Privacy Policy

Front Row Financial Management Pty Ltd ACN 168 945 097 as trustee for the FRFM Unit Trust ABN 97 476 145 568 trading as Front Row Financial (Front Row/We/us)

This Privacy Policy describes how Front Row collects and uses information about you. 

Front Row is committed to protecting the privacy of your personal information obtained through its operations as a professional services firm and complying with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. 

In addition to this Privacy Policy, we may also have specific and additional privacy provisions that apply to certain activities and promotions. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions provided to you will apply. 

Your personal information 

Front Row recognises that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that trust seriously. 

Unless you give us explicit consent to act otherwise, the following policy will govern how Front Row handles your personal information and safeguards your privacy. 

What does “personal information” mean?

Personal information is any information about you that identifies you or by which your identity may be reasonably determined. By collecting this personal information we are able to:

  • Assist you in managing your financial needs;
  • Contact you when and where necessary;
  • Ensure that you attain the best possible service; and
  • Identify you and protect you from any unauthorised access to your personal information.

By requesting Front Row to provide you with its’ services, you consent to Front Row using your personal information as set out in this Privacy Policy. If you choose not to provide personal information to us, we may not be able to provide you with our services.

Types of Personal Information Collected

We collect your information to provide our services to you at your request and to ensure that you receive the best possible service from us. We collect your personal information directly from you either in person, over the phone or by email. 

Some of the types of information which Front Row collects include:

  1. Information that you give us:

We may collect information such as your name, date of birth, residential address, email address, telephone numbers and financial information from you to communicate with you and provide our services.

  1. Automatic information:

Front Row may record anonymous information which tells us about visitors to our website but not the identity of those visitors. For example, we may collect information about the date, time and duration of those visits and which pages of our website are being commonly accessed. We may also use “cookies” that are small pieces of information that allow an organisation to track websites browsed by you. You may be able to adjust your browser to disable cookies. However, if you do disable cookies, you may not be able to interact with our website or take advantage of the improved functionality that cookies enable. 

  1. Email communications:

We receive personal information from you when you provide your contact details and email address when you interact with or contact Front Row.

  1. Information relating to your engagement of us:
  1. Information that you provide to us for the purposes of engaging us to provide our services to you, which includes your financial information, residency, employment record information, identity documents, information about your assets, liabilities, income and expenditure, insurance cover and superannuation information.  
  2. Any other information that you send or provide to Front Row.   

How Front Row Collects and Holds Personal Information 

Where possible, Front Row will always collect your personal information directly from you, either in person, over the phone of by email. 

We may also receive information via an intermediary we have a relationship with, such as third-party service providers or contractors engaged to assist in providing our services to you. If we receive your personal information from a third party, it will be protected in accordance with this Privacy Policy.  

As a general rule, we do not collect sensitive information. Sensitive information is a type of personal information and can include, but is not limited to, information about an individual’s health, opinions and beliefs. However, if we do collect sensitive information, it will usually be for the purposes of providing our services and we will seek your consent to collect it. 

Why Does Front Row Collect and Hold Personal Information? 

Generally, we will collect and hold personal information about you for the purpose of providing our services to you. Your personal information is only used for the purpose it was collected for or for such other secondary purposes that are related to that purpose. 

If we intend to use your personal information in any other way than is described in this Privacy Policy, we will disclose this to you and request your consent. 

We collect your personal information for purposes including:

  1. Supplying to you the financial services which you have requested;
  2. Updating you in relation to products or services that have or could be provided to you;
  3. Administering the website,  http://frontrowfinancial.com.au/
  4. Enabling your access to use the website;
  5. Sending you statements and invoices and collecting payments from you; 
  6. Improving the quality of services provided to you; 
  7. Providing you with updates on news and upcoming promotions; and
  8. Sending you marketing communications.

We may use personally identifiable information in a summative form to improve our services and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by us or provided to others as a summary report for marketing, advertising or research purposes.

For us to deliver the requested services to you, it will be necessary to disclose your personal information to other parties such as financial institutions with whom you may apply for financial products.  

We will not otherwise disclose your personal information to other companies without your consent.  

We will not sell, transfer, assign or rent your personal information.  

Personal information is also collected to ensure that the products or services that have been sought from Front Row are effectively and efficiently delivered to you. 

Who would Front Row disclose your personal information to?

Front Row will need to disclose your personal information, where you have consented to us doing so, in providing you with our services or where disclosure is necessary to achieve the purpose for which it was submitted.  

We may need to disclose or transfer your personal information if Front Row is acquired or merged with another entity.

Front Row will, at all times, attempt to ensure that we do not disclose your personal information to a third party where consent for such disclosure has not been given. In all cases where we may be required to disclose information, we will attempt to obtain your direct consent for such disclosure.

Please note that if at any time Front Row is required by law to release information about you, we must cooperate fully. 

We may also disclose your information to investigate, halt or take action regarding illegal activities. 

Direct marketing

Front Row may from time to time use your personal information, such as your email address or contact details, to provide you with information about other services that we offer. 

If at any time you do not wish to receive any information about these services please feel free to contact us on (07) 3162 0046 or by email on enquiries@frontrowfinancial.com.au and we will not send you any further material.

Does Front Row disclose your personal information? 

Front Row stores the personal information collected from you in Microsoft Sharepoint. All our files and information are backed up using the built in sharepoint versioning method along with a backup to an on-premises NAS unit. Microsoft Office 365 accounts are encrypted via password protection along with Multi-Factor Authentication.  All information collected or held by email is hosted in Microsoft Office 365.  

You acknowledge that the servers for Microsoft may be held in countries abroad and you agree to cross-border transfers of personal information.  

Microsoft Office 365, Microsoft OneDrive and Microsoft Sharepoint are contracted services utilised by Front Row for sharing, storage and backup of information and that information remains under the effective control of Front Row and is not released or controlled by Microsoft.  Front Row and Microsoft have an arrangement where Front Row retains sole right of access to the information stored with Microsoft Office 365, Microsoft OneDrive and Microsoft Sharepoint on its secure servers which is password controlled.  Microsoft’s terms of use and privacy policy can be accessed here:   https://privacy.microsoft.com/en-us/privacystatement.

The way we provide our services involves a range of tasks and some of these may be carried out by Front Row or by third party service providers on our behalf, both in and outside Australia. This includes the use of offshore services which includes a sub-contractor of our service provider based in the Philippines. In carrying out these tasks, we will provide our service providers with access to your personal information (including, where relevant, sensitive information and/or credit related personal information). To protect your personal information, we have entered into contracts with our service providers that require them to comply with the Privacy Act 1988 (Cth) and to only use the personal information we disclose to them for the specific purpose of that disclosure, that is to perform the tasks we ask them to perform. 

For the offshore services the privacy policy of our service provider (OSP) under which they collect, use and disclose your personal information can be found at https://affordablestaff.com.au/privacy-policy/. In respect of any of your sensitive information that you provide to us, you consent both to our providing such, where required to perform their services, to OSP and to OSP’s collection, use and disclosure of such sensitive information in accordance with their privacy policy https://affordablestaff.com.au/privacy-policy/.

The security of your personal information 

Front Row will take reasonable precautions to safeguard any personal information we hold about you, either on a physical file or on a computer, from loss, misuse, unauthorised access, modification, or disclosure. 

We strive to ensure the security, integrity, and privacy of the personal information of our clients. To do so, we use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss, modification, unauthorised access, or disclosure. In addition, our employees are obliged to respect the confidentiality of personal information held by Front Row.

However, as the internet is not a secure environment, any information that you send to us via that method is sent at your own risk.

How can you access your personal information and/or seek correction?

At any time, you may give Front Row notice that you wish to access the personal information we hold about you. We will endeavour to handle all requests for access to personal information within a reasonable time. 

You may access and/or request that your personal information be edited or corrected by contacting us in any of the following manners: 

Email: enquiries@frontrowfinancial.com.au 

By Post: Brendan Turnbull, Front Row Financial Management, Unit 1, 86 Dunhill Crescent, Morningside QLD 4170.

By phone: (07) 3162 0046 

We strive to ensure that all personal information held about you is accurate, up-to-date and complete. We rely on the accuracy of personal information to provide you with our services. If you believe the personal information we hold about you is incorrect, we encourage you to contact us to notify us of any change in your personal information. 

We may require you to sign a document stating that you have accessed your information for our records. 

How can you complain about privacy breaches?

If at any time you believe that we have breached our privacy reporting obligations under the Act, or you are not satisfied with the manner in which we have dealt with your personal information, you may lodge a compliant with us by emailing or writing to us.

Emailing us at: enquiries@frontrowfinancial.com.au

Writing to: Brendan Turnbull, Front Row Financial Management, Unit 1, 86 Dunhill Crescent, Morningside QLD 4170.

If you are not satisfied with the response you received from us, you may wish to direct your complaint to the Office of the Australian Information Commission at http://www.oaic.gov.au/  or alternatively:

By phone: 1300 363 992 

In writing: The Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001 

Will this privacy policy change?

We intend to keep our privacy policy current, making this policy subject to change. We may change or update this policy at any time. Changes to this Privacy Policy will be published to our website.