We are committed to protecting your privacy when managing your personal information, which includes information about beneficiaries and/or bond guardians where relevant. We have policies and procedures in place to ensure that all personal information is handled carefully and securely in accordance with:

• in Australia, the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth); and
  
  
• in New Zealand, the Privacy Act 1993 and any other relevant law.
  
  

The purpose of this Privacy Policy is to tell you:

• what kind of personal information we may gather;
  
  
• how we may use that information and the choices you have regarding our use of such information;
  
  
• whether we disclose your personal information to anyone;
  
  
• how you may enquire, access and/or seek correction of your personal information and our access and correction handling procedure; and
  
  
• how you may alert us about an alleged breach of the APPs and our complaint handling procedure.
  
  

Collection of information

The types of information that we collect from you will depend on the circumstances of collection and on the service that we are providing to you. Our primary purpose in collecting information is to provide a range of products, information and resources to support children’s education from their early learning stage through to post-secondary studies. These include but are not limited to:

• Futurity Education Bonds, to create dedicated education vehicles for investors;

• Tuition Instalment Loan, an annual school fee payment service;

• Futurity Education loans, credit facilities to assist with the streamlining of education expenses;

• memberships and member-only discounts on products and services, as well as limited offers and competitions from time to time.

We need to collect, hold, use and disclose information that allows us to perform our current business functions or activities (and any others we adopt from time to time), any related or consequential functions and any activities or functions that are known, consented to or reasonably expected by you.

Examples of the information we may need include your name, address, birth date and contact details (and evidence of such e.g. passport), the name, birth date and address of your children, the school(s) or institution(s) your children attend, your bank account or credit card details, your employment details, your family circumstances, financial information, education aspirations and objectives etc. This list is not exhaustive.

Personal information

The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in us being unable to provide you with the product, service or assistance you require. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection. You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.

Sensitive information

We do not generally collect sensitive information, such as racial or ethnicity information, political opinions or associations, criminal records as defined under the Privacy Act. We may from time to time collect health information but only to the extent necessary for us to provide services to you.

Unsolicited information

Where unsolicited information is received by us (such as through any Facebook page or other social media platforms we operate or may establish) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for us to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.

Information we collect automatically

When you visit our Website(s) we may collect certain information by automated means such as through the use of cookies, other automated devices and website tracking tools such as Google Analytics. We use Google Analytics to collect information about how our Website(s) are used. Google Analytics generates statistical and other information about websites by means of cookies stored on users’ computers. Google may collect, transfer, store, and process this information on its servers located in the United States. We will not use Google Analytics to track or collect any personal information from visitors to our Website(s). You can read about how Google Analytics collects and processes data at ‘How Google uses data when you use our partners’ sites or apps’. If you do not want information relating to your visit to our Website(s) reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more information see 'Google Analytics Opt-out Browser Add-on’.



The type of information we may collect by automated means includes:

• your visiting domain name or IP address;
  
  
• the device, browser, operating system type and screen resolution you use;
  
  
• information on actions taken at our Website(s) such as navigation patterns (ie. pages viewed and downloaded; products viewed and/or purchased) and the date, time, duration and number of times you visited our Website(s);
  
  
• the previous site you visited;
  
  
• the geographical location (such as the country and city of origin) from where you accessed our Website(s); and
  
  
• the website you came from (if any), search terms or any other webpages that led you to our Website(s).

You can change the privacy settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer. However, by blocking or deleting cookies used for our Website(s), you may not be able to take full advantage of services offered via our Website(s). This is because cookies are used to help you navigate the Website(s) and to perform certain functions when using our Website(s) such as delivering content specific information to you.

The information we collect automatically is also used for statistical and administrative purposes (e.g. the number of visits by visitors to our Website). Analysing the way in which visitors utilise our Website(s) enables us to improve our services. The information is not used in any way to uniquely identify a customer and we do not collect information about the identity of the visitors unless they voluntarily provide that information. Visitors or their browsing activities (other than previously stated) will not be identified except in the event that any law requires us to disclose or permit a law enforcement agency to inspect the service provider's logs.

Information from third parties

Our website also contains links to the websites of third-party providers of goods and services (Third- Party websites). If you have accessed Third Party websites through our website and if those third- parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties.

Where you access a Third Party website from our website, cookie information, information about your preferences or other information you have provided about yourself may be shared between us and the third party. We are not responsible for the content, privacy practices or business practices of any website or company except our own.

Online applications

When you send a completed online application to us, we retain the information contained in that application. We are able to then use that information to provide any assistance that you require. You can also suspend and save online applications, so you can complete and send the applications at a later time. If you suspend or save your application, the information that you have entered will be retained in our systems so that you may recover the information when you resume your application. Online applications that have been suspended or saved may be viewed by us.

Method of collection

This personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way.

We collect your personal information when you deal with us directly, including via our website(s) or our Facebook, Instagram or other social media platforms we operate or may establish, via forms or correspondence (ie by mail or email), over the phone or in person. We may also collect information about you that is publicly available or made available by third parties. We may also collect your personal information from credit reporting bodies, employers and other people such as accountants and lawyers.

We will not ask you to supply personal information publicly over Facebook, Twitter or any other social media platform that we use.

Use of information

Use of personal information

We will use the personal information you have chosen to provide us for the purpose for which you provided it. We will not use it for any other purpose without your consent, unless permitted or required by law. Generally, we will use your personal information for the following purposes:

• to open or administer your Futurity Education Bonds and to process ongoing transactions such as switching between investment options;

• to establish you as a customer of Futurity Lending Loans, Tuition Instalment Loan or other credit facilities;
  
  
• to provide or deliver relevant products or services;
  
  
• to respond to any enquiries, feedback or complaints made by you, or your clients;
  
  
• direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;

• to improve our products and services and making them more relevant to you;

• to improve our Website(s) or any social media platforms we operate or may establish;
  

• to process and assess employment applications for current and future positions; and

• otherwise managing our internal business operations and processes.

We may aggregate and/or de-identify the information we collect to limit or prevent identification of any particular user or device. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

Direct marketing

We will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services (subject to obtaining your prior consent if the entity is not a related body corporate).

Any direct marketing materials that you receive from us via email may utilise open tracking so that we can monitor delivery and receipt of the material. We will provide you with the opportunity to opt out of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.

Use of information collected automatically

In addition to the uses described above, we use information collected automatically to:

• monitor the use of our Website(s);

• help us make improvements to the Website(s); and
  
  
• offer relevant information and services to as many users as possible.
  
  

Identification

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, you may request to do business with us anonymously or via a pseudonym and we will comply where it is lawful and practicable to do so. If it is not possible or if there are any consequences of us doing business with you anonymously or via pseudonym, we will let you know.

Access to and updating of your personal information

You can ask us, at any time, to confirm whether we hold information about you and to provide you with access to that information. You can ask us to correct or update any information we hold about you and we will record and action your request at no expense to you. If we are unable to provide access or comply with your request we will explain why. You can contact us to correct or update any information we hold about you by completing our online enquiry form or via the relevant customer portal.



Disclosure

There will be occasions where it will be necessary for us to disclose your personal information to third parties. We may disclose your personal information:

• to contractors and third-party service providers that we use in the ordinary course of our business or as is reasonably necessary to fulfil a particular business purpose, function or activity of ours. This includes organisations such as marketing agencies, customer relationship management companies, data processing companies, survey providers, printing and mailing houses, delivery companies, credit reporting bodies, debt collection agencies, information technology support, and data service providers, who may also disclose your personal information to our third party partners for the purpose of personalising the advertising you receive from us and them (you can opt out of this type of activity by contacting us on the details below);
  
  
• to our related entities and subsidiaries, authorised agents, or an organisation with which we have or form a joint business or collaborative arrangement;
  
  
• where necessary, to external advisers (e.g. professional advisers such as legal advisers) or with regulators or other bodies (e.g. for the investigation and resolution of complaints or disputes made by you or other users); or
  
  
• to companies that provide information systems to us;
  
  
• to government authorities or other third parties as required by law;
  
  
• where we are authorised to do so by law, such as to process Anti Money Laundering and Counter Terrorism identity and verification checks;
  
  
• to any person or entity, where you have provided us consent; and
  
  
• for any other purpose that you have consented to.
  
  

Prior to disclosing any of your personal information to another person or organisation, we will take reasonable steps to satisfy ourselves that:

• the person or organisation has a commitment to protecting your personal information at least equal to our commitment; or
  
  
• you have consented to us making the disclosure.
  

Transfer of information outside Australia

Our offices and personnel are located in Australia and your information will be collected, held, used and disposed here.

We utilise a cloud service provider which has back-up servers located overseas (in Singapore), as well as a Customer Relationship Management (CRM) provider that processes data in the United States. Your personal information will be transferred outside Australia to these overseas locations. Employee data, including prospective employee data, is processed and stored by a cloud service provider in Canada. Such transfer is subject to obligations on the recipient to act in a manner consistent with our privacy policy and statement and Australian privacy and information transfer/management laws and requirements.

No sale of personal information

Under no circumstances will we sell or receive payment for disclosing your personal information.

Security

The security of your information is important to us. We operate secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. We have implemented acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.

Only our authorised personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.

We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.

Children’s privacy

We are mindful and respectful of the privacy of children. As a risk management practice we will seek to engage with children under the age of 16 only via their parents, families, guardians or carers. We do not knowingly collect personal information directly from children under the age of 16.

Complaints about privacy and our complaint handling procedure

If you have any complaints relating to the management of your personal information or if you believe we have breached any of the APPs, please contact our Privacy Officer via our online enquiry form.

Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint. If our Privacy Officer decides that there has been a breach of the APPs, s/he will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing.

If you are still not satisfied after lodging a complaint with us and have given us reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:

• Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749
  
  
• TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls).
  
  

TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)

Post: GPO Box 2999 Canberra ACT 2601 Fax: +61 2 9284 9666
Email: enquiries@oaic.gov.au

Contact Privacy Officer

Please contact our Privacy Officer via our online enquiry form if you would like to:

• enquire about or request access and/or update your personal information;
  
  
• report an alleged breach of your privacy rights or make a complaint or;
  
  
• enquire about our Privacy Policy
  
  

Miscellaneous

Personal information has the same meaning as in the Privacy Act 1988 (Cth) in Australia and the Privacy Act 1993 in New Zealand.

Website(s) refers to all websites which are owned, operated or under our control including www.futurityinvest.com and www.asg.com.au

We reserve the right to modify or amend this Privacy Policy at any time. The effective date will be displayed at the beginning of the policy.

Further Information on Privacy

For more information about your privacy rights:

• in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au
  
  
• in New Zealand, visit the Office of the Privacy Commissioner’s website, www.privacy.org.nz



APPENDIX

Credit Reporting Policy (Australia only)

Credit applications by businesses for our services

We provide ‘consumer credit’ for the purposes of the Privacy Act 1988 in Australia to consumers who apply for credit in relation to our goods and services. We do not provide any commercial credit.

References to you and your in this credit reporting policy are references to individuals in relation to whom we hold credit-related information for the purposes of the Privacy Act 1988 in Australia in connection with such credit. This policy provides details about our management of such information.

Credit-related information means:

• Credit information, which includes your identity: the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information; default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and
  
  
• Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

Credit information and credit eligibility information may include:

• identification information: such as your name, address, date of birth or employer;
  
  
• consumer credit liability information: being information about consumer credit accounts you hold with other credit providers;
  
  
• details about information requests made to Credit Reporting Bodies (CRB): such as the fact that we or another credit provider have requested credit reporting information about you from a CRB to assess a credit application and various details about the credit you have applied for;
  
  
• default information: being information about overdue payments owed by you in connection with consumer credit which have been disclosed to a CRB by other credit providers;
  

  

• payment information: being information that an overdue payment has been repaid;
  
  
• information about serious credit infringements;
  
  
• new arrangement information: being information about certain credit-related arrangements you may have entered with another credit provider in connection with a consumer credit default or serious credit infringement;
  
  
• court proceedings information: being information about certain credit-related judgments;
  
  
• personal insolvency information: being information recorded in the National Personal Insolvency Index about bankruptcy or various other insolvency-related matters;
  
  
• publicly available information about activities relating to credit worthiness.

Credit eligibility information also includes credit worthiness information that we may derive from data we receive from a CRB, such as a credit risk score.

We may collect credit information about you in any of the circumstances described above under the heading "Method of collection". We collect credit eligibility information from CRBs but may collect it from other third parties where permitted by the Privacy Act 1988 in Australia (such as from other credit providers with your consent).

We store and safeguard your credit information and credit eligibility information in the manner described in this Privacy Policy.

How we use and when we disclose your credit information and credit eligibility information

We may disclose your credit information to CRBs. Those CRBs may then include that information in credit reporting information that they provide to other credit providers to assist them to assess your credit worthiness. For example, we may disclose to a CRB the type of consumer credit, and the amount of credit, sought in your application for credit with us.

Our use and disclosure of credit eligibility information is regulated by provisions of Part IIIA of the Privacy Act 1988 in Australia and the Credit Reporting Privacy Code. We will only use or disclose such information for purposes permitted by these provisions, such as:

• to process an application for credit with us in relation to our goods and services;
  
  
• to manage the credit we provide and collect overdue payments; or
  
  
• where a disclosure is required or authorised under an Australian law or a court/tribunal order.



Correction of and access to credit information and credit eligibility information

To request correction of, or access to, your credit eligibility information please contact our Privacy Officer as outlined above.

Complaints regarding our compliance with credit reporting requirements

If at any time you would like to make a complaint about whether we have complied with Part IIIA of the Privacy Act in Australia 1988 or with the Credit Reporting Privacy Code please contact our Privacy Officer so that we may resolve your concerns.

If you make such a complaint, we will handle that complaint in accordance with our complaints process as described above. We may need to consult with a CRB or another credit provider to respond to a complaint. If we need more than 30 days to resolve your complaint, we will keep you informed of our processes and timeframes.