Our Privacy Arrangements

Who we are

We are Davos & Miles Ptd Ltd, ABN 66 675 226 614, holder of Australian Financial Services Licence number 556158, trading as Davos & Miles Wealth Partners.  We are located at Tower 5, Level 23, 727 Collins Street, Docklands, Vic 3008

 What is the purpose of this policy?

This policy provides you with information about:

  • The personal information that Davos & Miles collects about you

  • How we handle your information, including how we use, disclose and keep it secure, and

  • How you can access your personal information or make a complaint about our handling of your information.

As a business operating in Australia, we are required to adhere to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act), which regulate the collection, storage, use, and disclosure of personal and sensitive information. In addition, they also give individuals the right to access and correct any personal information that we have collected about them.

 What information do we collect, and why?

We only collect personal information that is required for us to provide financial services to you and to satisfy our own legal obligations as the holder of an Australian Financial Services Licence.  Typically, we will collect this information directly from you, using a combination of meetings and questionnaires, or via our website where you send a request that includes personal information.  We may receive information about you from third parties, such as your Accountant or other professionals, where you have authorised this in writing. 

We do not utilise any standard personal identification reference numbers (such as Tax File, Medicare or Centrelink numbers) as identifiers.

 The types of information we collect includes:

  • Demographic information such as your full name, address, date of birth, nationality, marital status, gender and dependent details,

  • Verification of your identity to ensure compliance with AML/CTF laws, such as sighting an original or certified copy of your drivers' licence, passport or other primary identification,

  • Financial information including details of your superannuation, investments, liabilities, savings,

  • Tax file number (we will require you to separately authorise our collection and use of this),

  • Sensitive information such as Personal health and medical information (where required) to assess your eligibility for personal risk insurances, and

  • Information about your financial needs, goals and objectives.

It is important that you provide us with complete and accurate information, as we use this to develop appropriate strategies and research suitable financial products that suit you.  While we will take all reasonable steps to verify the information you have provided us is complete and accurate, we are not responsible for advice that is defective based upon incomplete or inaccurate information provided by you.  Should you choose to give us incomplete or inaccurate information, you will need to consider the appropriateness of our recommendations in the context of your full circumstances. 

 How will your information be stored?

We store all personal information in electronic format in facilities we own, or in secure cloud-based storage.  We do not retain any hard-copy files. 

We maintain high data security standards to reduce the risk of unauthorised access to your information. However, should a data breach occur, we will contact you to notify you of the information that was compromised.  In certain data breach situations, we will also be required to report to the Office of the Australian Information Commissioner.

Any original documents given to us will be returned to you after we have scanned them.  We are required to retain most records for at least 7 years, or longer where legally required.

How will we use and disclose your information?

We only use and disclose your personal information for the purpose of providing you with financial services, to carry on our financial services business compliantly and to seek legal advice about our affairs. 

The information we collect will be used to develop an appropriate financial strategy to achieve your short, medium and long-term goals, and determine which financial products (if any) should be acquired or replaced.  Our support staff and outsourced contractors will have access to this information as required to assist with the development of your financial strategy.

Where we accept your instruction to acquire a financial product, we will disclose your relevant personal information to the financial product issuer. 

We may also disclose your information to other third parties where required to deliver our financial services to you, or as required by law. These parties include issuers of financial products, life risk insurers, outsourced service providers such as paraplanning, administration support, auditors, accountants, or quality assurance.  In some instances, these providers may be based overseas.  We currently have outsourcing arrangements that access and store data in the United States and Canada.  

Where your information is shared with a third party outside Australia, we will take reasonable steps to satisfy ourselves the third party has arrangements to comply with the Australian Privacy Principles.

If we merge with, or are acquired by another business, your details may be transferred to the new entity, who will be assigned the servicing rights for the ongoing management of your financial products and review services.  Should this occur, we will always write to you and provide the opportunity to opt out.

 How can you access or correct the information we hold about you?

We will take reasonable steps to ensure that the personal information we hold about you is accurate, up to date, relevant and complete, including when it is used or disclosed.  If you identify inaccuracies with the information we hold, or there are changes to your circumstances, you can contact us to correct or update the information we hold.  If we do not agree with your corrections, we may refuse to update the personal information, in which case we will provide you with a written explanation as to why.

The Privacy Act allows you to seek access to your personal information.  To request access, please contact our Privacy Officer at frank.varallo@davosandmiles.com, or on (03) 9977 9693.  There are certain circumstances however when we may not be required to provide access to this information, in which case a written explanation will be provided.

 How can you complaint about our handling of your information?

If you have a complaint about how we have collected, used or stored your personal information, you can direct your complaint to our Complaints Manager at frank.varallo@davosandmiles.com.  Alternatively, you may contact the Office of the Australian Information Commissioner by submitting a complaint through their online form, or by contacting them at:

Privacy Complaints

GPO Box 5288

Sydney NSW 2001

 Phone: 1300 363 992

Fax:  02 6123 5145

How we handle complaints

At Davos & Miles Wealth Partners, we view complaints as an opportunity to improve our advice and services to our clients.  If you are dissatisfied with our services, we will take your concerns seriously, and in doing so, we expect you to treat our staff with respect when they manage your complaint.

How can I complain?

Initially, we recommend speaking to your adviser to explain why you are not satisfied.  It's possible that discussing your concerns openly may enable them to be resolved to your satisfaction.

If you are not comfortable raising the concerns with your adviser, or you have already done so and are not satisfied with their response, you can contact us in one of the following ways:

If you need help making a complaint, please let us know and we will take reasonable steps to provide the assistance you need. 

When you complain, we need as much information as possible to enable us to understand your concerns, so we can investigate these thoroughly.  It would be helpful if you are able to tell us:

  • Your full name and how we can contact you,

  • What your complaint is about, including who you have been dealing with at Davos & Miles and

  • How you would like your complaint resolved.

What happens when we receive your complaint?

When we receive your complaint, we will acknowledge receipt within 24 hours.  We may need to contact you to obtain further information so that we have a full understanding of the cause of your concern. 

We will investigate your concerns and provide a written response to your complaint within 30 days.  If there are complexities with obtaining information that make it difficult to respond within 30 days, we will write to you to inform you of the reasons for the delay.

In some instances, we may be able to resolve your complaint to your satisfaction within 5 days.  In these cases, we will ask you to confirm that you are satisfied with the outcome, and a written response may not be required. 

What if I'm not satisfied with your response?

If you are not satisfied with our response to your complaint, or if we do not respond within 30 days, you are entitled to escalate the matter to the Australian Financial Complaints Authority (AFCA), of whom Davos & Miles is a member (membership number 106287).

 You can complain to AFCA by:

Australian Financial Complaints Authority Limited

GPO Box 3

Melbourne, VIC 3001