Privacy Policy

generation asset management

Privacy Policy

Generation Asset Management Pty Ltd and Generation Asset Management Holdings Pty Ltd (“we” or “us”) are committed to protecting your personal information in accordance with the Australian Privacy Principles provided under the Privacy Act 1988 (Cth). The principles regulate the way organisations collect, use, disclose, keep secure and give people access to their personal information.

What personal information do we collect?

We collect personal information so that we can provide you with our services and to comply with our regulatory obligations.

The type of personal information we may collect from you includes (but is not limited to) your name, contact details (such as your residential address, email address and telephone number), date of birth, your driver’s licence and/or passport, tax file number and bank account details.

We may also require copies of any relevant trust deeds, partnership agreements, constitutions or articles of association, which may be needed to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act.

In addition, we may collect contact details of your representatives with whom we deal.

How do we collect personal information?

We generally collect information about you when you register with us or complete an Agreement.

In most cases, we will collect your personal information directly from you. However, we may also collect your personal information from other sources, such as your financial adviser or accountant.

If you do not provide us with the personal information requested, we may not be able to provide some or all of the services you want us to provide or the process applications for you.

How do we use your personal information?

We use personal information for business purposes – the purpose for which it was disclosed to us or related purposes which would reasonably be expected.

Those purposes include:

  • to establish and manage your investment accounts;
  • to communicate with you; and
  • to comply with relevant laws, regulations or court orders.

We may use personal information provided to us to verify your identity and/or to prevent fraud, crime or other activity that may cause harm.

How do we store and protect your personal information?

We use personal information for business purposes – the purpose for which it was disclosed to us or related purposes which would reasonably be expected.
Those purposes include:

• to provide you with advice and other financial services;
• to establish and manage your investment accounts;
• to communicate with you;
• to enable us to inform you about new and existing products and services; and
• to comply with relevant laws, regulations or court orders.

We may use personal information provided to us to verify your identity and/or to prevent fraud, crime or other activity that may cause harm.
How do we store and protect your personal information?

We regard the security of your personal information as a priority and take reasonable steps to protect your information from misuse, loss, unauthorised access, use, modification or disclosure.

We hold personal information in secure computer storage facilities; on paper-based files; as well as in other formats. We use a range of security measures to protect the personal information we hold.

You should be aware that there are security risks in transmitting information via email or through the internet. You should consider these potential risks when deciding how you want to provide information. If you do not wish to use email or the internet other arrangements can be made.

Our staff who handle personal information for us are trained on the importance of maintaining the privacy and the confidentiality of personal information.

We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal reporting or document retention requirements. When your personal information is no longer needed it will be deleted, destroyed or de-identified.

In the event of a data breach, we have measures in place to manage and respond to the data breach. We must comply with the Notifiable Data Breaches scheme which requires us to notify affected individuals and the Office of Australian Information Commissioner (OAIC) when a data breach involving personal information is likely to result in serious harm.

Who do we disclose your personal information to?

There are circumstances under relevant legislation where we are required to disclose personal information and we may be required by law to disclose your personal information. These include:

  • to the Australian Government regulators such as the OAIC, Australian Tax Office (ATO), the Australian Securities and Investments Commission (ASIC), the Australian Transaction Reports and Analysis Centre (AUSTRAC), and to other regulatory or government entities;
  • as required by a court order; and
  • in accordance with the Family Law Act requirements.

We may disclose personal information to anyone authorised by you or in respect of whom you have provided your consent.

We may also disclose personal information in managing and administering our business to the following:

  • our external services providers and contractors who supply services to us; and
  • our auditors, professional advisers and insurers.

Where relevant we will take all reasonable steps to ensure that they protect your information in the same way that we do.

Do we send personal information to overseas recipients?

We may store your information in “the cloud” or using other types of electronic storage. As electronic storage can be accessed from various countries it is not always possible to ascertain in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than Australia.

How can you check, update or change the information we are holding?

In many circumstances you can request access to your personal information that we hold. Sometimes it is not possible for us to give you access in which case we will explain why.

We will take reasonable steps to correct personal information held about you where we are satisfied that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading or, you request us to correct the information.

How can you contact us about privacy?

You can send an email to operations@generationam.com.au or write to us at Generation Asset Management at 32/328 Reserve Road, Cheltenham, VIC 3192.

How can you make a complaint about privacy?

If you wish to make a complaint about how we have handled your personal information, you can email our Privacy Officer at kerry@generationam.com.au or write to our Privacy Officer, at Generation Asset Management Pty Ltd at 32/328 Reserve Road, Cheltenham, VIC 3192.

If you feel your complaint has not been satisfactorily addressed in the first instance, or that it is taking too long to resolve, you may contact the Office of the Australian Information Commissioner to have the complaint heard and determined. To contact the OAIC call 1300 363 992 or find them online at www.oaic.gov.au

Review of this Policy

This Privacy Policy is effective as at February 2025.
We will update the Policy from time to time in response to legislative changes and business requirements.