Privacy Policy

Table of Contents

  1. Introduction
  2. Audience
  3. Personal information
  4. Acceptance
  5. Changes
  6. Collection
  7. Use
  8. Disclosure
  9. Security
  10. Accurate and up to date
  11. Retention
  12. Transfer to another country
  13. Limitation
  14. Enquiries

Callouts like this are a summary of our privacy policy and contain the most important and relevant points for you. Please read the full privacy policy because it applies to you.

1 Introduction

Welcome to PortfolioMetrix’s privacy policy, which lays out our plan of action for protecting your privacy. We respect your privacy and take the protection of personal information very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect information that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal information).

The purpose of this policy is to describe the way that we handle personal information.

2 Audience

This policy applies to you if you are:

  • a visitor to our website; or
  • a client or adviser who has invested the products or services that we provide.

This policy applies to you under certain circumstances.

3 Personal information

Personal information includes:

  • information that we collect automatically when you visit or use any of our websites or online services;
  • information collected on registration (see below);
  • information collected in the process of your financial advisor providing advice (whether or not that leads to you becoming a client of the advisor or PortfolioMetrix), producing advice and investing you in financial products and services
  • optional information that you provide to us voluntarily (see below);

but excludes:

  • information that has been made anonymous so that it does not identify a specific person;
  • permanently de-identified information that does not relate or cannot be traced back to you specifically;
  • non-personal statistical information collected and compiled by us; and
  • information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Personal information includes information we collect (i) automatically when you visit or use our website and online tools, (ii) on registration, (iii) collected by your financial advisor and (iv) from you voluntarily. It excludes (i) anonymous, (ii) de-identified, (iii) non-personal statistical, and (iv) public information.

3.1 Common examples

Common examples of the types personal information which we may collect and process include your:

  • identifying information – such as your name, date of birth, or identification number of any kind;
  • contact information – such as your phone number or email address;
  • address information – such as your physical or postal address; or
  • demographic information – such as your gender or marital status.

3.2 Sensitive personal information

Depending on the products or services that you require, we may also collect sensitive personal information, including your:

  • financial information – such as your bank account details, assets and liabilities, cash flow details;

But, we will not collect sensitive personal information in the form of your:

  • sensitive demographic information – such as your race or ethnicity;
  • medical information – such as information about your physical or mental health;
  • sexual information – such as information about your sex life or sexual orientation;
  • criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
  • employment information – including your membership of a trade union; and
  • beliefs – including your political, philosophical or religious beliefs.

4 Acceptance

4.1 Acceptance required

You must accept all the terms of this policy when you choose to contract with PortfolioMetrix, register for, or use any of our services. If you do not agree with anything in this policy, then you must not contract with PortfolioMetrix, register for, or use any of our services.

You may not contract with PortfolioMetrix or register for, or use any of our services if you do not accept this policy.

4.2 Deemed acceptance

By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

4.3 Your obligations

You may only send us your own personal information or the information of another data subject where you have their permission to do so. For example if you are providing financial information relating to your spouse or a related legal entity such as a trust, you need the permissions to do so.

5 Changes

We may change the terms of this policy at any time by updating this web page. We will notify you of any material changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our products or services. If you continue to use the website or our products or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

6 Collection

6.1 On registration

Once you register on our website, you will no longer be anonymous to us. You will provide us with certain personal information when you register on our website or for one of our online tools.

We will use this personal information to provide services and information to you and your advisor as we reasonably think appropriate, and for any other purposes set out in this policy.

We collect certain information on registration, when you register on our website or for one of our online tools.

6.2 On order

When use any products or services from us, you may be asked to provide us with additional information on a voluntary basis (products information or services information). This information is necessary to provide the product or services to you.

6.3 From browser

We automatically receive and record Internet usage information on our server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our websites might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

We collect certain information from your web browser, including your Internet usage information when you visit this website.

6.4 Cookies

We may place small text files called ‘cookies’ on your device when you visit our websites. These files do not contain personal information, but they do contain a personal identifier allowing us to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:

  • granting you access to age restricted content;
  • tailoring our website’s functionality to you personally by letting us remember your preferences;
  • improving how our website performs;
  • allowing third parties to provide services to our website; and
  • helping us deliver targeted advertising where appropriate in compliance with applicable laws.

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our websites or tools where cookies are necessary. Many websites use cookies and you can find out more about them at

We collect certain information from cookies that we may send to your computer to try and give you a personalised experience.

6.5 Third party cookies

Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

6.6 Web beacons

Our websites may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.

We collect certain information from web beacons on our website to compile anonymous information about our website.

6.7 Optional details

You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional products or services, or otherwise use the optional features and functionality of the website.

6.8 Recording calls

We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.

6.9 Purpose for collection

We may use any products information, services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us.

We generally collect and process your personal information for various purposes, including:

  • services purposes – such as providing advice, administration, and management services related to investment products, financial advice, or other services;
  • marketing purposes – such as pursuing lawful related marketing activities;
  • business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
  • legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

Processing includes gathering your personal information, disclosing it, and combining it with other personal information.

We may use your usage information for the purposes described above and to:

  • remember your information so that you will not have to re-enter it during your visit or the next time you access our websites or online tools;
  • monitor website usage metrics such as total number of visitors and pages accessed; and
  • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.

We may use any of your personal information that you provide to us for the purposes that you indicated when you agreed to provide it to us.

6.10 Consent to collection

We will obtain your consent to collect personal information:

  • in accordance with applicable law;
  • when you provide us with any registration information or optional information.

We will get your consent to collect your personal information in accordance with applicable law when you provide us with it.

7 Use

7.1 Our obligations

We may use your personal information to fulfil our obligations to you.

7.2 Messages and updates

We may send administrative messages and email updates to you about our website, online tools and services. We may wish to provide you with information about new products or services in which we think you may be interested. This means that in some cases, we may also send you primarily promotional messages. We will not send you promotional messages unless you have chosen to opt-into them. But, we may send you one message asking you to opt-into promotional messages without you having opted-into promotional messages.

We may use your information to send you administrative messages and email updates to you regarding the website and for marketing purposes where lawful.

7.3 Targeted content

While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a client is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.

We may use your information for targeted content in certain, specified instances.

8 Disclosure

8.1 Sharing

We may share your personal information with:

  • other companies within the PortfolioMetrix group of companies to which we belong and who comply with this privacy policy so as to provide joint content and services like registration, for transactions and client support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications;
  • our product suppliers or service providers under contract who help supply certain products or help with parts of our business operations, including monitoring and management of your account, fraud prevention, bill collection, marketing, technology services (our contracts dictate that these product suppliers or service providers only use your information in connection with the products they supply or services they perform for us and not for their own benefit);

We may share your personal information with third parties for the purposes of fulfilling our obligations to you among other purposes.

8.2 Regulators

We may disclose your personal information as required by law or governmental audit.

8.3 Law enforcement

We may disclose personal information if required:

  • by a subpoena or court order;
  • to comply with any law (including any disclosures required by the Common Reporting Standard or FATCA (Foreign Account Tax Compliance Act as the case may be. );
  • to protect the safety of any individual or the general public; and
  • to prevent violation of our client relationship terms.

We may disclose personal information to third parties if required for legal reasons.

8.4 No selling

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

8.5 Marketing purposes

We may disclose aggregate statistics (information about the client population in general terms) about the personal information to advertisers or business partners.

8.6 Employees

We may need to disclose personal information to our employees that require the personal information to do their jobs. This means we may disclose it to our management, operations, human resources, accounting, audit, compliance, information technology, or other personnel.

8.7 Change of ownership

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.

9 Security

We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.

Our website is hosted on a secure server and uses security measures to prevent interference by intruders.

10 Accurate and up to date

We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information. You are able to review or update any personal information that we hold on you at any time by accessing your account online, emailing or phoning your financial advisor. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.

Please keep your personal information accurate and up to date by accessing your account online, emailing or phoning your financial advisor. You may request access to the data we hold on you at any time.

11 Retention

We may retain your personal information in physical or electronic records at our discretion. We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

  • retention of the record is required or authorised by law; or
  • you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

We will only retain your personal information for as long as is necessary.

12 Transfer to another country

We may transmit or transfer and process personal information outside of the country in which we are providing the product or service.

Personal information may be processed or stored on servers located outside the country in which we are providing the product or service, and whose laws protecting personal information may not be as stringent as the laws in the country in which we are providing the product or service. PortfolioMetrix will however ensure that any such transfer complies with the Data Protection Laws of the country in which we are providing the product or service and that the data it is given the same levels of protection as required under these laws. You consent to us processing your personal information in a foreign country in compliance with the Data Protection Laws of the country in which we are providing our services.

We may transfer your personal information outside the country in which it was collected.

13 Limitation

We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites or online tools.

14 Enquiries

If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us. See details on

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