PRIVACY POLICY

PRIVACY POLICY

Updated: 10th September, 2025.

TFG Australia Pty Ltd trading as HPH Solutions is committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Policy describes our current policies and practices in relation to the collection, handling, use and disclosure of personal information. It also deals with how you can complain about a breach of the privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

What information do we collect and how do we use it?

We collect personal and financial information from you so that we can understand your personal situation and provide advice which meets your needs and objectives. This may include a broad spectrum of information ranging from your name, address, contact details, age and other information about your personal affairs including assets, liabilities, income, expenses, relationships, and health. We also collect information from you to meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act.

We generally collect information directly from you however in some cases we may request your authority to collect it from other parties such as your accountant, insurer, or superannuation fund. If you are a client of HPH Life Pty Ltd, which is a joint venture between TFG Australia Pty Ltd and MBS Insurance WA Pty Ltd, you authorise us to collect information from HPH Life Pty Ltd.

We also collect data from our web site to determine usage patterns, help make the web site easier to use and enable us to better meet the needs of its users in terms of content. Information may be collected through the use of "cookies" exchanged between the web site and your computer. A ‘cookie’ is a small file which remains on your computer and contains information enabling our website to recognise your browser. You have the option to disable the use of cookies on your browser. All information collected via the web site will be subject to the same Privacy outlined in this policy.

We may provide your information to product providers to enable us to collect or amend account information or establish new accounts.

We also use your information internally to manage your ongoing advice and service needs.

From time to time, we may use your contact details to send you updates, articles, newsletters, surveys, or other information we believe may be of interest to you. We will always give you the option of electing not to receive these communications and you can unsubscribe at any time by notifying us.

Your consent

By engaging us to assist with your Financial Planning needs, you consent to the collection, use and disclosure of the information you have provided to us for the purposes described in this document.

What if you don’t provide some information to us?

If you do not provide all the information we request, we may not be able to provide our services to you.

How do we hold and protect your information?

We strive to maintain the relevance, reliability, accuracy, completeness, and currency of the personal information we hold and to protect its privacy and security.

Your information is stored in electronic format in facilities we own or in secure cloud-based storage systems operated by our service providers. Some of these providers store and process data outside of Australia, including in the United States, Canada, and the European Union. This may include information handled through systems used for communicating with you via our website chatbot, recording and storing meeting notes and discussions, and preparing financial modelling and charts relevant to your circumstances.

We only engage providers that have comprehensive data protection technologies, so your data is protected from unauthorised access, use or disclosure. We may also hold some of your information in printed form in our office from time to time. We maintain the physical security of assets and data in our office using locks and security systems.

Information Security Measures

We take a range of information security measures to protect your personal information. Multi-factor authentication (MFA) is used across all systems we access, including tools used for communication, modelling, document storage, and client records, to ensure that only authorised personnel can access your data.

We have also engaged a cybersecurity provider to monitor our systems for threats, including malware, unauthorised access, and malicious activity.

Where possible we prioritise the use of secure, cloud-based platforms to exchange information with clients rather than relying on email, and all uploads to our systems are automatically scanned for viruses and malware.

Will we disclose the information we collect to anyone?

We do not trade, rent or sell your personal information.

To enable us to provide our services, we may disclose your personal information to organisations that support our operations. These may include superannuation fund trustees, product providers, information technology service providers, compliance consultants, and external contractors.  We also engage an Australian company specialising in back-office support. As part of their service delivery, they use resources based in Vietnam. Following appropriate due diligence, we are confident that they meet the standards required under the Australian Privacy Principles when handling your personal information. They will not contact you or disclose your information to any other party without your explicit consent.

We may disclose your information to representatives of HPH Life Pty Ltd, with whom we have a joint venture arrangement for personal insurance advice for all clients of HPH Solutions.

We may disclose your information to others if required to do so by law or in other circumstances which the Privacy Act permits. Your information may also be disclosed in confidence to a potential purchaser or organisation involved in the proposed sale or restructure of our business for the purpose of due diligence or transfer or all or part of our business assets.

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

You may request access to the personal information we hold about you. We will also correct, amend, or delete any personal information that we agree is inaccurate, irrelevant, out of date or incomplete.

If you wish to access or correct your personal information, please contact us and we will attend to your request. We may ask for proof of your identity before acting on your request. We do not generally charge for receiving a request for access to personal information or for complying with a correction request where this involves electronic records. We may however charge you for access where we incur a cost to retrieve the records.

What happens if you want to complain?

If you have any concerns about whether we have complied with the Privacy Act or this Privacy Policy, please contact our Privacy Officer at HPH Solutions, PO Box 157, COMO WA 6952 or email info@hphsolutions.com.au.  We will consider your complaint through our internal complaint resolution process, and we will respond to you within 30 days of you making the complaint.

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