Health Information

We collect your health information where we offer you products with an insurance component or in assessing certain claims, including hardship. We do not use or share that information for any purpose other than the underwriting or administration of your policy, claim or account, or as otherwise notified to you at the time we collect your information.

Sensitive Information

Generally, we do not collect sensitive information about you unless required or permitted by law or where you consent for us to do so. Sensitive information will only be collected if it is relevant to your product or the service or function you are engaging us to provide. If applicable, this will be communicated to you. For example, some forms of biometric data are collected, stored and used to support access and verification procedures as well as fraud prevention. To support the management of COVID-19 related risks and compliance with our local legal obligations, we may collect, store, use or otherwise process some forms of health information.

We will not collect sensitive information about you where this is expressly prohibited by local law.

Sensitive information includes information relating to:

• race
• political or religious beliefs
• sexual orientation and sexual life
• criminal convictions
• membership of professional or trade associations or unions
• biometric and health information
• information about your affiliation with certain organisations, such as professional associations

Why we collect personal information

We collect personal information about you which is reasonably necessary to:

• provide you with quality products, services or transaction opportunities. This may include consumer facing services conducted by Sage Trust Bank Limited and or its related entities (such as consumer banking, insurance or wealth advisory services) or services, advice or investment activity provided and/or undertaken by entities involved in the various corporate advisory and investment activities undertaken by Sage Trust Bank Group Limited and its related entities
• consider applications and approaches you make to us
• conduct marketing and social functions
• maintain your contact details
• fulfil our legal obligations, such as those relating to taxation and anti-money laundering and counter-terrorism financing or prevent fraud or as otherwise authorised by you

Without such information, we may not be able to process your application or provide you with an appropriate level of service.  In such circumstances, we will process your application and provide you with the most appropriate level of service that we can.

How we collect your information

We collect personal information about you directly from you — this can be in person, in documents you give us, from telephone calls, emails, competitions you enter, your access to our website or from transactions you make including via mobile banking. We take reasonable steps to be transparent about how and why we collect personal data.

We may also collect your personal information from joint account holder(s) or third parties including public sources, your adviser(s), employer (or its affiliates), agents, introducers, referrers, brokers, our related companies and service providers (including credit reporting bodies, fraud and financial crime information exchanges and other information service providers).

How we store your information

We keep personal information in physical and electronic records, at our premises and the premises of our service providers, which may include processing or storage in the cloud, which may mean in practice that this information is stored outside Australia. Where this occurs, we take steps to protect the security and integrity of personal information.

We also keep records of our interactions with you (including by telephone, email and online) and of your transaction history.

How we use your information

We use personal information about you for the purpose for which it was provided to us, including to:

• process applications
• administer and manage our products and services (including monitoring, auditing, and evaluating those products and services)
• model and test data (in a controlled environment)
• develop scores, risk assessments and related analytical tools
• communicate with you and deal with or investigate any complaints or enquiries

We may also:

• anonymise your data for our own purposes including market research and new product development
• use personal information about you for the prevention and mitigation of fraud and other financial crimes
• use or permit our affiliates to use your personal information for related purposes to the extent that it is lawful to do so without your express permission. For example, we may from time to time use your personal information to inform you or your employer of investment opportunities or to provide information about products and services which we expect may be of interest to you. However, if you don't want to receive such communications you can tell us by using any of the methods listed below.
  

While we may sometimes - where it is lawful and with your permission if necessary - share personal information with companies we do business with (e.g., in product development, joint venture arrangements or distribution arrangements), we do not sell personal information for marketing purposes to other organisations or allow such companies to do this.

When your information is disclosed

Subject in all cases to local law, we may share personal information within the Sage Trust Bank Group, and may disclose personal information outside the Sage Trust Bank Group:

• to our service providers, who provide services in connection with our products and services (including archival, auditing, accounting, customer contact, legal, business consulting, banking, payment, delivery, data processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services)
• to comply with any legal or regulatory obligations imposed by regulators including those under anti-money laundering or anti-terrorism financing laws, or reasonably arising in connection with legal proceedings.
• to our affiliates
• to your nominated financial adviser with your permission
• for the prevention and mitigation of fraud and other financial crimes
• as contained in the terms and conditions of any specific product or service.
  

We may also disclose your personal information (on a confidential basis) in connection with our operating business and principal investment activities including, but not limited to:

• mergers and acquisitions,
• the management of any parts of our business assets (including divestments and reorganisation),
• the provision of any debt to another party

In some circumstances the parties to whom we disclose personal information may operate outside of Australia or, in the case of data collected within the United Kingdom or European Union, outside the United Kingdom and European Union — this includes locations in the countries listed in the Appendix. Where this occurs, we take steps to protect personal information against misuse or loss and to comply with local law in respect of the transfer of your data from one jurisdiction to another. Those parties, in turn, may make such information available to the governments of such other countries in accordance with local law requirements.

Keeping information accurate and up to date

We take reasonable steps to ensure that all information we hold is as accurate as possible. You are able to contact us at any time and ask for its correction if you feel the information we have about you is inaccurate or incomplete.

Keeping information secure

We use security procedures and technology to protect the information we hold. Access to and use of personal information within Sage Trust Bank Group seeks to prevent misuse or unlawful disclosure of the information — this includes internal policies, auditing, training and monitoring of staff.

If other organisations provide support services, we require them to take appropriate technical and organisational measures to secure the privacy of the information provided to them.

How you can access or correct your information

You can contact us to request access to or correction of your personal information. In normal circumstances we will give you full access or make the requested corrections to your information. However, there may be some legal or administrative reasons to deny these requests. If your request is denied, we will provide you with the reason why (if we can). Where we decide not to make a requested correction to your personal information and you disagree, you may ask us to make a note of your requested correction with the information.

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