Privacy

Privacy Policy.

Our Commitment

Sensibly is committed to providing you with the highest levels of client service. We recognise that your privacy is very important to you. The Privacy Act 1988 and the Australian Privacy Principles set out requirements for how personal information must be handled. Our aim is to support and ensure compliance with these requirements. Further information on privacy in Australia may be obtained by visiting the website of the Office of the Australian Information Commissioner.

This Privacy Policy discloses the purpose, and how the personal information you provide to us and our representatives, is collected, used, held, disclosed and disseminated. We encourage you to check our website regularly for any updates to our Privacy Policy.

Your Personal Information

As a financial service provider, Sensibly is subject to certain legislative and regulatory requirements under s961B of the Corporations Act and the Anti-Money Laundering and Counter-Terrorism Financing Act 2006. These require us to obtain personal information about you including:

your name, contact details, date of birth, tax file number
proof of your address, and ID (Australian Driver License or Australian Government issued ID or International Passport)
information regarding your dependents and family commitments
your occupation, and employment history
your financial needs and objectives;
your assets, liabilities, income, expenses insurances, and social security entitlements

How We Collect Personal Information

Sensibly collects personal information directly from you or from third parties once authorisation has been provided by you. You have the right to refuse us authorisation to collect such information from a third party.

How We Use Your Personal Information

Primarily, your personal information is used in order to provide advice to you. We may also use the information for purposes related to the primary purpose where it is reasonable for you to expect the information to be disclosed.

We use the Document Verification Service (DVS) to verify a customer’s identity by confirming that the details on their identity document match the government’s records. The DVS can also confirm that the details are still valid and not expired or cancelled.

We do not give you the option of dealing with us anonymously, or under a pseudonym. This is because it is impractical, and, in some circumstances, illegal for us to deal with individuals who are not identified.

We may record client meetings, phone calls, inbound calls or video conferences where you have been notified and, where required, have consented to the recording. Recordings may be used to help us maintain accurate records of our discussions, prepare file notes, confirm instructions, prepare client summaries, generate call summaries, update our client management system, complete follow-up actions, support compliance reviews and assist with the preparation of financial advice documents.

We may use transcription services, call recording systems, artificial intelligence tools and other technology systems to convert meeting or call recordings into written transcripts, summaries, file notes, tasks or other client records.

We may store transcripts, AI-generated summaries, call summaries, file notes and related information in our client management system and other approved business systems.

We may also use technology systems, automated tools and artificial intelligence tools to assist with file notes, client summaries, advice preparation, strategy research, document drafting, workflow management, compliance support, administration and client service.

The information used for these purposes may include your name, contact details, identification information, family circumstances, employment details, income, expenses, assets, liabilities, superannuation, insurance, investment, social security, aged care, estate planning information, financial objectives, needs, preferences, instructions and other information relevant to the services we provide.

We do not use artificial intelligence or automated tools to make final financial advice recommendations without appropriate human review. Financial advice recommendations, strategies and advice documents are reviewed by appropriately authorised persons before being provided to you.

We only use approved technology systems, automated tools, artificial intelligence tools and service providers for client-related work. We take reasonable steps to ensure those tools and providers are subject to appropriate privacy, confidentiality and security controls.

We do not permit client personal information to be used to train external artificial intelligence models unless the information has been de-identified or you have consented to that use.

From time to time, we may provide you with direct marketing material. If, at any time, you do not wish to receive this information any further, you may contact us with this request. You will be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you. You may “opt out” from receiving these communications, such as newsletters, emails and other marketing and promotional materials, by clicking on an unsubscribe link at the end of an email. We maintain details of the source of your personal information used for direct marketing and you have the right to request these details. We will endeavour to meet any requests within 2 weeks. We maintain a Register for those individuals not wanting direct marketing material.

When We May Disclose Your Personal Information

In line with modern business practices common to many financial institutions and to meet your specific needs we may disclose your personal information to the following organisations:

superannuation fund trustees, insurance providers, fund managers and other product providers in order to manage or administer your product or service;
compliance consultants;
paraplanning contractors or temporary staff to handle workloads during peak periods;
mailing houses;
insurance reference bureaus and loss adjusters
our professional advisers, including your solicitor or accountant as authorised by you;
information technology, cyber security, cloud storage, document management and client relationship management service providers;
call recording, telephony, transcription and artificial intelligence service providers;
meeting recording, video conferencing and communication service providers;
artificial intelligence tool providers, where used to assist with file notes, client summaries, call summaries, advice preparation, document drafting, compliance support, workflow management, administration or client service;
client relationship management, workflow management and client record management system providers;
another authorised representative of Sensibly if necessary;
a potential purchaser/organisation involved in the proposed sale of our business for the purpose of due diligence, corporate re-organisation and transfer or all or part of the assets of our business. Disclosure will be made in confidence and it will be a condition of that disclosure that no personal information will be used or disclosed by them;
a new owner of our business that will require the transfer of your personal information;
government and regulatory authorities, as required or authorised by law.

Our employees and the outsourcing companies/contractors are obliged to respect the confidentiality of any personal information held by Sensibly.

As members of the Financial Advice Association Australia, we are required to meet a level of professional standards. From time to time, we may need to provide the Association with access to your personal information to ensure that we are meeting our compliance requirements.

The Corporations Act has provided the Australian Securities and Investments Commission with the authority to inspect certain personal information that is kept on our files about you.

We collect information about you for the purpose of reporting to AUSTRAC under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006.

The most common examples of who we may share your personal information with are:

Sensibly related companies
Financial product and credit product providers
Financial planning software providers
External service providers, such as technology service providers, telephony providers, call recording providers, transcription providers, artificial intelligence tool providers, paraplanning providers, document preparation providers and administration services
Accountants, mortgage brokers, solicitors and other professionals you nominate

We may also disclose personal information to other individuals and companies where necessary to provide you with products and services or for our business operations. In some circumstances, we may be required by law to disclose your personal information to regulators, government agencies or law enforcement agencies.

We may disclose your personal information to service providers who operate outside Australia including New Zealand, Japan, South Africa, USA, member states of the European Union, India, Vietnam, Thailand and the Philippines. The purpose of such disclosure is to facilitate the provision of financial services and related business operations, including the preparation of financial advice documents, file notes, client summaries, call summaries, transcription, technology support, artificial intelligence assisted tools, administration, compliance support and document preparation. Your adviser may enter into their own outsourcing arrangements to countries other than those listed above. If so, your adviser will disclose these arrangements separately to you. All reasonable steps will be taken to ensure that offshore service providers comply with the Privacy Act and handle personal information in accordance with appropriate privacy, confidentiality and security obligations.

How We Store and Secure Your Personal Information

We keep your personal information in your client files or electronically. These files are accessible to authorised personnel only and are appropriately secured and subject to confidentiality requirements.

Call recordings, meeting recordings, transcripts, AI-assisted outputs, AI-generated summaries, call summaries, file notes, client summaries and draft advice documents are treated as client records and confidential information. Access to this information is limited to authorised personnel, representatives, contractors and service providers who need the information to provide services to you, support our business operations, meet our legal and regulatory obligations, or assist with compliance, supervision and dispute resolution.

We take reasonable steps to ensure that personal information used in approved technology systems, call recording systems, transcription services, artificial intelligence tools and client management systems is protected from misuse, interference, loss, unauthorised access, modification or disclosure. These steps may include access controls, confidentiality obligations, system security settings, approved provider arrangements and internal procedures for the use of client information.

Personal information is treated as confidential information and sensitive information is treated as highly confidential.

It is a legislative requirement that we keep all personal information and records for a period of 7 years. Should you cease to be a client of ours, we will maintain your personal information on or off site in a secure manner for 7 years. After this, the information may be destroyed.

Automated Decision-Making

We may use computer programs, automated tools or artificial intelligence tools to assist with administrative, analytical, document preparation, compliance, workflow and client service tasks.

These tools may assist us to organise information, prepare summaries, identify missing information, generate call summaries, support workflow management, prepare draft documents, update client records or assist with compliance checks.

We do not use automated tools to make final financial advice recommendations without human review.

If we use personal information in a computer program to make or assist with decisions that could reasonably be expected to significantly affect your rights or interests, we will include information in this policy about the kinds of personal information used and the kinds of decisions made.

Ensure Your Personal Information Is Correct

Sensibly takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. To ensure we can maintain this level of accuracy and completeness, we recommend that you:

inform us of any errors in your personal information; and
update us with any changes to your personal information as soon as possible.

If you provide inaccurate or incomplete information we may not be able to provide you with the products or services you are seeking.

Unsolicited personal information

We don't usually collect unsolicited personal information. Where we receive unsolicited personal information, we'll determine whether or not it would have been permissible to collect that personal information if it had been solicited. If we determine that collection would not have been permissible, to the extent permitted by law, we'll destroy or de-identify that personal information as soon as practicable.

Access to Your Personal Information

You have a right to access your personal information, subject to certain exceptions allowed by law. We ask that you provide your request for access in writing (for security reasons) and we will provide you with access to that personal information. Access to the requested personal information may include:

providing you with copies;
providing you with the opportunity for inspection; or
providing you with a summary.

If charges are applicable in providing access to you, we will disclose these charges to you prior to providing you with the information.

Some exceptions exist where we will not provide you with access to your personal information if:

providing access would pose a serious threat to the life or health of a person;
providing access would have an unreasonable impact on the privacy of others;
the request for access is frivolous or vexatious;
the information is related to existing or anticipated legal proceedings between us and would not be discoverable in those proceedings;
providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
providing access would be unlawful;
denying access is required or authorised by or under law;
providing access would be likely to prejudice certain operations by or on behalf of an enforcement body or an enforcement body requests that access not be provided on the grounds of national security.

Should we refuse you access to your personal information, we will provide you with a written explanation for that refusal.

Using Government Identifiers

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

Dealing with us anonymously or using a pseudonym

You have the option to deal with us by not identifying yourself or by using a pseudonym where it is lawful and practicable to do so. For example, if you telephone requesting our postal address.

Your sensitive information

Without your consent we will not collect information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or afflations, membership of professional or trade association, membership of a trade union, details of health, disability, sexual orientation, or criminal record. Should we ever undertake direct marketing, we will only use or disclose your sensitive information with your consent.

This is subject to some exceptions including when:

collection is required by law; and
the information is necessary for the establishment, exercise or defence of a legal claim.

Our Website

Sensibly’s website may provide links to third party websites. The use of your information by these third-party sites is not within our control and we cannot accept responsibility for the conduct of these organisations. Other websites are not subject to our privacy standards. You will need to contact or review those websites directly to ascertain their privacy policies.

You may register with us to receive newsletters and other information. By doing so, your name and email address will be collected and stored on our database. We take care to ensure that the personal information you give us on our website is protected. For example, our website has electronic security systems in place, including the use of firewalls and data encryption.

If you do not wish to receive any further information from us, or you wish to update your registration details, please email your request to us. We will endeavour to meet your request within 5 working days.

Our Website utilises cookies to provide you with a better user experience. Cookies also allow us to identify your browser while you are using our site - they do not identify you. If you do not wish to receive cookies, you can instruct your web browser to refuse them.

Complaints Resolutions

Please contact privacy_officer@sensibly.com.au if you wish to complain about any breach or potential breach of your privacy rights. We will refer your complaint to our Privacy Officer who will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the determination of our Privacy Officer. If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner at www.oaic.gov.au.

Spam Policy

Spam is a generic term used to describe electronic ‘junk mail’ - unwanted messages sent to a person’s email account or mobile phone. In Australia, spam is defined as ‘unsolicited commercial electronic messages’.

The Australian Communications and Media Authority (ACMA) is responsible for enforcing the provisions of the Spam Act. Additional information about the Spam Act and ACMA’s role is available from the ACMA website.

‘Electronic messaging’ covers emails, instant messaging, SMS and other mobile phone messaging, but does not cover normal voice-to-voice communication by telephone.

Sensibly complies with the provisions of the Spam Act when sending commercial electronic messages.

Equally importantly, Sensibly makes sure that our practices are in accordance with the Australian Privacy Principles in all activities where they deal with personal information.

Internal Procedure For Dealing With Complaints

The three key steps Sensibly follows:

Consent - Only commercial electronic messages are sent with the addressee’s consent - either express or inferred consent.
Identify - Electronic messages will include clear and accurate information about the person and the Sensibly that is responsible for sending the commercial electronic message.
Unsubscribe - We ensure that a functional unsubscribe facility is included in all our commercial electronic messages and deal with unsubscribe requests promptly.

Comply With The Law Regarding Viral Messages

Sensibly ensures that Commercial Communications that include a Forwarding Facility contain a clear recommendation that the Recipient should only forward the Commercial Communication to persons with whom they have a relationship, where that relationship means that person could be said to have Consented to receiving Commercial Communications.

Comply With The Age Sensitive Content of Commercial Communication

Where the content of a Commercial Communications seeks to promote or inspire interaction with a product, service or event that is age sensitive, Sensibly takes reasonable steps to ensure that such content is sent to Recipients who are legally entitled to use or participate in the product service or event.

Complaints Resolutions

The Spam Act specifies that the person’s consent has been withdrawn within five working days from the date that an unsubscribe request was sent (in the case of electronic unsubscribe messages) or delivered (in the case of unsubscribe messages sent by post or other means).

Please contact privacy_officer@sensibly.com.au if you wish to complain about any breach or potential breach of your privacy rights. Your complaint will be responded to within 30 days.

If you are not satisfied with the outcome of your complaint, you are entitled to contact the Office of the Australian Information Commissioner or, for spam-related complaints, the Australian Communications and Media Authority.

Version 1.05 - July 2026