Privacy Policy

SHM Investments Group Pty Ltd (ABN 51 702 578 621) is committed to protecting your privacy and handling your personal information responsibly, lawfully and transparently, in accordance with the Privacy Act 1988 (Cth) and the thirteen Australian Privacy Principles (APPs). This policy applies to our website at https://shminvestmentsgroup.site and to the investment and wealth management services we provide from Perth, Western Australia.

1. Who we are

SHM Investments Group Pty Ltd (ABN 51 702 578 621) is an Australian private company providing investment and wealth management services to individuals, families and businesses, with our principal place of business in Perth, Western Australia.

2. The personal information we collect

Depending on the services you engage us for, we may collect:

• your name, email address and postal address;
• date of birth and identity verification details where required under anti-money laundering and know-your-client obligations;
• information about your financial circumstances, including income, assets, liabilities, superannuation and existing investment holdings;
• your investment objectives, risk profile, time horizon and other information relevant to developing an appropriate investment strategy;
• tax residency and related information where required by law; and
• records of your communications and dealings with us.

We only collect personal information that is reasonably necessary for one or more of our functions or activities, as required by APP 3.

3. How we collect personal information

We collect personal information:

• directly from you, through enquiry and quote forms on this website, by email, and during meetings and correspondence;
• from third parties you authorise us to contact, such as your accountant, solicitor, broker or platform administrator;
• from publicly available sources where it is unreasonable or impracticable to obtain it from you; and
• automatically through our website, via cookies and similar technologies (see section 8).

Where reasonable and practicable, we collect personal information directly from you and take reasonable steps to notify you of the purposes of collection, as contemplated by APP 5.

4. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information so that we can:

• respond to your enquiries and prepare proposals and quotes;
• provide, administer and personalise our investment and wealth management services;
• verify your identity and comply with our legal, regulatory, taxation and anti-money laundering obligations;
• manage accounts, transactions, instructions and reporting;
• communicate with you, including sending market insights and service updates where you have consented or where permitted by law; and
• improve the quality and security of our services and website.

We only use or disclose personal information for the primary purpose of collection, or for a related secondary purpose you would reasonably expect, or as otherwise permitted by APP 6 and the Privacy Act.

5. Sensitive information

We will only collect sensitive information (for example, health information where relevant to insurance-linked or estate planning considerations) with your consent, or where the collection is required or permitted by Australian law.

6. Anonymity and pseudonymity

Where lawful and practicable, you may deal with us anonymously or using a pseudonym. You are able to browse most of our website without identifying yourself; however, we generally need identifying information to provide regulated investment and wealth management services.

7. Direct marketing

We may send you information about our services, market commentary or invitations to events where you have consented or where permitted under APP 7. Every marketing communication will include a simple way to opt out, and you may also opt out at any time by emailing ceo@shminvestmentsgroup.site. We do not sell, rent or trade your personal information to third parties for their own marketing.

8. Cookies and website analytics

Our website may use cookies and similar technologies to operate the site, remember your preferences and gather aggregated, de-identified analytics about site usage. You can control or delete cookies through your browser settings; disabling cookies may affect some site functionality.

9. Disclosure of personal information

We may disclose personal information to:

• professional service providers who assist us to deliver our services, such as custodians, brokers, investment platforms, administrators, auditors, accountants and information technology providers;
• regulators and government agencies, including the Australian Securities and Investments Commission, AUSTRAC and the Australian Taxation Office, where required or authorised by law;
• your nominated advisers, attorneys or family members, where you have given authority;
• courts, tribunals or law enforcement bodies where required by law; and
• a related entity or successor entity in the event of a restructure, merger or sale of part of our business, subject to this policy continuing to apply.

10. Overseas disclosure

Some of our service providers, including cloud hosting and software providers, may store or process data outside Australia. Where personal information is disclosed to an overseas recipient, we take reasonable steps, as required by APP 8, to ensure that recipient handles the information consistently with the APPs, including through contractual safeguards.

11. Data quality and security

We take reasonable steps to ensure the personal information we collect is accurate, complete and up to date, as required by APP 10. We also take reasonable steps to protect personal information from misuse, interference, loss and from unauthorised access, modification or disclosure, as required by APP 11. Measures include access controls, encryption of data in transit, secure storage and staff confidentiality obligations.

We retain personal information for only as long as necessary for our purposes, including to meet statutory record-keeping obligations (commonly a minimum of seven years for financial records), after which it is securely destroyed or de-identified.

12. Access to and correction of your personal information

You may request access to the personal information we hold about you, or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading, as required by APPs 12 and 13. To make a request, email ceo@shminvestmentsgroup.site. We may need to verify your identity before responding and will do so within a reasonable period. We will normally provide access free of charge; where permitted, we may charge a reasonable cost of providing access, which we will advise you of before doing so. If we refuse a request, we will give you written reasons and information about how to complain.

13. Complaints and enquiries

If you have any questions about this policy, or if you believe we have breached the Australian Privacy Principles or the Privacy Act, please contact us by email at ceo@shminvestmentsgroup.site marked “Privacy Enquiry”. We will acknowledge your complaint, investigate it fairly and promptly, and respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au.

14. How to contact us

Privacy enquiries for SHM Investments Group Pty Ltd (ABN 51 702 578 621) can be directed to:

• Email: ceo@shminvestmentsgroup.site
• Post: Attention: Privacy Officer, SHM Investments Group Pty Ltd, Perth WA, Australia

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the law or technology. The current version will always be published on this page. Continued use of our website and services after an update constitutes acceptance of the revised policy.