At Totality Wealth Limited, ABN 32 110 128 286 (“Totality, we, our, us”), we are committed to protecting the privacy of our clients. We are bound by the Australian Privacy Principles (APPs) and the Privacy Act 1988 (Cth) (Privacy Act) and will ensure we meet our requirements in our dealings with you.
and our approaches to:
Information which we may collect from you includes, but is not limited to: your full name; date of birth; email address; residential, postal and business address; phone numbers; tax file numbers; drivers licence details; Medicare number; passport details; financial details; occupation; bank account details; and any other information we may consider necessary to undertake our activities.
Where reasonable and practicable, we will endeavour to collect your personal information from you via our client application form; this can either be a paper-based application form or an online application form. We may collect information from you via phone and email also. In certain situations we may collect personal information about you from third parties, such as your introducing broker, financial adviser, accountant, employer, and further those listed under names of entities we may disclose your information to, see below. If we have collected personal information about you from third parties not disclosed in this privacy policy, we will advise you of this as soon as practical, if not at or before the time of collection, the fact that we have collected the information and the circumstances of the collection. Further, we may also request for information from you via market research, surveys and questionnaires, these requests are voluntary.
Once we have collected your personal information, we will store this in our internal CRM system, secured office onsite, or in a secured storage facility.
Where reasonable and practicable, we will endeavour to collect your personal information from you via our client application form; this can either be a paper-based application form or an online application form. We may collect information from you via phone and email also. In certain situations we may collect personal information about you from third parties, such as your introducing broker, financial adviser, accountant, employer, and further those listed under names of entities we may disclose your information to, see below. If we have collected personal information about you from third parties not disclosed in this privacy policy, we will advise you of this as soon as practical, if not at or before the time of collection, the fact that we have collected the information and the circumstances of the collection. Further, we may also request for information from you via market research, surveys and questionnaires, these requests are voluntary.
We collect, hold and use your personal information for the purpose of:
We may disclose your information for such purposes to other organisations:
You have the right to request access to your personal information which we hold. Your access rights are subject to some exceptions permitted by law. We will respond to your request in accordance with the Privacy Act and any other law which affects this obligation. A fee may be payable if you request a copy of your information. If we deny your access request, we will provide you with written reasons for doing so. If you wish to lodge a complaint in reference to this refusal, you may do so via the details provided in e) below.
We aim to keep the personal information we hold about you up to date. Should any of your personal details change, or if you believe that information, we hold about you is incorrect please let us know so we can correct this. If we refuse your request to correct information, we will generally give you a written reason for the refusal. If you wish to lodge a complaint in reference to this refusal, you may do so via the details provided in e) below.
For any privacy related feedback, or complaints, please send via the Trading Platform or your written request to:
Totality Wealth Limited
Email: Compliance@Totality.com.au
Postal Address: Suite 1, Level 14, 9 Castlereagh St, Sydney NSW 2000, Australia
Phone: +61 2 8267 9000
Fax: +61 2 8267 9050
If you are not satisfied with a response received from Totality in reference to a privacy complaint, or feel that Totality may have breached an Australian Privacy Principle, then you have the right to refer the complaint directly to the Office of the Australian Information Commissioner (OAIC), previously known as Office of the Privacy Commissioner. A complaint form may be lodged via the OAIC website, or via the details below.
For provisions of the Privacy Act, please refer to the website www.oaic.gov.au
Office of the Australian Information Commissioner
Email: enquiries@oaic.gov.au
Phone: 1300 363 992
Address: GPO Box 5218 Sydney NSW 2001
Fax: +61 2 9284 9666
www.oaic.gov.au
As per Totality’s IDR – complaints handling policy, if you lodged a written complaint with Totality, you should receive a response within 1 business day from the date Totality receives the written formal complaint. The written complaint will be dealt by the Compliance department and potentially the Account Executive managing the account. If additional time is required to resolve the complaint, the compliance department will inform you of this. Totality aims to resolve a complaint as soon as possible, and within 30 days.
If you are still not satisfied with Totality’s response, you can then proceed to lodge a formal complaint with OAIC.
Totality may disclose your personal information to related entities and service providers, some of whom may be based outside Australia. In the case of such disclosures, the recipients are likely to be located in Europe including Denmark, Singapore, India and South Africa. You consent to your personal information being transferred to such entities for the purpose of operating your trading account.
Under the Privacy Act you have the right to deal with us anonymously where this is lawful and practicable. For example, this can sometimes be the case when you are enquiring about our products and services. However, in situations where we may need to take instructions from you or implement a change to your account, this may not be appropriate and in compliance with AML/CTF rules and regulations.
While we usually do not need to collect sensitive information about you (such as health information; information about racial or ethnic origin; criminal record information), if we require such information we will generally only collect it with your consent. This is subject to exceptions, such as where the collective is required by law or necessary to establish or defend a legal claim.
If you do not provide us with any requested personal information, this may mean that we are unable to provide you with financial products or services, or potentially pursue the relationship you have as a client with Totality.
If we have received unsolicited personal information regarding you, which we did not solicit, we will as soon as practical, destroy the information, or ensure the information is de-identified. However, if it is information which is provided to us in a situation where it is mingled or attached with information that we have requested, you acknowledge that this information may be held by us as described in this policy.
Totality may from time to time send you information regarding our current and upcoming products and services, events being held by Totality, surveys and/or request for feedback on how we can improve on our products and services to you as a client, or information we may consider of interest to you. Such communication will be sent to you via the personal details you provide to us in the client application form, commonly your registered email address. If you do not wish to receive such information, please email enquiries@totality.com.au or you may submit a request to unsubscribe from receiving such information via the actual communication email.
We collect or store user information on our website by using “cookies” (small files placed on your computer by some websites you have visited) for marketing purposes, such as displaying pages that are more relevant to your preferences.
The security of your personal information is important to us and so we take reasonable steps to protect it from misuse, loss and unauthorized access or disclosure. Such steps include:
At times you can access other organisation’s websites through links on our websites. Please note that we are not responsible for the privacy standards and processes of those organisations and external websites. It is recommended that you read and understand their privacy policy.
In the event that the EU GDPR requires a higher level of protection for the personal data of individuals in EU than local law, Totality shall comply with such stricter requirements.
Pursuant to Article 27 of the EU GDPR, Totality has appointed Saxo Bank A/S as our representative in the EU.