Part 1

Privacy Statement for those registered to complete the Test

What Personal Information Does FinaMetrica Collect?

We collect and process the following information about you:

  1. Your name (which may be generic or fictitious) and, if you are registered to do the Test on-line, your email (which may be generic or fictitious) and, if you access the Website, your IP addresses;
  2. Your answers to the risk tolerance questionnaire;
  3. In some situations, you may have the option to enter optional demographic and research information upon completion of the risk questionnaire for research purposes to understand the pattern of risk tolerance in the community. E.g. whether male is more risk tolerance than female.

 

When is that information collected?

We collect the information in paragraphs (a), (b), (c) and (d) (“Your Information”) from your financial advisor, from associated website, or other third party who registered you to have access to the Test (“Your Financial Advisor”) or through your use of the Website. You will have consented to Your Information being shared with us, where information is provided via a third party.

How is Your Information used and processed?

Your email address is used to send an email to you notifying you of your username and password.

Your name is used for the purpose of identifying you in the database at the Website - for example, if you lost your FinaMetrica username and password, we would use your name to search for and retrieve them. Your name may be a generic or fictitious name.

Your IP address is used to assist us to establish where the Test was completed in the event of a legal dispute.

The answers to the risk tolerance questionnaire are used by FinaMetrica for the primary purpose of producing your risk tolerance report, including your risk tolerance score and information for your personal use in the management of your financial affairs or for use by your financial advisor in advising you with regard to your financial affairs or for use by the third party through whom you were registered to do the Test.

Your information is necessary for the performance of a contract between you and FinaMetrica, the performance of a contract between you and your financial advisor in advising you with regard to your financial affairs, the performance of a contract between you and a third party through whom you were registered to do the Test or the implementation of pre-contractual measures taken at your request.

FinaMetrica will use a copy of the risk tolerance and optional demographic and research information (“Research Information”) you supply without your personal identifiers for secondary purposes of researching risk tolerance and risk-taking behaviour and to further develop the Test.

ALL INFORMATION THAT COULD IDENTIFY YOU WILL BE REMOVED FROM THIS RESEARCH INFORMATION

The anonymous Research Information will be combined with similar information from other people who have completed the Test into an existing separate aggregated, anonymous database which may be supplied to third parties.

Processing and Transfer of Your Information to Australia

Our Subscription Service including our Test is hosted by our provider located in Sydney, Australia given FinaMetrica provides its services from Australia. The information provided by you or about you by a third party such as your financial advisor will be processed and stored on our secure server(s) located in Australia.

If you are from a country outside Australia, the various electronic communications will necessarily result in the transfer of information across national boundaries.

The GDPR sets out in detail the factors the EU Commission is to consider when deciding whether a third country or international organisation ensures an adequate level of protection (Article 45). The European Commission has so far not recognized Australia as providing adequate protection. We rely on Article 49(1)(b) for the transfer of Personal Data outside of the EEA to Australia. If you are based in the EEA, the transfer is necessary for the performance of a contract between you and FinaMetrica, the performance of a contract between you and your financial advisor in advising you with regard to your financial affairs, the performance of a contract between you and a third party through whom you were registered to do the Test or the implementation of pre-contractual measures taken at your request.

Disclosure of Your Information Outside of Australia

Your Financial Advisor may be located outside of Australia and/or may retrieve or download Your Information or may initiate an automatic transfer of Your Information on a regular basis to a computer or server located outside of Australia. Your Financial Advisor may not be an Australian entity or may not be regulated by the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs).

By using or participating in our services and/or providing us with Your Information, you consent to the disclosure of Your Information to Your Financial Advisor, on the basis that if Your Financial Advisor engages in any act or practice that contravenes the APPs it may not be accountable under the Australian Privacy Act 1988 and you may not be able to seek redress under the Act.

The countries in which Your Financial Advisor may be located include Australia, Austria, Brazil, Canada, Cyprus, Germany, Hong Kong, India, Malaysia, Netherlands, New Zealand, Portugal, Republic of Ireland, South Africa, Switzerland, Thailand, United Kingdom, the United States and Uruguay.