Westbridge Funds Management Privacy Policy
At the Momentum Wealth Group (MW Group), we recognise and respect the importance of privacy and are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth). This Privacy Policy applies to all pages on our website, as well as MW Group marketing activities, products, services, and existing client database. This Privacy Policy governs our data collection, processing and usage practices. It also details the ability to apply your preferences and your rights regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the website.
If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at info@momentumwealth.com.au or by mail to MW Group, Level 1, 38 Station St, Subiaco, 6008.
Information collected on any MW Group website, or through any marketing activities or from existing client, employee, contractor and subcontractor databases will belong to the MW Group and may be utilised for direct marketing activities by any other MW Group companies.
As at the date of this Privacy Policy, the MW Group of companies includes Momentum Wealth Property Pty Ltd, Momentum Wealth Finance Pty Ltd, Momentum Wealth Property Advisory Pty Ltd, Momentum Wealth Investment Planning Pty Ltd, Momentum Wealth Projects Pty Ltd, Westbridge Commercial Pty Ltd, MW Group Business Services Pty Ltd, MW Group Communications Pty Ltd, Westbridge Funds Pty Ltd, Westbridge Property Securities Limited and Westbridge Asset Management Pty Ltd.
What personal information do we collect, hold and how do we use it?
The MW Group collects and holds personal information from clients, customers, employees, contractors and other individuals. We collect and hold this information when it is necessary for business purposes, predominantly to facilitate the services we provide to our clients. Initially, the most common types of personal information we collect and hold relate to the contact details and organisational roles of our clients, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing professional services to our clients, we may collect and hold more detailed personal information relating to our business proceedings e.g. assets, liabilities, financial situation and health. We provide any information needed to those with whom we deal with, on your behalf, to implement your financial, investment and insurance strategies and or manage your financial affairs.
We also use your information to enable us to manage your ongoing requirements e.g. financial affairs, introducing you to our related entities services and/or managing our relationship with you (e.g. invoicing, additional services, clients surveys.) We may do so by mail or electronically unless you tell us you do not wish to receive electronic communications.
From time to time, we will use your contact details to send you direct marketing communications including offers, updates, events, articles, or newsletters that we think will be of interest to you. We always give you the option of electing not to receive these communications in the future. You can unsubscribe at any time by notifying us via the contact details in this Policy or by visiting our email preference centre and we will no longer send this information to you.
Providing the personal information of another person
If at any time a person provides the personal information of another person, he or she must ensure that the other person has read and understood this Privacy Policy and separately consents to that personal information being used and disclosed by us in accordance with this Privacy Policy.
What if you don’t provide some information to us?
We can only fully advise you about your financial affairs if we have all the relevant information. If you do not provide us with some or all of the information that we ask for, we may not be able to advise or assist you.
You can contact us without using your name or by using a pseudonym. However, we may need your name or contact details to respond to you.
How do we store/hold and protect your personal 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. We keep personal information only for as long as is reasonably necessary for the purpose for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
We hold the information we collect from you in our client files, in our CRM database and on our internal computers and servers. Our information technology service providers may use external servers for offsite back up and we may keep external hard-drives stored offsite. In some cases, your file is archived and sent to an external data storage provider for a period of time.
We ensure that your information is safe by limiting access to your data to authorised personnel only with password login access to electronic files. We maintain physical security over our paper and electronic data and premises, by using locks and security systems.
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites we may request that you provide Personal Information about yourself to enable you to access or receive some of our content. The registration and contact forms enable visitors to opt into the MW Group’s mailing lists and require visitors to give contact information. If available, we also collect acquisition data (such as site referrals, campaign tracking, and search data), behavioural data (such as pages visited, time spent on our website and numbers of visits), and technical data (such as browser and devices used to access our website). This data is collected and associated with your personal information when website forms are completed, or if logged into a website. Notice is given at the point of collection to enable visitors to choose whether or not they consent to the terms of collection and use. Those who have registered and subsequently wish to withdraw may opt out of receiving future direct marketing communications at any time (refer to Unsubscribe section of this policy).
In-Person and Telephone Enquiries
We use information collected over the phone and in-person to contact clients and prospective clients with information and promotional material about the MW Group or their products and services. Clients and prospective clients who do not register to receive marketing material may still be contacted by a consultant about their enquiry. If a client or prospective client no longer wishes to receive contact from their MW Group consultant, they can advise us using the contact details in the first section of this Privacy Policy.
Review Platforms
The MW Group may engage with customers through review platforms such as Google Review. We aggregate reviews that have been posted publicly and willingly by users on the review platforms. The use of this information sent via review platforms is governed by the individual platform’s security and privacy regulations. From time to time, we may use this posted data for marketing materials and promotions.
Cookies, Web Beacons, Advertising Features, and Pixel Tags
Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. We use first-party cookies to track a user’s experience through our website so we can analyse trends and patterns to provide better and more relevant user experiences. We also use Advertising Features such as Google Signals through our Web Analytics Provider. These enable us to associate visitation information with Google information for users who have enabled Ads Personalisation through their Google Account, helping us to better understand the user journey across devices and deliver relevant content and offers to users. You can manage or opt-out of these Advertising Features by updating your Ad Settings.
Some of our business partners, such as our Google Advertising provider, also use cookies on our Website (e.g. third-party cookies). These cookies are used to track visitor behaviour and enable us to deliver relevant offers to users who have previously visited our Website across other third-party sites across the Internet. . This Privacy Policy covers the use of cookies the MW Group only and does not cover the use of cookies by any third parties. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.
A web beacon is a clear picture file used to keep track of your navigation through a website. Along with cookies, web beacons help us gain an understanding of how users navigate through and process the content contained in those websites. On occasion we will advertise on third-party websites, including through the use of Google AdWords or display advertising. As part of the tracking process for advertising campaigns we may at times use web beacons to count visitors who have come to the website after being exposed to advertising on a third-party site.
The MW Group uses pixel tags and other methods to gather information about the emails it sends to registered website visitors and recipients of emails sent by MW Group visitors to others. Pixel tags are small graphic files that are included in HTML-encoded email messages. When these messages are opened in an HTML-capable email program, the recipient’s computer will access MW Group’s servers to retrieve the pixel tag file, allowing MW Group to record and store information such as an email address, date and time the recipient viewed the email message if the recipient’s email program is capable of receiving HTML and other logging information. MW Group uses this information to optimize delivery of future messages to specific recipients and to provide information to registered users with respect to emails they send through the MW Group systems.
Log Files
When you use our website we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by MW Group to provide statistics regarding use of MW Group Websites to determine how engaging our content is. The systems we use may link this data automatically to Personal Information collected such as name, email address, address, and phone number. However, you can choose to also browse our website anonymously via browser settings.
Information we collect from third parties
If and when we partner with external parties for marketing campaigns, we may receive Personal Information about you from third-party sources including partners which work with publicly available sources such as social media websites.
We Never Sell Personal Information
We do not sell, trade or rent your Personal Information to others. You will be notified of, and consent will be requested in any joint partnerships where we may share your information. Our partner may request the information from you separately. In all cases, you will be notified and consent will be requested.
Use of Personal Information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:
- contact you as part of a survey, or for feedback on content, or to enquire about your interest in other similar content or our services.
- provide other companies with statistical information about our users – but this information will not be used to identify any individual user.
- meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party.
Use of Navigational Information
We use Navigational Information to operate and improve the website. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalised information about the MW Group.
Customer Testimonials and Comments
We post customer testimonials and comments on our websites, which may contain Personal Information. We obtain each customer’s consent prior to posting the customer’s name and testimonial and will remove any comment should the customer request so.
Use of Credit Card Information
We use a third-party service provider to manage credit card processing. We do not manage this service nor do we have access to the credit card information provided to this service.
Social Media Features
Our websites include Social Media Features, such as the Facebook Like button and Widgets, the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.
External Websites
Our websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and/or other policies they may have.
Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
Reviewing, Correcting and Removing Your Personal Information
You have the following data protection rights:
- You can request access, correction, updates or deletion of your Personal Information.
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information.
To exercise any of these rights, please contact us at info@momentumwealth.com.au or by mail at MW Group, Level 1, 38 Station St, Subiaco 6008. Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
To Unsubscribe from Our Communications
You may unsubscribe from our marketing communications by clicking on the “update preferences” link located on the bottom of our e-mails to update your communication preferences, or by sending us an email us at info@momentumwealth.com.au. Customers may not opt out of receiving transactional emails related to their account with us.
If a person is included on multiple MW Group databases, they will need to specify that they want to opt-out of all MW Group databases, otherwise they may only be opted-out of one company’s database.
Opt-out requests exclude any non-marketing communications that we deliver (by email, post, phone, or other means) that are related to a contract you have signed with us.
Your consent
By asking us to assist with your financial affairs and needs or accessing our web pages, you consent to the collection and use of the information you have provided to us for the purposes described above.
Updating this policy
This Privacy Policy was prepared on 20 September 2023. We may update it at any time. The new version will be published on our website.
Contact
MW Group
Level 1, 38 Station St, Subiaco, 6008